Page
1
METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
ON
STRAWBERRY
NURSERIES
IN
OPEN
FIELDS
OR
IN
PROTECTED
ENVIRONMENTS
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
on
Strawberries
Nurseries
Grown
in
Open
Fields
or
in
Protected
Environments
NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
Use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Page
2
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
Page
3
TABLE
OF
CONTENTS
PART
A:
SUMMARY.................................................................................................................................................
6
1.
Nominating
Party
_________________________________________________________
6
2.
Descriptive
Title
of
Nomination______________________________________________
6
3.
Crop
and
Summary
of
Crop
System___________________________________________
6
4.
Methyl
Bromide
Nominated
_________________________________________________
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
6
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
8
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
8
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________
9
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
10
Southeastern
States
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.............................................
12
Southeastern
States
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
__________________________________________
12
Southeastern
States
­
11.
Characteristics
of
Cropping
System
and
Climate______________
12
Southeastern
States
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
13
SOUTHEASTERN
STATES
­
PART
C:
TECHNICAL
VALIDATION..................................................................................
14
Southeastern
States
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________
14
Southeastern
States
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
__
21
Southeastern
States
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_____________________________________________
21
Southeastern
States
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
________________________________________________________________________
22
Southeastern
States
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide
__________________________
23
Southeastern
States
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide
___________________________________________
23
Southeastern
States
­
Summary
of
Technical
Feasibility
____________________________
23
California
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
...........................................................
24
California
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
24
California
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
24
California
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
26
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
...................................................................................................
27
California
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
27
California
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
27
California
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
27
Page
4
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
___
27
California
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
32
California
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide____________________________________________________
32
California
­
Summary
of
Technical
Feasibility
___________________________________
32
PART
D:
EMISSION
CONTROL
................................................................................................................................
33
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
33
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
33
PART
E:
ECONOMIC
ASSESSMENT..........................................................................................................................
34
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
34
California­
22.
Gross
and
Net
Revenue
__________________________________________
34
Southeastern
States­
22.
Gross
and
Net
Revenue
__________________________________
35
Summary
of
Economic
Feasibility
_____________________________________________
38
PART
F.
FUTURE
PLANS
........................................................................................................................................
40
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
41
25.
Additional
Comments
on
the
Nomination
____________________________________
41
26.
Citations
______________________________________________________________
41
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.

LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
6
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
6
Table
A.
1:
Executive
Summary
__________________________________________________
7
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
__________________________
8
Southeastern
States
and
California­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
______________________________________________________________
9
Table
A.
2:
2006
Sector
Nomination
 
Strawberry
Nurseries
___________________________
11
SOUTHEASTERN
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
________
12
Southeastern
States
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
________________________________________________________________
12
Southeastern
States
­
Table
11.1:
Characteristics
of
Cropping
System
___________________
12
Southeastern
States
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________
12
Southeastern
States
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________
13
SOUTHEASTERN
STATES
­
PART
C:
TECHNICAL
VALIDATION
______________________________
14
Southeastern
States
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________
14
Southeastern
States
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________
21
Southeastern
States
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________
21
Southeastern
States
 
Table
16.1:
Effectiveness
of
Alternatives
 
Certain
Weeds
1
_________
22
Southeastern
States
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________
23
Page
5
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_________________
24
California
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request__
24
California
­
Table
11.1:
Characteristics
of
Cropping
System___________________________
24
California
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
25
California
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
25
California
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____________________
26
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
27
Southeastern
States
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________
27
Southeastern
States
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________
27
California
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
27
CALIFORNIA
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
Chemical
Alternatives
to
Methyl
Bromide
Fumigation
 
How
Well
Do
They
Work?
______________________________
29
CALIFORNIA
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
Chloropicrin
Effect
on
Weed
Seed
Viability.
_______________________________________________________________
30
CALIFORNIA
 
TABLE
16.3:
EFFECTIVENESS
OF
ALTERNATIVES
­
Soil
Fumigation
and
Runner
Plant
Production._________________________________________________________
30
CALIFORNIA
 
TABLE
16.4:
EFFECTIVENESS
OF
ALTERNATIVES
­
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries
_____
31
California
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
32
PART
D:
EMISSION
CONTROL
____________________________________________________
33
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
33
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
34
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
34
California­
Table
22.1:
Year
1
Gross
and
Net
Revenue
_______________________________
34
California­
Table
22.2:
Year
2
Gross
and
Net
Revenue
_______________________________
35
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________________________
35
Southeastern
States­
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________
35
Southeastern
States­
Table
22.2:
Year
2
Gross
and
Net
Revenue
________________________
35
Southeastern
States­
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________
35
Southeastern
States
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______
37
California
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
37
PART
F.
FUTURE
PLANS
________________________________________________________
40
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
46
Page
6
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
on
Strawberry
Nurseries
in
Open
Fields
or
in
Protected
Environments
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Southeastern
growers
(
Maryland,
North
Carolina,
Tennessee)
produce
their
transplants
in
open
fields
on
an
annual
basis.
Individual
fields
are
only
planted
to
strawberries
once
every
three
years.
Approximately
eighty­
five
percent
of
transplants
produced
are
exported
to
Florida.

California
growers
produce
their
transplants
over
a
five
year
cycle.
Screenhouses
are
utilized
during
the
first
two
years
and
open
field
plantings
are
used
during
the
last
three
years.
Methyl
bromide
is
only
needed
in
production
years
2
thru
5.
Individual
planting
sites
are
only
planted
to
strawberries
once
every
three
years.
The
fourth
and
fifth
production
years
account
for
22
and
77
percent,
respectively,
of
the
current
methyl
bromide
nursery
usage
in
California.
Transplants
produced
are
distributed
widely
throughout
the
U.
S.
and
other
countries.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
56,291
209
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
strawberry
nursery
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
tomato
production.
­
Quarantine
and
Pre­
Shipment
uses
are
not
included
in
this
CUE.

Methyl
bromide
is
needed
for
strawberry
nursery
production
to
produce
plants
free
of
all
damaging
diseases
and
nematodes
to
meet
state
and
foreign
certification
standards,
as
well
as
prospective
buyer
expectations.
In
addition
to
these
certification­
related
pest
control
concerns,
weed
control
is
also
essential
to
insure
maximum
runner
production
and
prevent
the
spread
of
Page
7
noxious
weeds.
The
available
alternatives
have
thus
far
not
been
found
to
provide
acceptable
levels
of
control
of
the
key
pests
to
depths
of
three
feet.
In
addition,
there
are
no
markets
for
plants
that
do
not
meet
the
certification
standards,
which
means
that
losses
up
to
100
percent
are
possible
when
less
than
required
levels
of
pest
control
occur.
Failure
to
adequately
control
pests
in
transplants
would
jeopardize
the
viability
of
the
transplant
and
fruit
production
industries
in
the
US,
as
well
as
the
viability
of
fruit
production
in
countries
purchasing
U.
S.
plants
(
e.
g.,
Canada,
Mexico,
Spain,
South
America,
and
a
number
of
other
countries).

TABLE
A.
1:
EXECUTIVE
SUMMARY
Region
Southeastern
States
California
AMOUNT
OF
NOMINATION
2006
Kilograms
2,086
53,751
Application
Rate
(
kg/
ha)
413
263
Area
(
ha)
5
204
AMOUNT
OF
APPLICANT
REQUEST
2006
Kilograms
41,453
443,432
Application
Rate
(
kg/
ha)
413
263
Area
(
ha)
100
1,683
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Marginal
Strategy
1,3D+
Pic
1,3D+
Pic
Yield
Loss
(%)
10%
10%

Loss
per
hectare
(
US$/
ha)
$
5,469
$
7,208
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
13.26
$
27.37
Loss
as
%
of
Gross
Revenue
(%)
13%
18%

Loss
as
%
of
Net
Revenue
(%)
46%
61%
Page
8
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE
The
key
alternatives
are
1,3­
D/
chloropicrin,
1,3­
D/
chloropicrin/
metam­
sodium,
and
1,3­
D/
metam­
sodium.
None
of
these
alternatives
provide
an
adequate
level
of
disease
and
nematode
control
throughout
the
root
zone
(
up
to
3
feet
deep).
Additionally,
these
alternatives
generally
provide
little
or
no
control
of
Yellow
&
Purple
Nutsedge
(
Cyperus
esculentus,
C.
rotundus)
(
SE
States
only)
and
a
number
of
other
critical
weed
pests
in
California
(
Table
10.1).
The
state
certification
requirements
(
references
7,
32a,
37a,
43a
listed
in
section
26)
associated
with
the
requesting
states
are
very
high
(
virtually
zero
tolerance
for
any
damaging
diseases
and
plant­
parasitic
nematodes)
in
order
to
minimize
the
prospect
of
spreading
these
nematode
and
disease
pests
to
other
states
and
countries
where
these
plants
are
shipped.

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
All
growers
in
the
affected
states
requesting
methyl
bromide
use
are
dependent
upon
its
wide
pest
spectrum
and
high
level
of
pest
control.

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
(%)
Southeastern
States
Not
Available
Not
Available
California
Not
Available
Not
Available
NATIONAL
TOTAL:
Not
Available
Not
Available
7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE.

Not
applicable.
Please
see
the
discussion
of
each
alternative
for
a
description
of
why
it
cannot
be
used
under
these
situations.

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?

Not
applicable
because
the
alternatives
have
not
been
proven
effective
for
the
control
of
the
target
pests
under
these
conditions.
Page
9
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
SOUTHEASTERN
STATES
AND
CALIFORNIA­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
SOUTHEASTERN
STATES
CALIFORNIA
YEAR
OF
EXEMPTION
REQUEST
2006
2006
KILOGRAMS
OF
METHYL
BROMIDE
41,453
443,432
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
FLAT
FUMIGATION
FLAT
FUMIGATION
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
100
ha.
1,683
ha.

APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
619
395
APPLICATION
RATE*
(
kg/
ha)
FOR
METHYL
BROMIDE
413
263
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
61.9
39.5
DOSAGE
RATE*
(
g/
m2)
OF
METHYL
BROMIDE
41.3
26.3
Page
10
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION
The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:

 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
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
two
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
There
was
a
small
adjustment
for
use
rate
in
one
of
the
applications.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Both
applicants
had
QPS
listed
the
amount
requested
reflects
the
subtraction
of
the
QPS
amount.
 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure.
Page
11
TABLE
A.
2:
2006
SECTOR
NOMINATION
 
STRAWBERRY
NURSERIES*

2006
Strawberry
Nurseries
Sector
Nomination
Southeastern
States
California
Requested
Hectares
(
ha)
100
1,683
Requested
Application
Rate
(
kg/
ha)
413
263
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
41,453
443,432
Nominated
Hectares
(
ha)
5
204
Nominated
Application
Rate
(
kg/
ha)
413
263
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
2,086
53,751
Overall
reduction
(%)
88%

2006
U.
S.
CUE
Nomination
(
kg)
55,837
Research
Amount
(
kg)
454
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
56,291
*
See
Appendix
A
for
complete
description
of
how
nominated
amount
was
calculated.
Page
12
SOUTHEASTERN
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
SOUTHEASTERN
STATES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
SOUTHEASTERN
STATES
­
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
Southeastern
States
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
Purple
nutsedge
(
Cyperus
rotundus)

Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.);
Crown
rot
(
Phytophthora
cactorum);
root­
knot
nematodes
(
Meloidogyne
spp.)
None
of
the
available
alternatives
provide
an
acceptable
level
of
control
of
nutsedge;
the
affected
states'
regulatory
requirements
to
meet
certification
standards
which
amount
to
virtually
complete
control
of
fungal
diseases
and
nematodes,
is
only
attainable
with
methyl
bromide
SOUTHEASTERN
STATES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
SOUTHEASTERN
STATES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTHEASTERN
STATES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Strawberry
Transplants
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
crop,
replanted
in
same
site
once
every
three
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Various
crops
planted
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
93%
medium
and
7%
light
soils,
containing
up
to
2%
organic
matter
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Every
year
OTHER
RELEVANT
FACTORS:
None
identified
SOUTHEASTERN
STATES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
temperate,
zones
6a
to
8b)
6a,
6b,
7a,
7b,
8a,
8b
RAINFALL
(
mm)
163
124
109
87
78
146
113
202
109
116
54
76
OUTSIDE
TEMP.
(
°
C)
9.4
14.5
17.7
23.4
26
25.9
22.6
14.9
7.7
3.4
2.9
4.2
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
X
HARVEST
SCHEDULE
2X
X
*
Macon,
GA
Page
13
SOUTHEASTERN
STATES
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

None
were
identified
as
being
limiting
factors.

SOUTHEASTERN
STATES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
SOUTHEASTERN
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)
82
82
82
55
67
71
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Virtually
all
flat
fumigation
Virtually
all
flat
fumigation
Virtually
all
flat
fumigation
Virtually
all
flat
fumigation
Virtually
all
flat
fumigation
Virtually
all
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
49,386
49,386
33,764
22,900
27,747
29,251
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide/
chloropicrin)
98:
2
98:
2
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
616
616
619
619
619
619
APPLICATION
RATE
OF
METHYL
BROMIDE
IN
kg/
ha*
604
604
413
413
413
413
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
61.6
61.6
61.9
61.9
61.9
61.9
ACTUAL
DOSAGE
RATE
OF
METHYL
BROMIDE
(
g/
m2)*
60.4
60.4
41.3
41.3
41.3
41.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
14
SOUTHEASTERN
STATES
­
PART
C:
TECHNICAL
VALIDATION
SOUTHEASTERN
STATES
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
SOUTHEASTERN
STATES
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
Chloropicrin
Objectionable
odors
in
residential
areas;
little
or
nor
efficacy
on
nutsedge
(
Locascio
1997
&
1999);
in
some
instances
it
caused
increased
emergence
of
nutsedge
(
Motis
and
Gilreath
2002);
very
unlikely
that
the
near­
perfect
levels
of
disease
and
nematode
control
required
by
state
certification
programs
cannot
be
attained
throughout
the
1
m.
root
zone.
Chloropicrin
is
generally
considered
a
good
control
measure
for
certain
diseases
(
Pythium,
Phytophthora,
Fusarium,
Verticillium),
but
is
not
generally
considered
very
effective
for
nematode
or
weed
control.
See
also
chloropicrin
issues
addressed
in
the
fumigant
combination
entries
in
this
section.
No
NON
CHEMICAL
ALTERNATIVES
Biofumigation
Lack
of
adequate
data
on
the
activity
of
biofumigation
materials
on
nutsedge
control;
Based
on
studies
with
other
crops,
allelochemicals
may
cause
phytotoxic
effects
(
Norsworthy
2002;
Johnson
et
al.
1993);
very
unlikely
that
the
near­
perfect
level
of
disease
and
nematode
control
required
by
state
certification
programs
can
be
attained
throughout
the
1m.
deep
root
zone.

Biofumigation
is
not
technically
feasible
because
it
does
not
provide
adequate
control
of
target
pests
to
produce
a
certifiable
strawberry
nursery
stock.
Research
conducted
in
Florida
showed
some
control
of
plant
pathogens
but
no
control
of
nematodes
or
weeds
in
the
soil.
In
cases
where
biofumigation
have
been
shown
to
control
weeds,
the
data
are
mostly
for
small­
seeded
weed
species
that
have
small
carbohydrate
energy
sources
compared
to
nutsedge.
The
data
on
biofumigation
are
too
limited
to
consider
it
as
a
practical
alternative
to
methyl
bromide.

In
addition,
biofumigation
is
not
technically
feasible
because
the
quantity
of
Brassica
crop
needed
to
control
target
pests
would
be
approximately
3
hectares
for
every
hectare
of
strawberry
production.
Incorporation
of
Brassica
at
these
levels
would
be
likely
to
have
allelopathic
effects
on
the
target
crop.
In
the
Southeast,
production
field
trials
with
cabbage
residue
and
tomato
produced
inconsistent
and
inadequate
efficacy,
and
poor
yields
in
two
years
out
of
three.
The
yield
losses
could
range
from
0%
­
50%.
No
Page
15
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Solarization
Even
in
warmer
climates
(
Georgia)
it
is
impossible
to
attain
temperatures
lethal
to
nutsedge
(
50­
55
°
C)
at
depths
below
10
centimeters
(
Miles
et.
al.
2002);
near­
perfect
level
of
disease
and
nematode
control
required
by
state
certification
programs
very
unlikely
to
be
attained
throughout
the
1
m.
deep
root
zone.

Solarization
is
not
a
technically
feasible
alternative
because
it
does
not
provide
adequate
control
of
target
pests
to
produce
certifiable
strawberry
nursery
stock.
Use
of
solarization
is
not
practical
due
to
the
depth
of
heating
required
to
eliminate
viable
weed
seed,
nematodes,
and
disease
organisms.
The
time
for
solarization
to
raise
soil
temperatures
to
the
level
needed
to
kill
soil
pathogens
in
any
strawberry
nursery
region
is
likely
to
also
be
the
time
when
the
crops
themselves
must
complete
their
growth
cycle.
Unpredictable,
stormy
summer
weather
still
creates
risks
and
may
damage
mulch.
In
one
Southeast
field
trial,
solarization
gave
poor
yields
in
two
years
out
of
three
with
losses
ranging
from
0%
to
40%.
No
General
IPM
Nothing
available
for
control
of
nutsedge;
near­
perfect
level
of
disease
and
nematode
control
required
by
state
certification
programs
very
unlikely
to
be
attained
throughout
the
1
m.
root
zone.

IPM,
the
use
of
pest
monitoring
activities
coupled
with
chemical
and
non­
chemical
management
tools,
has
been
adopted
for
management
of
weed,
diseases,
and
nematodes
on
many
crops.
However,
problematic
weeds
like
nutsedge
and
nightshade,
and
soilborne
diseases
and
nematodes
are
not
effectively
controlled
by
these
practices
in
strawberry
nurseries.

General
IPM
is
being
used
in
strawberry
nursery
stock
production,
but
it
is
not
technically
feasible
alone
to
provide
adequate
pest
control.
IPM
practices
include
field
sanitation
to
limit
inoculum
buildup,
crop
rotation
to
provide
non
host
periods,
and
breeding
for
resistance
to
pathogens.
No
Page
16
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Cover
crops
mulching
Cover
crops/
mulching
is
currently
being
used
but
it
is
not
technically
feasible
as
a
complete
replacement
for
methyl
bromide
to
control
the
target
pest
and
certify
the
nursery
stock;
level
of
disease
and
nematode
control
required
by
state
certification
programs
cannot
be
attained.

Cover
crops/
mulching
is
currently
being
used
but
it
is
not
technically
feasible
as
a
complete
replacement
for
methyl
bromide
to
control
the
target
pests
and
certify
the
nursery
stock.
The
use
of
cover
crops
is
a
common
practice
to
improve
soil
structure
and
suppress
an
array
of
soilborne
pathogens.
Cover
crops
and
mulches
have
been
integrated
into
strawberry
nursery
crop
production
systems.

Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
et
al.,
1996;
Galloway
et
al.,
1996).
Cowpea
and
sunn
hemp
have
been
shown
to
suppress
nutsedge,
but
the
effect
is
short
lived,
due
to
the
weed's
capacity
for
rapid
tuber
production.
Allelochemicals
released
by
some
cover
crops
or
organic
mulches
can
injure
crops
(
Johnson
et
al.,
1993;
Norsworthy,
2002).
No
Page
17
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Crop
rotation/
fallow
Growers
typically
utilize
this
practice
by
growing
other
crops
every
2
out
of
three
years;
this
practice
has
not
resulted
in
a
level
of
disease
and
nematode
control
required
by
state
certification
programs
throughout
the
1
m.
deep
root
zone;
no
suitable
nutsedge
controls
available
during
production
of
the
rotational
crops
(
Culpepper
2002).

A
three­
year
crop
rotation/
fallow
is
being
used
in
strawberry
nursery
stock
production,
but
it
is
not
technically
feasible
when
used
alone
to
control
the
key
target
pests.

Although
such
crop
rotation
and
fallow
procedures
are
generally
considered
useful
pest
management
tools
for
weeds,
diseases
and
nematodes,
they
are
rarely
considered
standalone
control
measures.
Significantly
longer
time
frames
may
produce
higher
levels
of
control
for
most
pests,
but
are
generally
considered
impractical
because
of
limited
land
availability
and
high
costs.

There
are
registered
herbicides
that
are
effective
for
nutsedge
control
in
agronomic
crops.
These
herbicides
are
not
available
for
most
fruit
or
vegetable
crops,
and
many
of
them
have
12­
to
26­
month
carryover
restrictions
for
vegetable
crops.

Crop
rotation
and
fallow
will
not
suppress
nutsedge.
Johnson
&
Mullinix
(
1997)
showed
that
uninterrupted
plantings
of
peanut,
corn,
or
cotton,
with
moderate
levels
of
weed
management
suppressed
yellow
nutsedge
in
Georgia.
Their
data
also
showed
an
increase
in
nutsedge
densities
in
fallow
plots,
likely
due
to
the
longevity
of
nutsedge
tubers
in
soil,
mild
winters
that
prevent
winter­
kill
of
tubers,
and
the
ability
of
tubers
to
regenerate
with
the
long
growing
season
in
the
southeastern
coastal
plain.
There
are
also
reports
of
increasing
populations
of
yellow
nutsedge
in
fallowed
fields,
even
when
weed
control/
management
is
performed.
Since
there
are
no
herbicides
registered
for
use
on
strawberry
plants
that
will
effectively
control
nutsedge,
management
of
these
weeds
during
short­
term
rotations
and
fallow
is
not
effective.
No
Soilless
culture
Soilless
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.

Soilless
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.
According
to
data
provided
by
The
National
Center
for
Food
and
Agricultural
Policy,
a
greenhouse
typically
costs
between
US$
12.5
million
and
US$
20
million
per
hectare.
Although
yields
obtained
through
greenhouse
production
are
higher
than
yields
of
the
best
growers,
the
issue
of
capitalization
for
this
and
other
Sectors
make
the
alternative
not
practically
feasible
as
a
near
term
strategy
to
reduce
reliance
on
methyl
bromide..
No
Page
18
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Substrates/
plug
plants
grown
hydroponically
Even
if
effective,
it
would
be
cost
prohibitive
to
change
over
to
the
required
technology.

Substrates/
plug
plants
are
currently
being
produced
and
sold
in
the
southeast
and
to
a
very
limited
extent
in
California
but
this
method
alone
does
not
provide
pest
control
and
would
fail
to
produce
a
pest
free
product.
Furthermore,
this
method
would
require
extensive
retooling
by
the
nursery
industry.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
Little
or
no
efficacy
on
nutsedge
(
Locascio
1997
&
1999);
level
of
disease
and
nematode
control
required
by
state
certification
programs
cannot
be
attained
throughout
the
1
m.
deep
root
zone;
may
be
the
best
alternative
where
nutsedge
is
not
a
problem
(
50%
of
production
area).

The
combination
of
1,3­
D
and
chloropicrin
is
not
technically
feasible
because
it
does
not
adequately
control
nematodes
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3
D
provides
good
nematode
control,
only
moderate
disease
control,
and
poor
weed
control.
A
30.5
meter
(
100
feet)
1,3­
D
buffer
requirement,
to
mitigate
area
resident
exposure,
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas,
which
is
typical
for
the
Southeastern
U.
S.
growers.
Personal
Protective
Equipment
(
PPE)
requirements
also
limit
operations
that
require
workers
in
the
field,
particularly
given
the
high
temperatures
which
occur
in
the
southeast,
which
are
exacerbated
by
high
humidity.
Workers
wearing
the
required
Personal
Protective
Equipment
become
at
risk
for
possible
heat
exhaustion
or
heat
stroke.
For
example,
PPE
may
require
applicators
to
wear
fully
sealed
suits,
with
respirators.
Such
suits
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity,
rapidly
become
unbearable
for
a
typical
applicator.
Growers
believe
that
the
requirements
for
buffers
and
PPE
may
make
it
impractical
to
adopt
1,3­
D.
The
buffer
requirements,
especially
for
the
small
acreage
farms
in
the
Southeastern
U.
S.,
eliminate
so
much
area
around
the
perimeter
of
a
field
that
there
is
very
little
left
that
can
be
treated
using
1,3­
D
alone
to
grow
strawberries.
Chloropicrin
provides
good
disease
control,
but
poor
nematode
and
weed
control.
Workers
complain
about
eye
and
lung
irritation
when
applying
chloropicrin,
which
is
virtually
the
same
as
tear
gas.
No
Page
19
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3­
D
+
chloropicrin
+
metam­
sodium
Little
or
no
efficacy
on
nutsedge;
very
unlikely
that
the
near­
perfect
levels
of
disease
and
nematode
control
required
by
state
certification
programs
cannot
be
attained
throughout
the
1
m.
root
zone.
The
combination
of
1,3­
D,
chloropicrin
and
metam
sodium
is
not
technically
feasible
because
it
does
not
adequately
control
pests
and
diseases
to
the
level
required
by
various
state
laws,
and
therefore
this
decrease
in
efficacy
results
in
yield
losses
in
nursery
plants.
1,3­
D
is
a
good
nematicide
and
chloropicrin
is
a
good
fungicide.
Metam
sodium
provides
moderate
but
unpredictable
disease,
nematode,
and
weed
control
since
it
suffers
from
erratic
efficacy,
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
Metam
sodium
degrades
in
the
soil
to
form
methylisothiocyanate,
which
has
activity
against
nematodes,
fungi,
insects,
and
weeds.
Methyl
bromide
has
a
higher
vapor
pressure
than
metam
sodium,
therefore
can
penetrate
and
diffuse
throughout
the
soil
more
effectively
than
metam
sodium.
In
addition,
the
effectiveness
of
metam
sodium
is
very
dependent
on
the
organic
matter
and
moisture
content
of
the
soil.
Studies
to
evaluate
best
delivery
systems
for
metam
sodium
are
being
conducted.
Some
studies
have
shown
that
soil
injections
and
drenches
are
more
effective
than
drip
irrigation.
Research
trials
show
that
incorporation
of
metam
sodium
with
a
tractor­
mounted
tillovator
provides
good
results
but
most
growers
do
not
have
this
equipment.

A
3­
week
time
interval
before
planting
is
required
to
avoid
phytotoxic
levels;
causing
delays
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profit
or
actually
causing
a
loss
for
a
grower.

The
combination
of
the
three
chemicals
would
still
require
a
companion
herbicide
or
hand
weeding.
Failure
to
control
the
full
spectrum
of
weeds
could
lead
to
increased
disease
pressure
over
time
because
the
weeds
can
be
reservoirs
for
disease
or
harbors
insect
vectors
of
disease.
Also,
in
strawberry
fruit
production,
there
is
demand
for
pest
free
strawberry
root
stock.
The
nursery
growers
who
do
not
supply
this
type
of
product
will
be
forced
out
of
the
market.
No
Page
20
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3­
D
+
metamsodium
1,3­
D
or
metam­
sodium
possess
little
or
no
efficacy
on
nutsedge
(
Webster
et.
al.
2001);
metam
component
is
likely
to
provide
inconsistent
nematode,
weed
and
disease
control
due
to
poor
movement
within
soil;
very
unlikely
that
the
near­
perfect
levels
of
disease
and
nematode
control
required
by
state
certification
programs
can
be
attained
with
this
combination
throughout
the
1
m.
deep
root
zone.
The
combination
of
1,3­
D
and
metam
sodium
is
not
technically
feasible
because
it
does
not
adequately
control
pests
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3­
D
is
a
good
nematicide
and
metam
sodium
provides
moderate
but
unpredictable
disease,
nematode,
and
weed
control.
As
indicated
above,
metam
also
suffers
from
erratic
efficacy,
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
The
combination
of
these
chemicals
would
still
require
a
companion
herbicide
or
hand
weeding.
Failure
to
control
the
weed
seed
in
soil
would
most
likely
lead
to
increased
disease
pressure
over
time.
Also,
in
strawberry
fruit
production,
there
is
demand
for
pest
free
strawberry
root
stock.
The
nursery
growers
who
do
not
supply
this
type
of
product
will
be
forced
out
of
the
market.

As
with
the
other
suggested
combinations
(
above)
there
are
issues
with
the
use
of
Personal
Protective
Equipment
(
PPE)
in
the
hot
or
hot
and
humid
climates
of
California
and
the
southeastern
U.
S.
In
addition,
the
buffer
requirement
of
90
meters
(
300
feet)
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas.
For
small
strawberry
nursery
operations
in
the
southeastern
U.
S.,
the
1,3­
D
buffer
requirements
eliminate
a
large
area
around
the
field
perimeter
which
impacts
the
total
acreage
available
for
strawberry
nursery
production.

Sequential
application
of
each
one
of
these
chemicals
requires
significantly
more
time
than
using
methyl
bromide
alone
since
growers
must
wait
longer
after
fumigation
to
put
the
strawberry
root
stock
in
the
ground.
Growers
have
a
greater
planting
delay
for
several
weeks,
which
will
extend
their
production
schedule.
This
delay
directly
impacts
cultivar
options,
Integrated
Pest
Management
practices,
timing
of
planting
and
harvest
for
strawberry
fruit
production,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
Since
growers
will
require
rootstock
at
a
fixed
time
during
the
year,
the
nursery
plants
could
be
of
lower
grade
and
quality
(
smaller)
causing
loss
to
both
the
nursery
grower
and
the
fruit
grower.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
21
SOUTHEASTERN
STATES
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
SOUTHEASTERN
STATES
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Other
fungicides,
herbicides,
or
nematicides.
There
are
no
other
pesticides
(
with
the
exception
of
iodomethane)
in
the
registration
process
that
can
take
the
place
of
methyl
bromide.

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

Iodomethane
Not
registered
for
any
crop
uses
in
the
US.
Yes
Unknown
Propargyl
bromide
Registration
in
the
U.
S.
has
not
yet
been
requested.
Comparative
performance
data
not
presented
in
any
of
the
studies
submitted.
No
Unknown
Sodium
azide
Registration
in
the
U.
S.
has
not
yet
been
requested.
No
Unknown
Page
22
SOUTHEASTERN
STATES
­
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
Preamble
­
The
following
is
the
only
directly
relevant
study
conducted
thus
far
in
the
southeastern
states.
Another
study
conducted
in
2003
is
nearing
completion.
Neither
study
utilizes
methyl
bromide
(
MB)
as
the
comparative
treatment,
but
rather
uses
methyl
iodide
(
MI)
as
the
principal
alternative
and
compares
it
to
Telone
C­
35
and
an
untreated
control.
Based
on
researchers'
opinions
from
numerous
studies,
MI
when
used
as
a
soil
fumigant
generally
provides
yields
and
levels
of
pest
control
comparable
to
methyl
bromide.
Accordingly,
we
assumed
that
the
results
of
the
available
study
are
representative
of
previous
studies
and
can
be
relied
upon
for
assessing
the
comparative
value
of
the
best
available
alternative
(
1,3­
D
+
35%
chloropicrin).

Given
the
soil
types
present
in
production
areas
the
root
zone
required
to
be
protected
is
generally
as
deep
as
3
feet.
Although
several
of
the
alternatives
provide
adequate
levels
of
pest
control
at
shallower
depths,
none
consistently
provide
suitable
control
levels
at
3
feet.
Failure
to
provide
levels
of
pest
control
at
the
required
depth
will
result
in
inadequate
levels
of
control
which
will
result
in
rejection
of
the
plants
produced
under
these
conditions
(
100%
loss
in
affected
fields).
Accordingly,
the
maximum
loss
estimate
is
listed
as
100%
because
the
various
State
certification
requirements
which
equate
to
a
zero
tolerance
for
disease
symptoms
and
nematodes.

SOUTHEASTERN
STATES
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
CERTAIN
WEEDS
%
MB
Pest
Control
Treatment
Application
Rate
(
kg/
ha)
Nem.
Dis.
Weeds
%
MB
Yield
Comments
Methyl
Iodide
(
100%)
263
NQ
NQ
Assume
100%
Assume
100%
No
methyl
bromide
tested
Methyl
Iodide/
Chloropicrin
(
75:
25)
263/
66
NQ
NQ
92%
81%

1,3­
D/
Chloropicrin
(
Telone
C­
35)
254/
139
NQ
NQ
87%
73%

Source:
Gilreath,
J.
P.,
E.
B.
Poling,
J.
W.
Noling,
2001,
unpublished
study
Key
to
Table
Abbreviations:
NQ
=
not
quantified
(
too
low
and
non­
uniform);
Nem.
=
nematodes;
Dis.
=
diseases
MI
alone
yield
was
statistically
higher
than
the
combination
with
chloropicrin
(
CP)
and
the
1,3­
D/
CP
treatments.
There
was
no
statistical
difference
between
these
later
two
treatments,
however,
they
both
provided
statistically
higher
yields
than
the
untreated
controls.
The
prominent
weeds
present
were
hairy
galinsoga
(
Galinsoga
cillata),
carpetweed
(
Mollugo
verticillata),
and
purslane
(
Portulaca
oleracea).
The
most
difficult
weed
to
control
was
hairy
galinsoga,
with
MI
alone
providing
the
highest
levels
of
control
of
this
as
well
as
the
other
Page
23
weeds.
The
post
treatment
disease
and
nematode
incidence
data
were
too
variable
and
too
low
in
any
of
the
plots
to
formulate
any
conclusions.
The
yield
benefit
exhibited
by
MI
is
likely
to
be
a
combination
of
weed
control
plus
control
of
other
unidentified
microbial
pests.
The
comparative
weed
control
percentages
are
based
solely
on
control
of
hairy
galinsoga.
Note:
Another
similar
study
was
initiated
in
2003
and
was
near
completion
in
December
2003.

SOUTHEASTERN
STATES
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D/
chloropicrin
(
Telone
C­
35)
Certain
Weeds
(
see
above
table)
0­
27%
10%

Metam
Sodium
Certain
Weeds
(
see
above
table)
50%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
10%

SOUTHEASTERN
STATES
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE
Iodomethane
is
in
a
pending
registration
status
and
is
being
evaluated
as
an
alternative.
It
is
generally
considered
to
be
as
efficacious
as
methyl
bromide
for
most
preplant
crop
uses
and
virtually
all
pests.
Growers
can
easily
transition
to
this
alternative.

Dazomet
is
also
in
a
pending
registration
status
as
a
nematicide
on
strawberries.
Based
on
previous
studies
on
other
crops,
it
is
reportedly
not
likely
to
be
a
suitable
alternative
for
strawberry
nurseries.

SOUTHEASTERN
STATES
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE
We
are
not
aware
of
any
that
are
feasible
in
the
short
run.
The
technology
changeover
costs
for
adopting
soilless
culture
techniques
are
extremely
high.
Although
yields
reportedly
obtained
through
greenhouse
production
are
higher
than
that
of
the
best
conventional
growers,
the
issue
of
capitalization
for
this
and
other
sectors
make
the
alternative
not
practically
feasible
as
a
near
term
strategy
to
reduce
reliance
on
methyl
bromide.
No
information
was
presented
on
the
long
term
viability
of
this
option.
Reportedly,
the
organic
strawberry
fruit
production
growers
are
dependent
upon
methyl
bromide
treated
transplants.

SOUTHEASTERN
STATES
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
None
are
considered
technically
feasible
at
the
present
time
due
to
the
high
levels
of
disease
and
nematode
control
required
by
the
current
state
certification
standards.

Since
chloropicrin
is
virtually
the
same
as
tear
gas
worker
eye
irritation
concerns
exist
for
this
option.
Page
24
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
NEEDED
California
Diseases:
Phytophthora
Crown
and
Root
Rots
(
Phytophthora
spp.);
Red
Stele
(
Phytophthora
fragariae);
Verticillium
Wilt
(
Verticillium
dahliae);
and
possibly
others
Nematodes:
Root­
knot
(
Meloidogyne
spp.);
sting
(
Belonolaimus
spp.);
dagger
(
Xiphinema
spp.);
lesion
(
Pratylenchus
spp.);
foliar
(
Aphelenchoides
spp.);
needle
(
Longidorus
spp.);
stem
(
Ditylenchus
spp.)

Weeds:
numerous
weeds
listed
(
e.
g.,
annual
bluegrass,
bur
clover,
carpetweed,
chickweed,
field
bindweed,
goat
grass,
hairy
nightshade,
lambsquarter,
malva,
nutsedge,
pig
weed,
portulaca,
prostate
spurge,
puncture
vine,
purslane,
vetch)
The
State
mandatory
certification
program
has
strict
requirements
for
control
of
diseases
and
nematodes
which
amount
to
virtually
complete
control
of
the
key
pests.
Given
the
growing
situations
encountered
over
the
course
of
the
5­
year
transplant
production
cycle
(
a
different
growing
location
is
used
each
year),
none
of
the
alternatives
have
thus
far
been
shown
to
be
consistently
perform
at
a
highly
effective
level
at
soil
depths
to
3
feet.

Methyl
iodide
is
considered
by
most
researchers
to
be
viable
potentially
alternative,
which
is
currently
proposed
for
registration
in
the
US.

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)
Strawberry
transplants
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
crop,
only
planted
in
the
same
location
once
every
three
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
The
principal
rotational
crops
are
endive,
garlic,
onion,
horseradish,
mint,
alfalfa,
sugarbeets,
and
potatoes.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
80
%
light
soils,
10%
medium
soils
and
10%
heavy
soils;
70%
with
2%
or
less
organic
matter
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Every
year
OTHER
RELEVANT
FACTORS:
No
Page
25
CALIFORNIA
(
LOW
ELEVATION
AREAS;
YEARS
3
&
4)
­
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)
6a,
6b,
7a,
9a,
9b
RAINFALL
(
mm)
16
72.1
17.3
0
trace
1.0
trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
X
HARVEST
SCHEDULE
X
*
For
Fresno,
California.

CALIFORNIA
(
HIGH
ELEVATION
AREAS;
YEAR
5)
­
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)
6a,
6b,
7a,
9a,
9b
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
HARVEST
SCHEDULE
X
X
X
CALIFORNIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

None
were
identified
as
being
limiting
factors.
Page
26
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)
1,128
1,153
1,267
1,283
1,295
1,477
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
308,860
313,200
341,230
337,604
341,022
389,069
FORMULATIONS
OF
METHYL
BROMIDE
(
e.
g.
methyl
bromide
98:
2;
methyl
bromide
/
chloropicrin
70:
30)
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)
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
411
408
404
395
395
395
APPLICATION
RATE
OF
METHYL
BROMIDE
IN
kg/
ha*
274
272
269
263
263
263
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
41.1
40.8
40.4
39.5
39.5
39.5
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
27.4
27.2
26.9
26.3
26.3
26.3
*
For
Flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
27
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
Please
see
the
description
of
the
alternatives
not
being
feasible
under
the
Southeastern
U.
S.
above.

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
Please
see
the
description
of
the
technically
infeasible
alternatives
discussion
under
the
Southeastern
U.
S.
above.

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
State
if
registered
for
this
crop,
registered
for
crop
but
use
restricted,
registered
for
other
crops
but
not
target
crop,
or
not
registered
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Iodomethane
Not
registered
for
any
crop
uses
in
the
US.
Generally
considered
an
excellent
potential
alternative.
Yes
Unknown
Sodium
Azide
Not
submitted
for
registration.
Comparative
performance
data
not
presented
in
any
of
the
studies
submitted.
No
Unknown
Propargyl
bromide
Not
submitted
for
registration.
No
Unknown
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
Preamble
 
Although
only
several
studies
are
represented
in
the
Tables
below,
numerous
studies
have
been
conducted
and
referenced
(
see
section
26)
in
the
two
applications
(
Southeastern
States
[
MD,
NC,
TN],
and
California).
Given
all
the
permutations
of
edaphic
and
pest
variables
Page
28
that
exist
in
the
production
areas,
it
is
of
limited
practical
value
to
present
a
limited
subset
of
the
total
number
of
studies
as
being
indicative
of
the
actual
performance
variability
ranges
of
the
alternatives.
Given
the
time
constraints
associated
with
these
requests,
it
is
impossible
to
accurately
present
the
finding
of
all
relevant
studies.
However,
after
perusing
a
large
number
of
these
studies
it
is
obvious
that
none
of
the
alternatives
can
consistently
provide
sufficient
control
of
the
target
pests
(
comparable
to
levels
and
frequency
attained
with
methyl
bromide
(
MB).
This
is
especially
true
for
those
pests
subject
to
the
rigorous
requirements
of
the
State's
nursery
certification
program
(
virtually
a
zero
tolerance
for
symptoms
of
soilborne
diseases
and
the
presence
of
plant­
parasitic
nematodes
in
the
soil).
Even
though
most
studies
have
shortcomings
in
terms
of
the
procedures
utilized
and/
or
the
information
reported,
the
aggregate
conclusion
is
that
none
of
the
chemical
and/
or
non­
chemical
alternatives
will
consistently
achieve
levels
of
pest
control
comparable
to
methyl
bromide.

When
one
takes
into
account
that
the
five­
year
production
system
involves
new
planting
sites
each
year,
consistency
is
important
in
satisfying
the
needs
of
their
international,
interstate
and
intrastate
customers.
The
inconsistency
in
performance
of
the
alternatives
most
likely
relates
to
the
application
methods,
application
rates,
alternative(
s)
evaluates,
formulations
of
alternatives
utilized,
soil
conditions,
and
weather
conditions
which
occurred,
and
pest
species
and
levels
present
in
tests.

Given
the
soil
types
present
in
production
areas
the
root
zone
required
to
be
protected
is
generally
as
deep
as
3
feet.
Although
several
of
the
alternatives
provide
adequate
levels
of
pest
control
at
shallower
depths,
none
consistently
provide
suitable
control
levels
at
3
feet.
Failure
to
provide
levels
of
pest
control
at
the
required
depth
will
result
in
inadequate
levels
of
control
which
will
result
in
rejection
of
the
plants
produced
under
these
conditions
(
100%
loss
in
affected
fields).
Page
29
CALIFORNIA
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
Chemical
Alternatives
to
Methyl
Bromide
Fumigation
 
How
Well
Do
They
Work?

Treatment
Application
Method
&
Rate
(
kg/
ha)
Pest
Control
(%
of
MB)
Yield
(%
of
MB)
Comments
NEM
DIS.
MB/
CP
(
67:
33)
MB:
246kg/
ha;
CP:
121
kg/
ha;
chisel
injection
&
tarped
+
+
100
1,3­
D/
CP
(
70:
30)
1,3­
D:
361
kg/
ha;
CP:
155
kg/
ha;
chisel
injection
&
tarped
+
+
96
Chloropicrin
(
CP)
95­
189;
and
190
and
higher;
chisel
injection
&
tarped
+
+
89
(<
190kg/
ha);

103
(>
190
kg/
ha)
Evaluated
both
low
and
high
dosage
rates
Metam
Sodium
950
kg/
ha;
surface
drench
and
tarped
+
+
92
Dazomet
340
kg/
ha;
bdcst,
tilled
into
soil,
and
tarped
+
+
95
Enzone
(
sodium
tetra
thiocarbonate)
2.85
kg/
ha
tarped
+
+
80
Not
registered
for
use
on
strawberries
UTC
+
+
70
Source:
Gubler,
W.
D.,
J.
M.
Duniway,
and
N.
Welch.
1996.
Chemical
Alternatives
to
Methyl
Bromide
Fumigation
 
How
Well
Do
They
Work?

Key
to
Abbreviations:
1,3­
D
=
1,3­
dichloropropene;
MB
=
methyl
bromide;
CP
=
chloropicrin;
MS
=
metam
sodium;
UTC
=
untreated
control;
Nem.
=
nematodes;
Dis.
=
diseases;
bdcst
=
broadcast
application.

Watsonville,
CA
1993
study
using
large­
scale
plots;
low
levels
of
Phytophthora
crown
and
root
rot,
Verticillium
wilt,
and
nematodes;
one­
year
evaluation
only
Page
30
CALIFORNIA
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
Chloropicrin
Effect
on
Weed
Seed
Viability.

Control
Measures
Evaluated
Application
Method
&
Rate
(
kg/
ha)
Weed
Control
(%
of
MB)
Comments
MB/
CP
(
67:
33)
MB:
225
kg/
ha
CP:
111
kg/
ha;
soil
injection
100
Very
good
control
of
3
weeds;
no
control
of
2
weeds
(
mallow
&
filaree)

Metam
Sodium
(
MS)
MS:
197
kg/
ha;
drip
irrigation
Comp.
Very
good
control
of
3
weeds;
no
control
of
2
weeds
(
mallow
&
filaree)

MS
plus
CP
MS:
197kg
/
ha
drip
irrigation;
CP:
83
 
220
kg/
ha
soil
injection
Very
Comp.
produced
a
slight
increase
in
weed
control
over
MS
alone
=
best
available
treatment
for
the
weed
species
present
Chloropicrin
(
CP)
CP:
83
 
220
kg/
ha
soil
injection
Comp.
good
control
of
3
weeds
at
the
higher
rates;
no
control
of
2
weeds
(
mallow
&
filaree)

UTC
none
Source:
Haar,
M.
J.,
S.
A.
Fennimore,
H.
A.
Ajwa,
C.
Q.
Winterbottom.
2003.
Chloropicrin
Effect
on
Weed
Seed
Viability.
Key
to
Abbreviations:
CP
=
chloropicrin;
MS
=
metam
sodium;
1,3­
D
=
1,3­
dichloropropene;
UTC
=
untreated
controls;
Comp
=
comparable.

Study
conducted
over
two
years
near
Santa
Maria,
CA.
Primary
weed
pests:
Polygonum
aviculare
(
knot­
grass),
Portulaca
oleracea
(
common
purslane)
and
Malva
parviflora
(
little
mallow)
were
introduced
in
both
years,
whereas,
Stellaria
media
(
chickweed)
and
Erodium
cicutarium
(
red­
stem
filaree)
were
introduced
in
the
second
year;
similar
weed
seed
sensitivity
for
CP
and
MS;
no
yield
data
obtained.

CALIFORNIA
 
TABLE
16.3:
EFFECTIVENESS
OF
ALTERNATIVES
­
Soil
Fumigation
and
Runner
Plant
Production.

Treatment
Application
Method
&
Rate
(
kg/
ha)
Yield
(%
of
MB)
Comments
Methyl
bromide
Chisel
100
(
4
trials)

Chloropicrin
140­
191
kg/
ha
,
chisel
73­
92
(
3
trials)

Chloropicrin
 
300
kg/
ha,
Chisel;
86
 
100
(
4
trials)
Appeared
to
be
the
best
of
the
alternatives
evaluated
1,3­
D/
Chloropicrin
(
70:
30)
Chisel;
84
(
1
trial)
Did
not
rank
very
high
as
an
alternative
due
to
reduced
plant
growth
and
runner
production
1,3­
D/
Chloropicrin
(
30:
70)
Chisel
91
(
1
trial)
Appeared
to
perform
similar
to
the
high
rate
of
chloropicrin
UTC
Not
Applicable
38­
55
(
4
trials)
Page
31
Source:
Larson,
K.
D.
and
D.
V.
Shaw,
2000,
Soil
Fumigation
and
Runner
Plant
Production:
A
Synthesis
of
Four
Years
of
Strawberry
Nursery
Field
Trials,
Hort
Sci.
35
(
4):
642­
646.
Key
to
Abbreviations:
1,3­
D
=
1,3­
dichloropropene;
UTC
=
untreated
controls.

This
study
was
conducted
over
four
on
former
strawberry
nursery
soils,
however,
other
crops
planted
in
these
soils
prior
to
initiating
this
study;
fumigants
chiseled
into
soil
at
a
36
cm
depth
and
covered
with
a
tarp
for
7
days;
pest
types
and
pressures
uncertain,
however,
verticillium
wilt
(
V.
albo­
atrum)
was
detected
in
some
locations
and
roots
were
examined
for
decay
and
discoloration,
with
the
untreated
plants
(
UTC)
exhibiting
most
of
the
disease
symptoms;
nematodes
were
not
considered
to
be
a
problem
in
any
of
the
test
locations.
It
should
be
noted
that
the
main
focus
of
this
study
was
to
evaluate
yield
responses
and
that
quantification
of
the
various
pest
organisms
was
beyond
the
scope
of
this
study.

CALIFORNIA
 
TABLE
16.4:
EFFECTIVENESS
OF
ALTERNATIVES
­
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries
Treatment
Application
Method
&
Rate
(
kg/
ha)
Nematode
Control
(%
of
MB)

Methyl
bromide
/
chloropicrin
(
75:
25)
MB:
448
kg/
ha;

CP:
151
kg/
ha
100
1,3­
D/
CP
???
plus
m­
s???
1,3­
D:
518
kg/
ha;

CP:
283
kg/
ha
83­
100
1,3­
D
+
Metam
Sodium
Sequential
application;
1,3­
D:
518
kg/
ha;

MS:
??
kg/
ha.
16­
100
1,3­
D/
dazomet
Sequential
application;
396
kg/
ha;
224
kg/
ha
DZ
28­
100
Source:
McKenry,
M.
V.,
2001.
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries,
California
Department
of
Pesticide
Regulation
(
Contract
#
99­
0218).

Key
to
Abbreviations:
1,3­
D
=
;
CP
=
;
MB
=
;
DZ
=
dazomet;
Prominent
nematode
pests
present:
lesion
(
Pratylenchus
spp.),
spiral
(
Helicotylenchus
dihystera),
dagger
(
Xiphinema
americanum)
and
some
root­
knot
(
Meloidogyne
spp.)
Page
32
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
D/
Chloropicrin
Certain
weeds
0­
27%
10%
1,3­
D
+
Metam
Sodium
Certain
weeds
­­­
13%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
10­
13%

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

California­
Table
15.1
for
status
of
iodomethane.
This
fumigant
is
unregistered,
but
is
reported
to
be
a
potential
suitable
alternative
for
all
key
pests.

Dazomet
is
also
in
a
pending
registration
status
as
a
nematicide
on
strawberries.
Based
on
previous
studies
on
other
crops,
it
is
reportedly
not
likely
to
be
a
suitable
methyl
bromide
alternative
for
strawberry
nurseries.

CALIFORNIA
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE
We
are
not
aware
of
any
current
or
near
future
technologies
that
are
technically
and/
or
economically
feasible.
Some
people
consider
soilless
hydroponic
culture
as
a
possible
long­
term
option.
Although
this
technique
could
eliminate
all
or
most
of
the
typical
soilborne
pests
currently
controlled
by
methyl
bromide.
However,
new
pests
may
become
problematic,
which
may/
may
not
be
controllable
with
available
pesticides.

CALIFORNIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
None
are
considered
technically
feasible
at
the
present
time
due
to
the
high
levels
of
disease
and
nematode
control
required
by
the
current
state
certification
standards,
which
equate
to
virtually
complete
control
of
all
damaging
disease
and
nematode
pests.
Buffer
zones
and
regulatory
constraints
are
only
secondary
concerns,
since
none
of
the
available
alternatives
can
provide
suitable
pest
control
at
root
zone
depths
to
1
meter.
Page
33
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
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?
Currently
some
growers
use
HDPE
tarps.
Between
1997
and
2002
the
dosage
rate
of
methyl
bromide
has
dropped
by
one
eighth.
All
use
67:
33
Unidentified
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Research
is
underway
to
develop
use
in
commercial
production
systems
Possible
changeover
from
broadcast
to
raised
bed
band
treatments,
Unidentified
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

OTHER
MEASURES
(
please
describe)
Examination
of
promising
but
presently
unregistered
alternative
fumigants
with
non­
chemical
methods.
Unidentified
Unidentified
Unidentified
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
In
accordance
with
the
criteria
of
the
critical
use
exemption,
each
party
is
required
to
describe
ways
in
which
it
strives
to
minimize
use
and
emissions
of
methyl
bromide.
The
use
of
methyl
bromide
in
the
growing
of
strawberry
nurseries
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
has,
for
the
last
40
years,
been
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
application
for
strawberry
nurseries
is
most
often
machine
injected
into
soil
to
specific
depths.
Page
34
As
methyl
bromide
use
has
become
scarcer,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
95%
methyl
bromide
and
5%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
at
low
to
moderate
levels
of
infestation,
it
must
be
stressed
that
the
long­
term
efficacy
of
these
mixtures
is
unknown.

Tarpaulin
(
high
density
polyethylene)
is
also
used
to
minimize
use
and
emissions
of
methyl
bromide.
In
addition,
cultural
practices
are
utilized
by
strawberry
nursery
growers.

Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.

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

TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Methyl
Bromide
100
1,806
1,806
1,806
Metam
Sodium
50
3,187
3,187
3,187
1,3­
d+
pic
90
4,774
4,774
4,774
Chloropicrin
95
5,419
5,419
5,419
1,3­
d+
Metam
Sodium
86
5,317
5,317
5,317
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
CALIFORNIA­
22.
GROSS
AND
NET
REVENUE
CALIFORNIA­
TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
41,019
11,879
Metam
Sodium
­
­
1,3­
d+
pic
36,918
4,670
Chloropicrin
38,968
8,112
1,3­
d+
Metam
Sodium
35,892
5,137
Page
35
CALIFORNIA­
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
41,019
11,879
Metam
Sodium
­
­
1,3­
d+
pic
36,918
4,670
Chloropicrin
38,968
8,112
1,3­
d+
Metam
Sodium
35,892
5,137
CALIFORNIA­
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
41,019
11,879
Metam
Sodium
­
­
1,3­
d+
pic
36,918
4,670
Chloropicrin
38,968
8,112
1,3­
d+
Metam
Sodium
35,892
5,137
SOUTHEASTERN
STATES­
22.
GROSS
AND
NET
REVENUE
SOUTHEASTERN
STATES­
TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
42,008
11,763
Metam
Sodium
21,004
­
8,923
1,3­
d+
pic
37,807
6,294
Chloropicrin
39,907
7,749
1,3­
d+
Metam
Sodium
­
­

SOUTHEASTERN
STATES­
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
42,008
11,763
Metam
Sodium
21,004
­
8,923
1,3­
d+
pic
37,807
6,294
Chloropicrin
39,907
7,749
1,3­
d+
Metam
Sodium
­
­

SOUTHEASTERN
STATES­
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
Page
36
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
42,008
11,763
Metam
Sodium
21,004
­
8,923
1,3­
d+
pic
37,807
6,294
Chloropicrin
39,907
7,749
1,3­
d+
Metam
Sodium
­
­
Page
37
SOUTHEASTERN
STATES
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
STATES
METHYL
BROMIDE
ALTERNATIVE
METAM
ALTERNATIVE
1,3­
D+
PIC
YIELD
LOSS
(%)
0
50
10
YIELD
PER
HECTARE
(
PLANTS)
211,715
105,857
190,543
*
PRICE
PER
UNIT
(
US$)
.20
.20
.20
=
GROSS
REVENUE
PER
HECTARE
(
US$)
42,008
21,004
37,807
­
OPERATING
COSTS
PER
HECTARE
(
US$)
30,245
29,927
31,513
=
NET
REVENUE
PER
HECTARE
(
US$)
11,763
­
8,923
6,294
LOSS
MEASURE
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
20,686
$
5,469
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
50.15
13.26
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
49%
13%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
176%
46%

CALIFORNIA
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
ALTERNATIVE
1,3­
D
METAM
ALTERNATIVE
1,3­
D+
PIC
YIELD
LOSS
(%)
0
13%
10%

YIELD
PER
HECTARE
(
BOXES)
332
291
299
*
PRICE
PER
UNIT
(
US$)
50
50
50
=
GROSS
REVENUE
PER
HECTARE
(
US$)
41,019
35,892
36,918
­
OPERATING
COSTS
PER
HECTARE
(
US$)
29,141
30,755
32,247
=
NET
REVENUE
PER
HECTARE
(
US$)
11,879
5,137
4,670
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
6,741
7,208
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
25.59
27.37
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
16%
18%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
57%
61%
Page
38
SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
compared
the
costs
of
methyl
bromide
alternative
control
scenarios
for
the
Southeastern
Strawberry
Consortium
and
the
California
Strawberry
Growers
Association
to
the
baseline
costs
for
methyl
bromide.
The
economic
estimates
were
first
calculated
in
pounds
and
acres
and
then
converted
to
kilograms
and
hectares.
The
costs
for
the
alternatives
are
based
on
market
price
for
the
control
products
multiplied
by
the
number
of
pounds
of
active
ingredient
that
would
be
applied.
The
baseline
costs
were
based
on
the
average
number
of
applications
to
treat
strawberry
plants
(
boxes)
with
methyl
bromide
per
year.
The
loss
per
hectare
measures
the
value
of
methyl
bromide
based
on
changes
in
operating
costs
and/
or
changes
in
yield.
The
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
derive
gross
revenue
and
the
operating
costs
for
each
alternative
were
derived
from
the
baseline
methyl
bromide
costs
compared
to
the
costs
of
changes
under
three
fumigation
scenarios
in
the
Southeastern
States:
1)
metam
sodium;
2)
1,3­
d
+
chloropicrin;
and
3)
chloropicrin.

For
California,
the
baseline
methyl
bromide
costs
were
compared
to
three
scenarios:
1)
1,3­
d
+
metam
sodium;
2)
1,3­
d
+
chloropicrin;
and
3)
chloropicrin.
The
differences
in
the
cost
of
production
were
primarily
attributable
to
changes
in
fumigation
costs.

One
of
the
issues
facing
nursery
growers
is
that
pest
infestation
can
wipe
out
production
for
the
season.
If
there
are
quality
concerns
such
as
disease,
weeds,
or
insect
infestation
growers
will
not
be
able
to
market
their
seedlings.
Fruit
producers
are
not
willing
to
purchase
plants
that
have
any
visual
symptoms
of
disease
and
may
hold
the
nursery
responsible
for
any
disease
that
shows
up
during
fruiting
in
the
field
in
the
first
weeks
after
planting.
Nearly
a
billion
plants
are
produced
by
the
California
strawberry
nursery
system
alone
each
year
and
this
production
is
distributed
world­
wide.
There
are
approximately
13
seedling/
runner
producers
in
California
that
must
manage
disease
incidence
over
the
4
year
production
cycle
of
the
strawberry
stock.
Without
data
to
illustrate
the
impacts
of
a
growers
stock
being
wiped
out,
we
assumed
that
if
an
estimated
10%
of
the
root­
stock
is
contaminated
this
would
directly
reduce
the
yield
by
that
amount.
Clearly
this
would
have
a
detrimental
impact
on
the
entire
industry
as
the
yield
losses
would
be
in
addition
to
the
yield
losses
generated
by
the
change
to
alternative
chemical
controls.
Yield
losses
on
a
hectare
basis
could
range
from
15­
60%
reflecting
lower
yields
from
alternative
control
and
loss
of
the
nursery
supply.
However,
a
more
likely
scenario
is
that
several
growers
in
a
region
would
suffer
pathogen
or
insect
infestation
and
that
the
entire
stock
for
those
growers
cannot
be
marketed,
yield
losses
would
be
much
higher.

Southeastern
States:
Under
Alternative
1
(
Metam
sodium),
yield
loss
was
estimated
to
be
50%,
which
translates
into
a
49%
loss
in
gross
revenues.
With
operating
costs
in
U.
S.
dollars
per
hectare
of
$
29,927,
the
estimated
net
revenue
was
­$
8,923
per
hectare,
or
a
loss
of
176%.
The
loss
per
hectare
is
estimated
to
be
$
20,686.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
50.15
per
kilogram.
Page
39
Under
alternative
2
(
1,3­
d
+
chloropicrin),
the
yield
loss
was
estimated
to
be
10%
and
the
loss
a
percent
of
gross
revenue
was
13%.
Operating
costs
in
U.
S.
dollars
per
hectare
are
$
31,513.
The
estimated
net
revenue
was
$
6,294
per
hectare,
or
a
loss
of
46%.
The
loss
per
hectare
is
estimated
to
be
$
5,469.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
13.26
per
kilogram.

Under
alternative
3
(
chloropicrin
alone),
the
yield
loss
was
estimated
to
be
5%.
Operating
costs
in
U.
S.
dollars
per
hectare
are
$
32,158.
The
estimated
net
revenue
was
$
7,749
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
4,014.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
9.73
per
kilogram.

California:
Alternative
1
(
Metam
sodium),
yield
was
assumed
to
be
13%
with
operating
costs
in
U.
S.
dollars
per
hectare
of
$
30,755.
The
estimated
net
revenue
was
$
5,137
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
6,741.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
25.59
per
kilogram.

Under
alternative
2
(
1,3­
d
+
chloropicrin),
the
yield
loss
was
estimated
to
be
10%.
Operating
costs
in
U.
S.
dollars
per
hectare
are
$
32,247.
The
estimated
net
revenue
was
$
4,670
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
7,208.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
27.37
per
kilogram.

Under
alternative
3
(
chloropicrin),
the
yield
loss
was
estimated
to
be
5%.
Operating
costs
in
U.
S.
dollars
per
hectare
are
$
30,856.
The
estimated
net
revenue
was
$
8,112
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
3,766.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
14.30
per
kilogram.
Page
40
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?
The
available
alternatives
are
currently
all
considered
unsuitable.
Continued
testing
for
5
to
10
years
may
be
required
to
explore
new
or
improved
application
techniques
that
may
be
considered
suitable.
Combinations
of
several
chemical
and
non­
chemical
controls
may
ultimately
be
needed
along
with
application
technique
changes.

Since
1997,
the
United
States
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
EPA
currently
has
more
applications
pending
in
its
registration
review
queue
than
the
resources
to
evaluate
them,
EPA
prioritizes
the
applications.
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.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
Agency
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
Agency's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
Agency
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,
Agency
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.
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
U.
S.$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
U.
S.$
2.5
million
per
year
methyl
bromide
alternatives
research
has
further
ensured
close
coordination
between
the
U.
S.
government
and
the
research
community.

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
nurseries
research
will
require
454
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
three
year
study
testing
the
comparative
performance
of
methyl
bromide,
alternative
fumigants,
preplant
fungicide
dips,
post
plant
fungicides,
Page
41
germplasm,
microbial
inoculants,
and
cultural
practices.
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
nurseries
research
will
require
454
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
three
year
study
testing
the
comparative
performance
of
methyl
bromide,
alternative
fumigants,
preplant
fungicide
dips,
post
plant
fungicides,
germplasm,
microbial
inoculants,
and
cultural
practices
24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

The
U.
S.
wants
to
note
that
our
usage
rate
is
among
the
lowest
in
the
world
in
requested
sectors
and
represents
efforts
of
both
the
government
and
the
user
community
over
many
years
to
reduce
use
rates
and
emissions.
We
will
continue
to
work
with
the
user
community
in
each
sector
to
identify
further
opportunities
to
reduce
methyl
bromide
use
and
emissions.
.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

26.
CITATIONS
REFERENCED
IN
THIS
REPORT
Ajwa,
H.
A.,
T.
Trout,
J.
Mueller,
S.
Wilhelm,
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D.
Shatley.
2002.
Application
of
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Fumigants
Through
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92(
12):
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1355.

Ajwa,
H.,
T.
Trout.
2000.
Distribution
of
Drip
Applied
Fumigants
Under
Various
Conditions.
2000
Annual
International
Research
Conference
on
Methyl
Bromide
alternatives
and
Emissions
Reductions.

Ajwa,
H.,
T.
Trout.
2000.
Strawberry
Growth
and
Yield
with
Three
Years
of
Drip
Fumigation.
2000
Annual
International
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on
Methyl
Bromide
alternatives
and
Emissions
Reductions.

Braun,
A.
L.,
D.
M.
Supkoff.
1994.
Options
to
Methyl
Bromide
for
the
Control
of
Soil
Borne
Diseases
and
pests
in
California.
Pest
Management
Analysis
and
Planning
Program.
Page
42
Browne,
G.
T.,
H.
E.
Becherer,
M.
R.
Vazuesq,
S.
A.
McGlaughlin,
R.
J.
Wakeman,
C.
Q.
Winterbottom,
J.
M.
Duniway,
S.
A.
Fennimore.
2001.
Outlook
for
Managing
Phytophthora
Diseases
on
California
Strawberries
without
Methyl
Bromide.
Report
to
DPR.

Browne,
G.
T.,
H.
E.
Becherer,
S.
T.
McLaughlin,
R.
J.
Wakeman.
2002.
Strategies
for
Management
of
Phytophthora
on
California
Strawberries.
Report
to
California
Strawberry
commission,
March
2002.
2
pgs.

Burgos,
N.
R.,
and
R.
E.
Talbert.
1996a.
Weed
control
and
sweet
corn
(
Zea
mays
vir.
Rugosa)
response
in
a
no­
till
system
with
cover
crops.
Weed
Sci.
44:
355­
361.

Burgos,
N.
R.,
and
R.
E.
Talberty.
1996b.
Weed
Control
by
spring
cover
crops
and
imazethapyr
in
no­
till
southern
pea
(
Vigna
unguiculata).
Weed
Technol.
10;
893­
899.

California
Department
of
Food
and
Agriculture.
2003.
Summary
of
California
Laws
and
Regulations
Pertaining
to
Nursery
Stock.

Carpenter,
J.,
L.
Lynch.
1999.
Impact
of
1,3­
D
Restrictions
in
California
after
a
Ban
on
Methyl
Bromide.
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EPA
Website.

Carpenter,
J.
L.
Lynch,
T.
Trout.
2001.
Township
limits
on
1,3­
D
will
impact
adjustment
to
methyl
bromide
phase­
out.
California
Agricultural.
55(
3):
12­
18.

Culpepper,
A.
S.
2002.
Commercial
Vegetables
­
Weed
Control.
2002
Georgia
Pest
Control
Handbook.
Cooperative
Ext.
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University
of
Georgia,
Athens,
GA.
Pp.
247­
256.

Duniway,
J.
M.,
D.
M.
Dopkins,
J.
J.
Hao.
2002.
Chemical
and
Cultural
alternatives
to
Methyl
Bromide
Fumigation
of
Soil
for
Strawberry:
Research
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Report.
California
Strawberry
Commission
Pink
Sheet.

Duniway,
J.
M.
2002.
Status
of
Chemical
Alternatives
to
Methyl
Bromide
for
Pre­
Plant
Fumigation
of
Soil.
Phytopath
92(
12):
1337­
1343.

Duniway,
J.
M.,
J.
J.
Hao,
D.
M.
Dopkins,
H.
Ajwa,
G.
T.
Browne.
2000.
Some
chemical,
cultural,
and
Biological
alternatives
to
Methyl
Bromide
Fumigation
of
soil
for
Strawberry.
2000
Annual
International
Research
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on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

EPA.
2002.
Replacing
Methyl
Bromide
for
Preplant
Soil
fumigation
with
Telone,
Chloropicrin
and
Tillam
Combination
Treatments.
EPA
Website.
6
pgs.

Fennimore,
S.
A.
J.
M.
Duniway.
Alternative
fumigants
for
control
of
soil
pests:
strawberry
as
a
Model
System.
Report
to
California
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APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2001
&
2002
Average
%
of
2001
&

2002
Average
not
available
not
available
not
available
not
available
not
available
not
available
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
53,751
204
263
88%

2,086
5
413
95%

55,837
209
267
88%

88%
88%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
263
263
0
0
0
0
100
100
0
0
0
0
0
0
413
413
0
0
0
0
100
100
0
0
0
0
0
0
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
Yes
+
Yes
No
Yes
Yes
Tarp
Yes
+
Yes
Conversion
Units:
1
Pound
=
Kilograms
Hectare
Quality/
Time/
Market
Window/

Yield
Loss
(%)
Marginal
Strategy
10%
or
13
%

10%
1,3­
D
+
Pic
or
1,3­
D
+
Metam
1,3­
D
+
Pic
Combined
Impacts
(%)

HIGH
100%
100%
LOW
100%
100%

Regional
Hectares**

%
of
Requested
Hectares
MOST
LIKELY
IMPACT
VALUE
not
available
not
available
not
available
not
available
Sector:
STRAWBERRY
NURSERY
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
%
of
Average
Hectares
Requested:
not
available
Date:
2/
26/
2004
Methyl
Bromide
Critical
Use
Exemption
Process
Average
Hectares
in
the
US:

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)

443,432
1,683
263
365,045
1,386
263
85%

41,453
100
413
28,499
69
413
89%

338
87%

TOTAL
OR
AVERAGE
484,884
1,784
338
393,544
1,455
(­)
QPS
HIGH
LOW
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
443,432
­
85,094
­
304,587
53,751
53,751
41,453
­
22,489
­
16,878
2,086
2,086
Nomination
Amount
484,884
484,884
377,301
377,301
55,837
55,837
55,837
(%)
100
ft
Buffer
Zones
88%

%
Reduction
from
Initial
Request
0%
0%
22%
Cold
Soil
Temp
(%)

REGION
CALIFORNIA
SOUTHEASTERN
US
CALIFORNIA
2006
Nomination
Options
88%

(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)

CALIFORNIA
SOUTHEASTERN
US
REGION
REGION
REGION
SOUTHEASTERN
US
CALIFORNIA
SOUTHEASTERN
US
Other
Considerations
Adjustments
to
Requested
Amounts
0.453592
1
Acre
=
0.404686
22%
88%
Economic
Analysis
Dichotomous
Variables
(
Y/
N)
Other
Issues
Use
Rate
(
kg/
ha)
(%)
Karst
Topography
Page
47
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.
Page
48
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
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.
Page
49
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.
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
50
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

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

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

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

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

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

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
51
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
