METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
FRUIT,
NUT
AND
FLOWER
NURSERIES
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Fruit,
Nut
and
Flower
Nurseries
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
ii
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
.....................................................................................................................
7
1.
Nominating
Party
_________________________________________________________
7
2.
Descriptive
Title
of
Nomination______________________________________________
7
3.
Crop
and
Summary
of
Crop
System___________________________________________
7
4.
Methyl
Bromide
Nominated
_________________________________________________
8
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
9
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
10
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
10
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
11
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
12
WESTERN
RASPBERRY
NURSERIES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.................................................................................................................................................
13
Western
Raspberry
Nurseries
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
13
Western
Raspberry
Nurseries
­
11.
Characteristics
of
Cropping
System
and
Climate______
13
Western
Raspberry
Nurseries.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
15
WESTERN
RASPBERRY
NURSERIES.
PART
C:
TECHNICAL
VALIDATION........................................
16
Western
Raspberry
Nurseries.
13.
Reason
for
Alternatives
Not
Being
Feasible
__________
16
Western
Raspberry
Nurseries.
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
18
Western
Raspberry
Nurseries
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________________________________________
19
Western
Raspberry
Nurseries
­
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
___________________________________________________________
19
Western
Raspberry
Nurseries
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
21
Western
Raspberry
Nurseries
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
22
Western
Raspberry
Nurseries
­
Summary
of
Technical
Feasibility
____________________
22
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.............................................................................................................
22
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request__________________
22
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
24
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________________
26
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
PART
C:
TECHNICAL
VALIDATION.......
27
iv
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________________________________________________________________
27
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:_________________________________________________________
29
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________
29
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
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
__________________________________________________
30
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
________________________________________________________________________
31
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
______________________
32
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
Summary
of
Technical
Feasibility
_____
32
CALIFORNIA
NURSERY
ROSES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE..
33
California
Nursery
Roses
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
33
California
Nursery
Roses
­
11.
Characteristics
of
Cropping
System
and
Climate
_________
33
California
Nursery
Roses
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
35
CALIFORNIA
NURSERY
ROSES
­
PART
C:
TECHNICAL
VALIDATION..............................................
36
California
Nursery
Roses
­
13.
Reason
for
Alternatives
Not
Being
Feasible_____________
36
California
Nursery
Roses
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
37
California
Nursery
Roses
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_____________________________________________
38
California
Nursery
Roses
­
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
___________________________________________________________
38
California
Nursery
Roses
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
43
California
Nursery
Roses
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
43
California
Nursery
Roses
­
Summary
of
Technical
Feasibility
_______________________
44
PART
D:
EMISSION
CONTROL
..................................................................................................
45
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
45
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
45
PART
E:
ECONOMIC
ASSESSMENT...............................................................................................
46
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
46
22.
Gross
and
Net
Revenue___________________________________________________
46
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
46
v
Summary
of
Economic
Feasibility
_____________________________________________
46
PART
F.
FUTURE
PLANS
.............................................................................................................
48
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
48
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
48
25.
Additional
Comments
on
the
Nomination
____________________________________
49
26.
Citations
______________________________________________________________
50
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.

LIST
OF
TABLES
Part
A:
Summary______________________________________________________________
7
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
8
Table
A.
1:
Executive
Summary
_________________________________________________
10
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
10
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________________
11
Table
A.
2:
2006
Sector
Nomination
______________________________________________
12
Western
Raspberry
Nurseries
­
Part
B:
Crop
Characteristics
and
Methyl
Bromide
Use
_____
13
Western
Raspberry
Nurseries
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
13
Western
Raspberry
Nurseries.
Table
11.1:
Characteristics
of
Cropping
System____________
14
Western
Raspberry
Nurseries.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
____
14
Western
Raspberry
Nurseries.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide_______
15
WESTERN
RASPBERRY
NURSERIES.
PART
C:
TECHNICAL
VALIDATION
_______________________
16
Western
Raspberry
Nurseries.
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
_____
16
Western
Raspberry
Nurseries
­
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__
18
Western
Raspberry
Nurseries
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____
19
Western
Raspberry
Nurseries
 
Table
16.1:
Effectiveness
of
Alternatives
 
Diseases
_______
20
Western
Raspberry
Nurseries
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________
21
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
B
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________________________________________________
22
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_________________________________________
23
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________________
24
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule___________________________________________________________
25
California
Deciduous
Fruit
&
Nut
Tree
Growers
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
26
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
PART
C:
TECHNICAL
VALIDATION
_____
27
California
Deciduous
Fruit
&
Nut
Tree
Growers
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible___________________________________________________________
27
California
Deciduous
Fruit
&
Nut
Tree
Growers
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________________________________________
29
vi
California
Deciduous
Fruit
&
Nut
Tree
Growers
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________________________________________________
29
California
Deciduous
Fruit
&
Nut
Tree
Growers
 
Table
16.1:
Effectiveness
of
Alternatives
 
Nematodes______________________________________________________________
30
California
Deciduous
Fruit
&
Nut
Tree
Growers
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_______________________________________________________________
31
California
Nursery
Roses
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____
33
California
Nursery
Roses
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
33
California
Nursery
Roses
­
Table
11.1:
Characteristics
of
Cropping
System
______________
33
California
Nursery
Roses
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______
34
California
Nursery
Roses
­
Table
11.3
One
Year
Rose
Crop
Schedule
___________________
34
California
Nursery
Roses
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_________
35
CALIFORNIA
NURSERY
ROSES
­
PART
C:
TECHNICAL
VALIDATION__________________________
36
California
Nursery
Roses
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible________
36
California
Nursery
Roses
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
_____
37
California
Nursery
Roses
 
Table
15.1:
Present
Registration
Status
of
Alternatives_________
38
California
Nursery
Roses
 
Table
16.1:
Effectiveness
of
Alternatives
 
Nematodes
________
39
California
Nursery
Roses
 
Table
16.2:
Effectiveness
of
Alternatives
 
Phytophthora_______
40
California
Nursery
Roses
 
Table
16.3:
Effectiveness
of
Alternatives
 
Stunt
Nematode
____
41
California
Nursery
Roses
 
Table
16.4:
Effectiveness
of
Alternatives
 
Root
Knot
Nematode
42
California
Nursery
Roses
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary____________
43
PART
D:
EMISSION
CONTROL
___________________________________________________
45
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
45
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
46
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
46
PART
F.
FUTURE
PLANS
________________________________________________________
48
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
52
Page
7
Part
A:
Summary
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Fruit,
Nut
and
Flower
Nurseries
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
This
nomination
is
based
on
requests
for
critical
use
of
MB
by
growers
of
raspberry,
roses,
and
deciduous
tree
nursery
stock.
Nursery
producers
must
be
able
to
provide
stock
plants
that
are
pest­
free
to
allow
the
establishment
of
plantings
that
are
of
the
highest
initial
quality
and
optimize
the
longevity
of
orchards
or
other
producing
plots.
Nurseries
provide
plants
used
by
commercial
growers
of
fresh
and
processed
raspberries,
rose
bushes,
and
such
diverse
fruit
crops
as
apricots
peaches,
prunes,
nectarines,
cherries,
plums,
apples,
pears,
Asian
pears
(
as
well
as
ornamental
pears),
and
nut
crops
such
as
almonds,
walnuts,
pistachios,
pecans,
and
chestnuts.
Approximately
95%
of
the
trees
are
fruiting
varieties
sold
to
commercial
producers
(
although
residential
consumers
are
also
a
market);
the
other
5%
are
ornamental
types
used
for
landscaping.
Nurseries
are
concentrated
in
areas
conducive
to
early
plant
growth
 
deciduous
trees
are
primarily
produced
in
California
in
the
Sacramento
and
San
Joaquin
valleys
in
a
Mediterranean
climate,
many
large
raspberry
nurseries
are
located
in
eastern
San
Joaquin
valley
and
western
Washington
where
pest­
free
stock
can
be
grown
for
markets
in
the
cooler
production
areas
of
northern
California
and
the
Pacific
Northwest.

Raspberry
nurseries
in
the
western
U.
S.
provide
raspberry
stock
to
most
of
the
growers
in
North
America.
Dry
climates
and
soil
type
make
these
areas
ideal
for
nurseries
to
provide
high
quality
plant
stock.
Although
there
are
relatively
few
raspberry
nurseries,
they
provide
all
of
the
stock
used
by
commercial
growers
and
therefore,
have
a
large
impact
on
raspberry
production
overall.
MB
is
used
on
a
total
area
of
approximately
200
hectares
of
field
beds.
However
there
is
a
large
return
in
the
benefits
of
certified
pest­
free
stock
to
numerous
commercial
growers
throughout
the
continent.
The
raspberry
nursery
industry
uses
flat
fumigation
techniques
similar
to
that
of
the
strawberry
industry.
Raspberry
nursery
stock
is
grown
using
a
two
year
production
cycle
beginning
with
tissue
culture
and
moving
to
foundation
planting
the
first
year.
Winter
dormant
plants
are
replanted
in
commercial
nurseries
and
harvested
after
one
year.

Deciduous
tree
nurseries
range
from
15
to
over
600
hectares
in
field
beds.
A
typical
operation
in
California
ranges
between
80
and
120
hectares.
The
climate
and
soil
make
this
region
an
ideal
area
for
tree
nurseries
(
as
well
as
a
major
fruit
and
nut
producing
region).
While
some
nurseries
concentrate
on
specific
tree
crops,
most
nurseries
grow
and
sell
a
variety
of
different
trees.
Nursery
stock
is
grown
on
a
cropping
system
that
includes
crop
rotation
or
cover
cropping
between
tree
production
cycles;
therefore,
not
all
of
the
nursery
is
in
tree
production
in
a
given
year.
The
tree
production
cycle
can
be
anywhere
from
a
single
year
to
several
years
depending
Page
8
on
the
type
of
tree
crop
being
produced.
Nursery
production
of
trees
takes
from
one
to
four
years
in
the
ground
depending
on
the
type
being
produced.
Almonds
take
one
year
and
walnuts
take
at
least
two
years.
Also,
desired
tree
size
determines
how
long
it
is
grown
in
the
nursery.
The
most
common
cycle
is
for
the
tree
crop
to
be
in
the
ground
for
either
one
or
two
years.
A
typical
nursery
cycle
starts
by
digging
the
current
tree
crop
(
to
be
sold)
then
planting
a
cover
crop
for
one
or
two
years,
followed
by
replanting
with
a
tree
crop.
In
order
to
prepare
the
ground
for
planting,
the
fields
are
disked,
deep
ripped,
leveled,
and
then
fumigated
to
meet
certification
standards
set
by
the
California
Department
of
Food
and
Agriculture
(
CDFA,
1996).
Generally
the
fumigation
work
is
contracted
out.
A
shank
is
used
to
apply
a
fumigation
of
75%
MB
and
25%
chloropicrin,
typically
at
a
rate
of
340
kg
per
hectare.
At
the
same
time
the
majority
of
the
nursery
growers
cover
the
treated
area
with
a
high
barrier
tarp.
The
fumigation
is
carried
out
around
August
and
September,
and
planting
begins
in
October,
and
may
continue
through
January.
The
deciduous
nurseries
are
subject
to
mandates
set
forth
by
the
CDFA,
that
trees
must
be
pest
free.

Nursery
roses
are
grown
in
open
field
plots.
A
typical
crop
rotation
for
a
two
year
rose
crop
includes
one
year
fallow,
followed
by
one
or
two
years
of
rotational
crops,
and
then
a
two
year
rose
crop.
The
two­
year
rose
crop
cycle
begins
with
land
preparation
(
removing
the
cover
crop,
deep
cultivation,
and
fumigation
with
methyl
bromide),
followed
by
planting
the
rootstock
and
T­
bud
grafting.
In
late
winter
of
the
first
year,
the
rootstock
tops
are
removed.
The
rose
crop
matures
by
the
second
autumn
and
is
then
harvested.
This
cycle
varies
depending
on
the
type
of
rose
crop
being
produced
(
e.
g.,
two­
year
roses,
one­
year
minis
and
patio
trees,
or
18­
month
mini
bushes).

METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
63,225
203
.
Page
9
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
Nomination
is
for
areas
within
this
sector
where
alternatives
are
not
suitable,
either
because
of
legal
restrictions,
specific
certification
requirements,
or
physical
features
such
as
unacceptable
soil
moisture.
Acreage
subject
to
quarantine
and
pre
shipment
exemption
(
QPS)
is
not
included.
The
deciduous
fruit
and
nut
tree
nurseries
in
California,
and
the
raspberry
nurseries
in
the
western
states
of
California
and
Washington
produce
the
majority
of
the
stock
for
their
respective
industries;
95%
of
their
sales
are
within
California.
The
majority
of
the
sales
go
to
commercial
fruit
growers
and
the
remaining
trees
are
flowering
varieties
sold
primarily
to
landscapers.
The
nematode
species
of
concern
in
the
nursery
industry
in
Washington
and
California
are
Meloidogyne
spp.,
Pratylenchus
spp.,
Trichodorus
spp.,
Xiphinema
spp.,
and
Criconemelia
spp.
Various
weed
species
and
fungal
pests
are
secondary
pests
in
nurseries.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
in
order
to
qualify
for
a
California
Department
of
Food
and
Agriculture
(
CDFA)
Nursery
Stock
Certificate
for
Interstate
and
Intrastate
Shipments
(
CDFA,
1996).
If
a
nursery
grower
uses
MB
or
if
allowed,
1,3­
D,
the
crop
is
assumed
to
be
"
free
of
especially
injurious
pests
and
disease
symptoms."
However,
if
a
grower
fumigates
with
another
alternative,
or
does
not
fumigate
at
all
and
there
is
history
of
nematode
problems,
the
CDFA
imposes
nematode
sampling
requirements,
which
is
at
the
expense
of
the
grower.
If
nematodes
are
found
stock
will
not
be
certified
and
grower
will
incur
economic
losses.

California
nursery
roses
must
meet
certification
requirements
as
well.
Roses
have
deep
roots,
which
require
pest
control
to
a
depth
of
1.5
meters.
Rose
growers
may
use
1,3­
D
if
the
following
conditions
are
met:
1)
the
field
has
not
been
previously
infested
with
nematodes,
and
2)
soil
moisture
levels
are
not
higher
than
12%,
which
implies
that
only
sandy
soils
are
approved.
In
addition,
township
caps
in
California
restrict
the
amount
of
1,3­
D
that
can
be
used
in
a
given
area.
This
issue
is
especially
important
for
nursery
rose
growers,
as
most
production
of
this
crop
is
concentrated
in
two
townships
where
other
crops
that
also
use
1,3­
D,
such
as
almonds
and
carrots,
are
grown
(
Trout,
2001).
Page
10
TABLE
A.
1:
EXECUTIVE
SUMMARY*

Region
Western
Raspberry
Nurseries
California
Deciduous
Fruit
&
Nut
Tree
Growers
California
Nursery
Roses
AMOUNT
OF
NOMINATION
2006
Kilograms
10,952
31,903
20,167
Application
Rate
(
kg/
ha)
235
336
328
Area
(
ha)
47
95
61
AMOUNT
OF
APPLICANT
REQUEST
2006
Kilograms
49,879
224,528
209,975
Application
Rate
[
Active
Ingredient]
(
AI)
(
kg/
ha)
253
336
337
Area
(
ha)
197
668
622
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Technically
Feasible
Alternative
(
s)
Best
Alternative
Best
Alternative
Best
Alternative
Yield
Loss
(%)

Loss
per
hectare
(
US$/
ha)

Loss
per
kg
Methyl
Bromide
(
US$/
kg)

Loss
as
%
of
Gross
Revenue
(%)

Loss
as
%
of
Net
Revenue
(%)
Not
included
as
there
is
no
technically
feasible
alternative.
Not
included
as
there
is
no
technically
feasible
alternative.
Not
included
as
there
is
no
technically
feasible
alternative.

*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Nurseries
must
provide
stock
that
is
pest­
free
in
order
to
meet
state
mandated
certification
requirements
for
plant
material
(
CDFA,
1996).
Where
allowed
by
township
cap
regulation
and
where
soil
type
and
moisture
are
acceptable,
use
of
products
with
1,3­
D
can
provide
an
alternative
to
MB.
Moisture
restrictions
for
1,3­
D
may
be
more
limiting
than
township
caps.
Nurseries
with
heavy
soils
or
moisture
greater
than
12%
(
especially
common
in
clay
soils
at
depths
of
1
to
1.5
meters)
are
not
likely
to
receive
certification
of
nursery
stock,
because
of
the
inability
to
effectively
reduce
populations
of
nematodes
or
pathogens.
In
these
situations
MB
is
critically
needed.
What
is
of
primary
importance
is
pest­
free
stock
that
is
of
sufficient
quality
to
meet
government
standards
and
comply
with
standards
for
intra­
and
interstate
plant
transit.

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TOTAL
CROP
AREA
2001
 
2002
AVERAGE
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
Western
Raspberry
Nurseries
Not
available
Not
available
California
Deciduous
Fruit
&
Nut
Tree
Growers
Not
available
Not
available
Page
11
California
Nursery
Roses
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.

Nurseries
must
provide
pest
(
pathogens)
free
stock
and
rely
on
MB
for
certification
requirements.

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?

The
critical
need
for
MB
exists
for
nurseries
that
are
limited
by
state
certification
requirements
or
soil
conditions
making
1,3­
D
formulations
unacceptable
for
many
cases.
Some
areas
with
light,
sandy
soil­
types,
appropriate
soil
moisture,
and
no
legal
restrictions
might
be
able
to
replace
MB
with
1,3­
D
alternatives
but
this
is
generally
a
limited
area.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Western
Raspberry
Nurseries
California
Deciduous
Fruit
&
Nut
Tree
Growers
California
Nursery
Roses
YEAR
OF
EXEMPTION
REQUEST
2006
2006
2006
KILOGRAMS
OF
METHYL
BROMIDE
49,879
224,528
209,975
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
75:
25
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
ha)
197
668
622
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
253
336
337
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
375
448
343
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
37.5
44.8
34.3
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
12
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:
 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide
were
subtracted.
There
was
no
double
counting
in
this
sector.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure,
regulatory
impacts,
and
unsuitable
terrain.

TABLE
A.
2:
2006
SECTOR
NOMINATION*

2006
(
Sector)
Nomination
Western
Raspberry
Nurseries
California
Deciduous
Fruit
&
Nut
Tree
Growers
California
Nursery
Roses
Requested
Hectares
(
ha)
197
668
622
Requested
Application
Rate­­
AI
(
kg/
ha)
253
336
337
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
49,879
224,528
209,975
Nominated
Hectares
(
ha)
47
95
61
Nominated
Application
Rate
(
kg/
ha)
235
336
328
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
10,952
31,903
20,167
Overall
Reduction
(%)
87%

2006
U.
S.
CUE
Nomination
(
kg)
63,225
Research
Amount
(
kg)
1506
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
64,731
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
13
WESTERN
RASPBERRY
NURSERIES
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
WESTERN
RASPBERRY
NURSERIES
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
WESTERN
RASPBERRY
NURSERIES.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Western
Raspberry
Nurseries
Primarily
pathogens:
Phytophthora
fragariae
var.
Rubi
(
root
rot),
Verticillium
spp.
(
wilt),
others
including
Pythium
spp.,
Rhizoctonia
spp.
To
meet
certification
requirements
for
sale
of
nursery
stock
within
and
outside
of
states.

WESTERN
RASPBERRY
NURSERIES
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
Raspberry
nurseries
in
the
western
U.
S.
provide
raspberry
stock
to
most
of
the
growers
in
North
America.
There
are
relatively
few
raspberry
nurseries,
yet
they
have
a
large
impact
on
raspberry
production
overall.
USDA
organic
standards
specifically
allow
the
use
of
nursery
stock
propagated
using
MB
for
organic
production
in
recognition
of
the
vital
role
vigorous
planting
stock
plays
in
organic
and
integrated
pest
management
systems.
This
further
confirms
that
the
use
of
MB
in
propagation
nurseries
reduces
the
need
for
MB,
and
other
chemical
inputs,
in
fruiting
fields.
MB
use
is
concentrated
within
nurseries
having
a
total
area
of
approximately
200
hectares.

According
to
this
consortium,
" 
fallow
is
part
of
the
two­
year
cycle.
The
production
of
one
acre
of
raspberry
nursery
is
a
24­
month
process.
It
begins
with
land
preparation
in
January
of
year
1.
A
cover
crop
is
then
grown
during
the
winter,
spring
and
early
summer
of
year
1.
In
the
summer
the
cover
crop
is
incorporated
into
the
soil
and
the
land
is
prepared
for
fumigation.
There
is
a
brief
fallow
period
in
June
of
year
1
prior
to
fumigation.
The
field
is
fumigated
in
August
of
year
1.
The
planting
beds
are
constructed
in
September
of
year
1.
These
beds
lay
"
fallow"
through
the
winter,
until
February
of
year
2.
The
planted
crop
will
grow
until
harvest
in
November
and
December
of
year
2.
Following
the
harvest
we
begin
another
cycle
in
January.

Although
the
nursery
is
a
24­
month
process,
some
land
is
fumigated
each
year
to
provide
an
annual
supply
of
planting
stock
for
our
farmers.
Therefore,
the
amount
stated
in
the
application
refers
to
an
annual
usage."
Page
14
WESTERN
RASPBERRY
NURSERIES.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
WESTERN
RASPBERRY
NURSERIES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
raspberry
cane
stock
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
2­
3
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
1
year
in
foundation
nursery,
1
year
in
commercial
nursery.
The
raspberry
nursery
industry
utilizes
flat
fumigation
techniques
similar
to
that
of
the
strawberry
industry.
Raspberry
nursery
stock
are
grown
using
a
two
year
production
cycle
beginning
with
tissue
culture
and
moving
to
foundation
nurseries
the
first
year.
Winter
dormant
plants
are
replanted
in
commercial
nurseries
and
harvested
after
one
year.
Ten
hectares
of
plants
in
a
foundation
nursery
will
serve
to
plant
100
hectares
of
a
commercial
nursery.
A
commercial
nursery
produces
enough
plants
to
provide
1200
hectares
of
commercial
fields;
therefore,
pest
infestation
of
nursery
plants
can
impact
significant
areas
of
commercial
fields.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light,
medium
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
2­
3
years
OTHER
RELEVANT
FACTORS:
None
identified
WESTERN
RASPBERRY
NURSERIES.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
8a,
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
*
For
Fresno,
California.

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

Soil
moisture
is
an
important
determinant
of
capacity
of
1,3­
D
efficacy
(
5).
Moisture
above
12%
is
common
below
1
meter
depth
and
reduction
of
1,3­
D
nematicidal
activity
results
at
this
moisture
level;
this
is
especially
a
problem
with
nurseries
with
heavier
soils.
It
is
critical
that
nurseries
must
control
pests
in
the
top
1
meter
of
soil
because
the
plant
roots
extend
to
this
depth.
In
addition,
certification
requirements
make
MB
critical
for
many
nurseries.
Page
15
WESTERN
RASPBERRY
NURSERIES
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
WESTERN
RASPBERRY
NURSERIES.
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)
100
83
103
111
103
131
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
25,485
21,313
26,671
26,937
24,188
30,570
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67:
33
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected,
with
tarp
shank
injected,
with
tarp
shank
injected,
with
tarp
shank
injected,
with
tarp
shank
injected,
with
tarp
shank
injected,
with
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
255
257
258
242
235
234
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
385
385
385
360
350
350
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
38.5
38.5
38.5
36.0
35.0
35.0
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
16
WESTERN
RASPBERRY
NURSERIES.
PART
C:
TECHNICAL
VALIDATION
Western
Raspberry
Nurseries
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
WESTERN
RASPBERRY
NURSERIES.
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
not
sufficiently
effective
to
meet
standards
for
pest­
free
nursery
stock
no
1,3­
dichloropropene
(
1,3­
D)
in
areas
with
moisture
restrictions
(
e.
g.,
>
12%
at
1­
1.5
meters)
(
or
under
township
caps)
would
not
be
able
to
meet
standards
for
pest­
free
nursery
stock;
nurseries
with
no
such
restrictions
should
be
able
to
use
1,3­
D
as
an
alternative
only
where
light
soils
and
township
caps
allow
use
metam­
sodium
not
sufficiently
effective
to
meet
standards
for
pest­
free
nursery
stock
no
dazomet
Like
metam­
sodium
is
not
an
effective
nematicide.
The
use
of
dazomet
in
combination
with
Telone
was
examined
in
a
study
submitted
by
the
applicant.
The
study
showed
that
although
weed
populations
were
suppressed,
nematode
populations
were
not
controlled,
causing
stock
to
be
commercially
unacceptable.
When
dazomet
was
used
in
combination
with
1,3­
D,
nematode
populations
were
15
times
greater
when
compared
to
that
of
a
dual
application
of
1,3­
D.
Importantly,
dazomet
does
not
allow
for
certification
of
the
stock.
no
Page
17
NON
CHEMICAL
ALTERNATIVES
containerized
production
A
field
is
planted
with
tissue
culture
plugs.
The
wide,
flat
planting
beds
allow
these
plants
to
grow
laterally
in
all
directions
and
to
produce
long
straight
roots.
The
nursery
is
watered
using
overhead
irrigation,
this
creates
optimal
growing
conditions
over
the
entire
surface
area
of
the
beds.

Switching
to
containers
would
require
much
more
land
area
to
make
up
for
the
lack
of
efficiency
in
the
system.
In
addition,
there
would
be
the
cost
of
the
containers,
the
cost
of
the
planting
mix
which
would
have
to
be
discarded
after
each
use,
and
all
the
increased
labor
costs
associated
with
a
container
based
system.

At
the
end
of
the
growing
season
when
plants
are
dormant
they
are
mowed
to
about
20
cm
long.
The
canes
are
chopped
into
small
pieces
and
later
they
are
incorporated
into
the
soil
to
increase
the
organic
matter.
Then
the
beds
are
"
lifted"
and
shaken,
this
removes
soil
from
the
plants
and
makes
it
easier
to
pick
the
plants
up
and
place
them
in
a
box
for
transfer
to
the
trimming
operation.
This
system
is
very
efficient
because
the
crews
can
simply
move
up
each
row
with
a
mower,
then
the
lifter
followed
by
several
workers
who
transfer
the
plants
into
the
bin
for
movement
to
the
trimming
operation.

With
field
grown
plants,
plants
are
produced
with
long
straight
roots.
The
roots
are
trimmed
from
the
canes
at
the
trim
shed
and
the
trimmed
roots
are
long
enough
to
provide
the
root
planting
material
used
by
the
growers.
Much
of
the
land
planted
by
growers
comes
from
these
trimmed
roots.
Generally,
containergrown
plants
produce
shorter
or
curved
roots.
New
canes
are
produced
from
adventitious
root
buds,
it
is
likely
that
any
reduction
in
surface
area
would
reduce
the
number
and/
or
quality
(
size,
strength)
of
these
new
adventitious
canes.

Nursery
managers
have
observed
that
when
raspberries
are
grown
in
pots,
the
south
or
hot
side
of
the
pot
is
not
an
optimal
environment
for
growing
raspberry
roots.
Pots
are
seen
where
there
are
no
roots
within
a
significant
distance
of
the
hot
surface
of
the
pot.
This
heat
further
reduces
yields
and
increases
water
demands.
Some
of
the
largest
nurseries
are
located
in
the
eastern
San
Joaquin
Valley
of
California
where
temperatures
can
reach
over
40
C
in
the
summer
months.
While
the
canes
and
aboveground
plant
parts
can
tolerate
these
temperatures,
roots
are
not
as
large
and
healthy
as
what
is
produced
in
field
systems.
no
Virtually
Impermeable
Film
(
VIF)
Might
have
role
in
reducing
MB
use
rates
while
maintaining
efficacy
due
to
reduced
emissions
(
Guillino
et
al.,
2002;
Martin,
2003).
Ongoing
studies
may
help
assess
value
of
VIF
with
MB
and
chemical
alternatives.
no
Page
18
biofumigation,
solarization,
steam
heat,
biological
control,
cover
crops/
mulches,
crop
rotation,
flooding
and
water
management,
grafting/
resistant
rootstocks,
organic
amendments,
sanitation,
and
resistant
cultivars
Some
of
these
alternatives
are
important
components
of
an
IPM
system
and
are
currently
employed
by
the
industry.
These
practices
include
field
sanitation
to
reduce
inoculum,
crop
rotation
to
reduce
hosts,
and
attempts
to
breed
resistance
to
pathogens.
However,
these
alternatives
will
not
meet
requirements
of
CDFA
for
nursery
stock
certification
either
individually
or
in
combinations.
Use
of
flooding
is
not
practical
because
of
the
topographic
features
of
many
production
areas
and
requirements
for
excessive
water
use.
The
use
of
steam
also
requires
extremely
large
quantities
of
water
and
is
very
slow
and
expensive
to
perform
which
would
impact
planting
and
production
intervals
for
this
industry.
Use
of
solarization
is
not
practical
due
to
the
depth
of
heating
required
to
eliminate
viable
weed
seed
and
environmental
constraints
at
high
altitude
nurseries
including
high
winds.
Biological
control
currently
is
not
a
feasible
alternative;
studies
done
with
biological
control
agents
at
Clemson
University,
South
Carolina
in
conjunction
with
University
of
California­
Riverside,
have
not
shown
sufficient
promise
to
date
to
expect
commercial
use
in
the
near
future.
no
COMBINATIONS
OF
ALTERNATIVES
(
1,3­
D)
+
chloropicrin
in
areas
with
moisture
restrictions
(
e.
g.,
>
12%
at
1­
1.5
meters)
(
or
under
township
caps)
would
not
be
able
to
meet
standards
for
pest­
free
nursery
stock;
nurseries
with
no
such
restrictions
should
be
able
to
use
1,3­
D
as
an
alternative
only
where
light
soils
and
township
caps
allow
use
(
1,3­
D)
+
metamsodium
in
areas
with
moisture
restrictions
(
e.
g.,
>
12%
at
1­
1.5
meters)
(
or
under
township
caps)
would
not
be
able
to
meet
standards
for
pest­
free
nursery
stock;
nurseries
with
no
such
restrictions
should
be
able
to
use
1,3­
D
as
an
alternative
only
where
light
soils
and
township
caps
allow
use
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

WESTERN
RASPBERRY
NURSERIES
­
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
below
ground
portions
of
raspberries.
Page
19
WESTERN
RASPBERRY
NURSERIES
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

WESTERN
RASPBERRY
NURSERIES.
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
Present
Registration
Status
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

sodium
azide
not
registered
in
U.
S.,
no
registration
has
been
requested
No
unknown
propargyl
bromide
not
registered
in
U.
S.,
no
registration
has
been
requested
No
unknown
iodomethane
not
registered
in
U.
S.
Yes
unknown
WESTERN
RASPBERRY
NURSERIES
­
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
As
with
other
nursery
commodities,
yield
is
not
the
only
(
and
possibly
not
the
most
important)
factor
in
the
production
of
raspberry
nursery
stock.
What
is
of
primary
importance
is
pest­
free
stock
that
is
of
sufficient
quality
to
meet
government
standards
and
comply
with
standards
for
intra­
and
interstate
plant
transit.
While
disease
and
other
pest
issues
also
occur
with
MB
treated
nurseries,
the
long
time
use
of
MB
has
given
a
level
of
experience
with
that
compound
that
is
only
beginning
to
be
assessed
with
alternatives.
Consequently,
the
industry
still
has
a
critical
need
for
MB
until
lessons
gained
from
research
with
alternatives
can
be
transferred
to
successful
implementation
in
commercial
nursery
locations.
Page
20
WESTERN
RASPBERRY
NURSERIES.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
DISEASES
KEY
PEST:
DISEASES
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
[
1]
MB
(
263
kg/
ha)
+
chloropicrin
(
129
kg/
ha)
[
2]
chloropicrin
(
140
kg/
ha)
[
3]
no
fumigation
no
pests
identified
12
reps
Runners/
mother
plant
(
strawberry)
[
1]
18.0a
[
2]
15.7b
[
3]
7.9c
Larson
and
Shaw,
2000
[
1]
MB
(
314
kg/
ha)
+
chloropicrin
(
78
kg/
ha)
[
2]
chloropicrin
(
191
kg/
ha)
[
3]
chloropicrin
(
303
kg/
ha)
[
4]
no
fumigation
no
pests
identified
4
reps
Runners/
mother
plant
(
strawberry)
[
1]
29.7a
[
2]
27.0a
[
3]
29.7a
[
4]
11.2b
Larson
and
Shaw,
2000
[
1]
MB
(
263
kg/
ha)
+
chloropicrin
(
129
kg/
ha)
[
2]
chloropicrin
(
157
kg/
ha)
[
3]
chloropicrin
(
314
kg/
ha)
[
4]
no
fumigation
no
pests
identified
24
reps
Runners/
mother
plant
(
strawberry)
[
1]
18.8a
[
2]
16.7b
[
3]
18.9a
[
4]
10.3c
Larson
and
Shaw,
2000
[
1]
MB
(
263
kg/
ha)
+
chloropicrin
(
129
kg/
ha)
[
2]
chloropicrin
(
168
kg/
ha)
[
3]
chloropicrin
(
336
kg/
ha)
[
4]
1,3­
D
(
134
kg/
ha)
+
chloropicrin
(
314
kg/
ha)
[
5]
1,3­
D
(
361
kg/
ha)
+
chloropicrin
(
155
kg/
ha)
[
6]
no
fumigation
no
pests
identified
12
reps
(
MB
trt,
11
reps)
Runners/
mother
plant
(
strawberry)
[
1]
39.2a
[
2]
28.6bc
[
3]
33.8abc
[
4]
35.8ab
[
5]
33.0bc
[
6]
15.8d
Larson
and
Shaw,
2000
N.
B.:
some
studies
were
with
strawberry
research,
a
crop
with
similar
pest
problems
and
because
of
the
large
size
of
the
industry,
a
greater
resource
for
research
data.
Page
21
WESTERN
RASPBERRY
NURSERIES.
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
More
important
than
yield
for
raspberry
nurseries,
as
well
as
other
nurseries,
is
their
dependence
on
certification
of
stock
as
`
pest­
free'
in
order
to
meet
state
requirements
to
sell
to
commercial
outlets.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
(
225
kg/
ha)+
chloropicrin
(
123
kg/
ha)
(
fungal)
pathogens
(
strawberry
nursery)
2­
15%
(
ref.:
CDFA,
1996;
Gullino
et
al.,
2002)
14%

chloropicrin
(
300
kg/
ha)
(
fungal)
pathogens
(
strawberry
nursery)
5­
16%
(
ref.:
CDFA,
1996;
Gullino
et
al.,
2002)
9%

metam­
sodium
(
350
kg/
ha)
(
fungal)
pathogens
(
strawberry
nursery)
13­
57%
(
Gullino
et
al.,
2002)
30%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
9%
plus
certification
issues
WESTERN
RASPBERRY
NURSERIES
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Raspberry
nurseries
have
spent
$
100,000
on
research,
including
$
20,000
on
screening
resistance
for
Phytophthora
and
Verticillium,
and
over
$
60,000
over
the
last
decade
studying
various
alternatives
in
the
large
Watsonville,
California
area.
Studies
are
also
ongoing
to
discover
how
application
methods
can
improve
efficacy
of
chemical
alternatives
such
as
1,3­
D
and
metam­
sodium,
and
mixes
of
chemicals.
Moisture
constraints,
both
too
much
and
too
little,
can
reduce
efficacy
of
effective
chemicals
such
as
1,3­
D,
especially
when
soil
textures
are
not
optimal
for
their
physical
chemistry.

The
use
of
virtually
impermeable
film
(
VIF)
may
offer
a
means
of
reducing
MB
use
rates
while
maintaining
efficacy
and
production
goals
.
Work
is
being
conducted
to
determine
if
this
type
of
film
is
feasible
in
the
U.
S.
from
a
technical
standpoint
(
e.
g.,
does
it
hold
up
physically
in
field
conditions?
can
it
be
glued
to
acceptable
specifications?,
etc.)
and
economically
feasible
(
e.
g.,
cost
of
material,
cost
of
application).
However,
the
efficacy
of
VIF
for
U.
S.
agriculture
may
be
different
than
that
for
Europe
(
Federal
Register,
1998).
There
is
also
interest
in
examining
the
effects
of
certain
fertilizer
salts
(
e.
g.,
ammonium
thiosulfate,
see
Gan
and
Yates,
1998),
which
may
act
as
barriers
to
volatile
compounds
(
e.
g.,
1,3­
D,
MB)
when
applied
to
the
soil
surface,
thus
reducing
emissions
and
improving
efficacy.
Page
22
WESTERN
RASPBERRY
NURSERIES
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

In
some
conditions
alternative
chemicals
are
used
and
research
is
ongoing
to
increase
efficacy,
as
has
been
described
above.

WESTERN
RASPBERRY
NURSERIES
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
raspberry
nursery
industry
faces
the
same
problems
that
other
nurseries
face
in
their
need
to
produce
nearly
pest­
free
plant
stock
to
their
respective
growers.
Quality
of
stock
plants
may
have
a
greater
place
in
the
requirements
of
the
nursery
managers
than
quantity
since
there
can
be
an
exponential
increase
in
pest
pressure
when
infested
nursery
stock
is
transferred
to
production
fields.
Therefore,
the
threshold
for
nurseries
to
manage
pest
problems
is
higher
than
might
be
for
field
production
and
critical
need
for
effective
pest
management
tools
is
paramount.
Because
locations
of
nurseries
vary
and
soil,
climate,
and
water
conditions
are
variable,
some
alternatives
may
be
acceptable
substitutes
for
MB
under
low
pest
pressure.
However,
for
the
industry
to
succeed,
currently
there
are
no
alternatives
that
will
allow
nurserymen
to
have
confidence
that
their
production
goals
can
be
met
without
MB,
at
least
until
research
indicates
that
alternatives
are
feasible.
As
highlighted
in
two
exhaustive
metaanalyses
studies
(
Larson
and
Shaw,
2000;
Shaw
and
Larson,
2000),
alternatives
are
not
currently
available
to
meet
this
sector's
production
needs.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
Page
23
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Deciduous
Fruit
&
Nut
Tree
Growers
Nuts:
Nematodes
 
Pratylenchus
vulnus
(
root
lesion),
Meloidogyne
spp.
(
root
knot),
Helicotylenchus
dihystera
(
spiral),
Xiphinema
americanum
(
dagger).

Stone
Fruit:
Nematodes
 
Helicotylenchus
dihystera
(
spiral),
Tylenchus
mexicanus
(
Tylenchus),
Tylenchorhynchus
spp.
(
stunt),
Trichodorus
spp.
(
stubby
root)
Nurseries
providing
stock
for
orchards
are
required
to
provide
the
stock
that
is
pest­
free
(
and
particularly
nematode­
free).
MB
is
particularly
effective
in
penetrating
soil
depths
to
reduce
(
frequently
eliminate)
nematode
populations
and
therefore
allow
movement
of
nursery
stock
intra­
and
interstate.
The
alternative
1,3­
dichloropropene
is
usually
an
effective
nematicide,
but
it's
use
is
restricted
in
California
and
may
not
be
available
to
all
the
nurseries
that
require
effective
pest
management
tools
to
meet
certification.
Compounds
producing
methyl
isothiocyanate
(
MITC)
have
been
tested
as
possible
alternatives
(
e.
g.,
metam­
sodium
and
dazomet)
but
nematode
control
was
not
sufficient
beyond
a
short
(
6
month)
time
period,
not
long
enough
to
meet
certification
requirements.
Furthermore,
because
of
strict
legal
requirements,
only
MB
(
and
in
some
localities,
1,3­
D)
applications
are
acceptable
for
quarantine
specifications.

The
goal
in
the
orchard
nursery
industry
is
99.9%
control
when
sampled
within
30­
60
days
after
treatment,
so
certification
can
be
met
when
stock
is
harvested
18
months
later
(
McKenry,
2000).
Generally,
less
than
98%
control
in
the
30­
60
day
sampling
period,
will
yield
unacceptable
stock
plants.
Field
moisture
is
a
carefully
monitored
factor.
A
site
(
e.
g.,
walnut
nursery
in
Davis,
California)
with
silty
clay
loam
over
sandy
loam
or
clay
loam
has
moisture
differential
with
the
lighter
textured
soils
holding
more
moisture
(>
12%),
which
can
impede
distribution
of
an
alternative
such
as
1,3­
D
(
McKenry,
2000)
and
make
it
ineffective.
In
California
deciduous
tree
nurseries,
approximately
30%
have
silt
or
clay
loam
soils
requiring
MB.
The
remaining
70%
have
sand
or
sandy
loam
soils.
Approximately
one
half
of
these
areas
have
a
critical
need
for
MB
due
to
moisture
requirements.
Therefore,
according
to
the
applicant,
approximately
65%
of
nursery
soils
in
California
have
a
critical
need
for
MB.
Township
caps
for
1,3­
D
may
further
limit
the
use
of
the
best
alternative.
Page
24
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
Deciduous
tree
nurseries
range
from
15
to
over
600
hectares
in
size.
The
median
operation
in
California
ranges
between
80
and
120
hectares.
While
some
nurseries
concentrate
on
specific
tree
crops,
most
nurseries
grow
and
sell
a
variety
of
different
trees.
Nursery
stock
is
grown
on
a
cropping
system
that
includes
crop
rotation
or
cover
cropping
between
tree
production
cycles;
therefore,
not
all
of
the
nursery
is
in
tree
production
in
a
given
year.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
nursery
tree
stock
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial
(
1
to
2
years
in
nursery)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
The
tree
production
cycle
can
be
anywhere
from
1
year
to
several
years
depending
on
the
type
of
tree
crop.
Nursery
production
of
trees
takes
from
1­
4
years.
Almonds
take
one
year,
walnuts
take
at
least
two
years.
Also,
desired
tree
size
determines
how
long
it
is
grown
in
the
nursery.
A
typical
cycle
is
for
the
tree
crop
to
be
in
the
ground
for
either
1
or
2
years.
A
typical
nursery
cycle
starts
by
digging
the
current
tree
crop
(
to
be
sold)
then
planting
a
cover
crop
for
1
or
2
years,
followed
by
replanting
with
a
tree
crop.
Fields
are
disked,
deep
ripped,
leveled,
and
then
fumigated
to
meet
certification
standards
set
by
the
California
Department
of
Food
and
Agriculture
(
CDFA,
1996).
A
shank
is
used
to
apply
a
fumigation
of
75%
MB
and
25%
chloropicrin,
typically
at
a
rate
of
340
kg
per
hectare.
The
treated
area
is
covered
with
a
high
barrier
tarp.
The
fumigation
is
carried
out
around
August
and
September,
and
planting
begins
in
October,
and
may
continue
through
January.
The
deciduous
nurseries
are
subject
to
mandates
set
forth
by
the
CDFA,
that
trees
must
be
pest­
free.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
mostly
sandy
loam
(
also
sandy
clay
loam,
sandy
loam,
silt
loam,
clay
loam);
light
soils
(
20%),
medium
(
50%),
heavy
(
30%)
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
typically
once
in
3­
5
years,
depending
on
crop
OTHER
RELEVANT
FACTORS:
Nursery
stock
is
inspected
by
county
agricultural
commissioners
through
the
California
Department
of
Food
and
Agriculture
(
CDFA).
Stock
must
be
"
found
free
of
especially
injurious
pests
and
disease
symptoms"
to
qualify
for
the
CDFA
Nursery
Stock
Certificate
for
Interstate
and
Intrastate
Shipments.
MB
is
the
only
approved
Page
25
CHARACTERISTICS
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
fumigant
for
fields
with
a
known
history
of
nematodes,
unknown
history,
or
moderate
to
heavy
clay
content
soils.
While
1,3­
D
is
a
legally
acceptable
treatment
in
some
areas,
township
restrictions
and
physical
limitations
(
e.
g.,
moisture
greater
than
12%
in
many
soils
reduces
efficacy
of
1,3­
D)
can
reduce
its
use.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
8a,
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
X
PLANTING
SCHEDULE
X
X
X
X
*
For
Fresno,
California.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Soil
moisture
content
of
greater
than
12%
reduces
efficacy
of
1,3­
D.
Soils
that
are
so
dry
are
unusual
at
1.5
meters
(
the
depth
required
to
be
nematode­
free)
(
CDFA,
1996)
especially
with
moderate
to
heavy
subsoils.
Approximately
65%
of
nurseries
require
MB
to
meet
certification
requirements
(
especially
in
wet
years).
Areas
with
light
soils
and
dry
conditions
generally
have
good
results
from
1,3­
D
(
where
township
caps
allow
its
use)
and
combinations
with
chloropicrin
and/
or
metam­
sodium.
(
See
Section
10,
above.)
Page
26
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
Approximately
30%
of
nursery
soils
are
clay
or
silt
loam
and
require
MB,
while
one
half
of
the
remaining
sand
or
sandy
loam
soils
do
not
meet
the
moisture
requirements
of
less
than
12%
for
use
of
1,3­
D.
Therefore,
approximately
65%
of
the
nurseries
have
a
critical
need
for
MB.
MB,
1,3­
D
and
some
solarization
treatments
are
the
only
approved
fumigants
for
treatment
of
nematodes
in
nurseries
to
meet
California
Department
of
Food
and
Agriculture
standards.
However,
MB
is
critical
to
the
production
of
nematode­
free
stock
where
1,3­
D
is
not
feasible
(
approximately
65%
of
the
area)
because
of
incompatible
soil
moisture
or
soil
type,
or
township
cap
limitations.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
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)
652
632
698
639
633
not
reported
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
not
reported
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
215,592
201,208
222,433
207,755
212,689
not
reported
FORMULATIONS
OF
METHYL
BROMIDE
(
e.
g.
methyl
bromide
98:
2;
methyl
bromide
/
chloropicrin
70:
30)
75:
25
75:
25
75:
25
75:
25
75:
25
not
reported
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
with
tarp
shank
injected
with
tarp
shank
injected
with
tarp
shank
injected
with
tarp
shank
injected
with
tarp
not
reported
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
331
319
318
325
336
not
reported
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
441
425
425
433
448
not
reported
Page
27
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
44.1
42.5
42.5
43.3
44.8
not
reported
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS.
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
dazomet,
metamsodium
Not
effective
nematicides.
The
use
of
dazomet
in
combination
with
Telone
was
examined
in
a
study
submitted
by
the
applicant.
The
study
showed
that
although
weed
populations
were
suppressed,
nematode
populations
were
not
controlled,
causing
stock
to
be
commercially
unacceptable.
When
dazomet
was
used
in
combination
with
1,3­
D,
nematode
populations
were
15
times
greater
when
compared
to
that
of
a
dual
application
of
1,3­
D.
Importantly,
dazomet
and
metam­
sodium
will
not
allow
for
certification
of
the
seedling
without
additional
expense
to
the
grower.
no
NON
CHEMICAL
ALTERNATIVES
STANDARD
NURSERY
PRACTICES
SEEK
TO
REDUCE
PEST
PROBLEMS
WITH
GENERAL
IPM
PROGRAMS.
HOWEVER,
FOR
THIS
SECTOR
NON­
CHEMICAL
ALTERNATIVES
ARE
NOT
TECHNICALLY
FEASIBLE
BECAUSE
OF
CALIFORNIA
CERTIFICATION
REQUIREMENTS
FOR
NEMATODE­
FREE
PLANT
STOCK
AND
TOWNSHIP
CAPS
AND
BUFFER
ZONE
RESTRICTIONS.

Virtually
Impermeable
Film
(
VIF)
Might
have
role
in
reducing
MB
use
rates
while
maintaining
efficacy
due
to
reduced
emissions
(
Gullino
et
al.,
2002;
Martin,
2003).
Studies
are
being
conducted
to
assess
film
with
MB
and
chemical
alternatives.
no
Page
28
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biofumigation,
solarization,
steam
heat,
biological
control,
cover
crops/
mulches,
crop
rotation,
flooding
and
water
management,
grafting/
resistant
rootstocks,
organic
amendments,
sanitation,
and
resistant
cultivars.
Some
of
these
alternatives
are
important
components
of
an
IPM
system
and
are
currently
employed
by
the
industry.
These
practices
include
field
sanitation
to
reduce
inoculum,
crop
rotation
to
reduce
hosts,
and
attempts
to
breed
resistance
to
pathogens.
However,
these
alternatives
will
not
meet
requirements
of
CDFA
for
nursery
stock
certification
either
individually
or
in
combinations.
Use
of
flooding
is
not
practical
because
of
the
topographic
features
of
many
production
areas
and
requirements
for
excessive
water
use.
The
use
of
steam
also
requires
extremely
large
quantities
of
water
and
is
very
slow
and
expensive
to
perform
which
would
impact
planting
and
production
intervals
for
this
industry.
Use
of
solarization
is
not
practical
due
to
the
depth
of
heating
required
to
eliminate
viable
weed
seed
and
environmental
constraints
at
high
altitude
nurseries
including
high
winds.
Biological
control
currently
is
not
a
feasible
alternative;
studies
done
with
biological
control
agents
at
Clemson
University,
South
Carolina
in
conjunction
with
University
of
California­
Riverside,
have
not
shown
sufficient
promise
to
date
to
expect
commercial
use
in
the
near
future.
no
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
no
1,3­
D
+
chloropicrin
+
metam­
sodium
no
1,3­
D
+
metamsodium
no
1,3­
D
+
dazomet
Only
feasible
in
limited
areas.
In
most
affected
areas,
especially
those
with
moderate
to
heavy
soils
or
subsoils,
moisture
at
depths
of
1.5
meters
(
depth
required
for
nematode­
free
certification)
(
CDFA,
1996)
is
usually
>
12%,
which
significantly
reduces
efficacy
of
1,3­
D.
This
situation
would
occur
in
at
least
65%
of
affected
soils.
While
some
research
trials
indicate
that
these
alternatives
can
be
effective
in
nematode
control
in
certain
nursery
areas
(
e.
g.,
Schneider
et
al.,
2002b;
Westerdahl
et
al.,
2002),
for
the
nursery
sector
as
a
whole
the
certification
standard
is
so
high
that
only
limited
nursery
areas
will
be
able
to
use
1,3­
D/
mixes
if
certification
requirements
are
to
be
satisfied.
Therefore,
there
is
still
a
critical
need
for
the
use
of
MB
for
production
of
nursery­
grown
orchard
stock.
According
to
one
calculation
(
Martin
et
al.,
2003),
overall
in
California
33%
of
the
area
previously
fumigated
with
MB
could
not
be
treated
with
1,3­
D
due
to
current
township
caps,
regardless
of
efficacy.
Caps,
combined
with
limitations
due
to
unacceptable
soil
moisture
make
alternatives
unlikely
to
replace
the
critical
need
of
MB
for
at
least
a
large
portion
of
this
nursery
sector.
no
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
29
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
below
ground
portions
of
deciduous
fruit
and
nut
trees.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

sodium
azide
not
registered
in
U.
S.,
no
registration
has
been
requested
No
unknown
propargyl
bromide
not
registered
in
U.
S.,
no
registration
has
been
requested
No
unknown
iodomethane
not
registered
in
U.
S.
Yes
unknown
Page
30
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
NEMATODES.

KEY
PEST:
NEMATODES
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
TRIALS
DISEASE
(%
OR
RATING)
CITATION
[
1]
untreated
[
2]
MB
(
568
kg/
ha)
[
Tarped]
[
3]
1,3­
D
(
272
kg/
ha)
+
chloropicrin
(
155
kg/
ha)
[
Telone
35,
Untarped]
[
4]
1,3­
D
(
312
kg/
ha)
+
chloropicrin
(
177
kg/
ha)
[
Telone
35,
Tarped]
[
5]
chloropicrin
(
400
kg/
ha)
[
Untarped]
[
6]
chloropicrin
(
455
kg/
ha)
[
Tarped]
mean
of
6
reps.
in
vine,
tree,
berry
field
nursery
trial
Rootknot
nematode
population/
cc
soil
sampled
at
120­
150
cm
depth
[
1]
21.3a
[
2]
0b
[
3]
0b
[
4]
2.2b
[
5]
0b
[
6]
0b
Schneider
et
al.,
2002b
[
1]
untreated
[
2]
MB
(
285
kg/
ha)
[
Tarped,
Fall]
[
3]
MB
(
285
kg/
ha)
[
Tarped,
Spring]
[
4]
metam­
sodium
(
425
kg/
ha
injected
+
329
kg/
ha
overlay
rotovate)
[
Tarped]
[
5]
metam­
sodium
(
425
kg/
ha
injected
+
329
kg/
ha
overlay
rotovate)
[
Untarped]
4
reps,
trial
Malin,
Oregon,
2001;
loamy
sand;
moisture
2%
at
surface,
19%
at
1
meter)
Percent
control
of
citrus
nematode
(
bioindicator)
compared
to
untreated:

[
2]
93%
(
some
survival
at
80
cm
depth)
[
3]
93%
(
some
survival
at
80
cm
depth)
[
4]
81%
(
survival
at
65­
80
cm
depth)
[
5]
73%
%
(
survival
below
5
cm
depth)
Westerdahl
et
al.,
2002
[
1]
untreated
[
2]
MB
(
455
kg/
ha)
[
shank,
Tarped]
[
3
1,3­
D
(
445
kg/
ha)
[
drip
Telone
II
EC;
Tarped]
4
reps,
artificially
inoculated
soils
with
rootknot
and
citrus
nematodes
to
depths
of
30
cm,
90
cm,
and
150
cm
Percent
control
of
citrus
and
rootknot
nematodes
compared
to
untreated:

[
2]
100%
(
at
all
depths)
[
3]
significant
nematode
populations
at
150
cm;
control
at
30
cm
was
"
excellent"
Schneider
et
al.,
2003a
Page
31
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
Yield
is
not
a
sufficient
measure
of
critical
need
for
MB
for
this
industry
or
to
determine
economic
feasibility
in
this
sector
since
the
issue
is
one
of
constraints
due
to
the
quality
of
the
plant
stock
and
the
ability
to
have
such
stock
certified
as
pest­
free
in
order
to
sell
to
commercial
users.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
(
312
kg/
ha)+
chloropicrin
(
177
kg/
ha)
nematodes
Not
applicable
Not
applicable
1,3­
D
(
312
kg/
ha)
+
chloropicrin
(
177
kg/
ha)
+
metam­
sodium
(
350
kg/
ha)
nematodes
Not
applicable
Not
applicable
1,3­
D
+
metam­
sodium
(
350
kg/
ha)
nematodes
Not
applicable
Not
applicable
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
Not
applicable;
certification
issues
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Between
1999
and
2000,
the
California
fruit,
vine,
and
nut
industries
have
spent
$
378,467
on
numerous
research
projects.
From
2002­
2003,
$
262,002
were
granted
to
researchers
by
this
industry.
In
addition,
an
equal
amount
has
been
granted
by
government
and
universities.

Research
for
MB
alternatives
has
been
conducted
in
earnest
by
the
nursery
industry
since
at
least
1990,
initially
to
find
alternatives
to
1,3­
D,
whose
registration
had
been
cancelled
(
Martin,
2003).
Upon
reinstatement
in
1994,
studies
began
to
examine1,3­
D
formulations
and
mixes
that
could
provide
acceptable
nematode
control
under
conditions
(
especially
critical
moisture
conditions)
common
to
commercial
nursery
sites
that
would
meet
certification
requirements
and
reduce
or
replace
the
use
of
MB
(
Martin,
2003;
McKenry,
2000).
Successful
treatment
with
1,3­
D
depends
on
enough
surface
moisture
to
allow
penetration
into
the
soil,
but
less
than
12%
moisture
(
difficult
to
achieve
with
heavier
soils
at
depths
over
1
meter).
Consequently,
while
experiments
are
continuing,
the
"
learning
curve"
is
significant,
and
the
critical
need
for
methyl
bromide
exists
in
many
nurseries,
for
technical
limitations
of
soil­
type
and
moisture,
and
township
limitations
of
1,3­
D
(
CDFA,
1996;
Martin,
2003).

Studies
with
new
emulsifiable
formulations
of
1,3­
D
and
chloropicrin
,
such
as
Inline
may
improve
efficacy
by
removing
technical
limitations
of
shank
injected
1,3­
D.
However,
township
caps,
buffer
zones,
and
limitations
due
to
physical
characteristics
of
soils
are
still
important
issues
to
successful
nursery
production.
Page
32
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

1,3­
D
can
be
effective
in
some
situations,
where
soil,
moisture,
and
legal
caps
are
not
limiting.

CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
primary
concern
for
the
deciduous
tree
nursery
industry
is
their
need
to
have
their
stock
certified
according
to
the
strict
standards
set
for
inter­
and
intrastate
movement
of
plant
material.
According
to
the
government
oversight
authorities
(
CDFA,
1996)
MB,
and
in
certain
cases,
1,3­
D,
are
the
only
treatments
that
are
recognized
as
able
to
satisfactorily
control
nematodes,
the
primary
pest
of
deciduous
tree
nurseries.
The
issue
with
critical
use
of
MB
is
the
circumstance
of
many
nurseries
whose
soil
type
or
other
conditions
(
e.
g.,
township
caps,
buffer
zone
limitations)
precludes
the
use
of
1,3­
D
formulations.
Consequently,
MB
is
still
considered
a
critical
tool
for
this
industry's
ability
to
maintain
its
production
and
market
goals.
In
those
areas
with
light
soils
and
no
legal
restrictions,
1,3­
D
formulations
may
suffice
to
meet
certification
requirements.
Page
33
CALIFORNIA
NURSERY
ROSES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
NURSERY
ROSES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
NURSERY
ROSES
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Nursery
Roses
(
primarily
in
the
San
Joaquin
Valley
 
55
to
65%
of
U.
S.
rose
plant
production
is
located
around
Wasco,
Kern
County,
CA)
Root
knot
nematode
(
Meloidogyne
hapla);
lesion
nematode
(
Pratylencus
penetrans);
pin
nematode
(
Paratylenchus
hamatus);
Verticillium
dahlia;
Pythium
spp.;
Agrobacterium
tumefaciens;
weeds
(
including
Cyperus
spp.)
California
Nursery
Stock
regulations
state
that
nursery
stock
must
be
commercially
clean
with
respect
to
established
pests
of
general
distribution.
County
agricultural
officials
may
certify
a
crop
based
on
the
completion
of
a
prescribed
fumigation
regime,
such
as
the
use
of
methyl
bromide
(
CDFA,
1996).
In
addition,
control
must
to
a
depth
of
1.5
meters,
and
methyl
bromide
is
uniquely
suited
for
this
situation.

CALIFORNIA
NURSERY
ROSES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
CALIFORNIA
NURSERY
ROSES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
NURSERY
ROSES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplant
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Perennial
(
see
below)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Typically,
crop
rotation
for
a
two
year
rose
crop
includes
one
year
fallow,
followed
by
one
or
two
years
of
rotational
crops,
and
then
a
two
year
rose
crop.
This
rotation
varies
depending
on
the
type
of
rose
crop
being
produced
(
i.
e.,
two­
year
roses,
one­
year
minis
and
patio
trees,
or
an
18­
month
mini
bush).

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Medium
soil
with
0
to
2%
organic
matter.

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
every
4
to
5
years
(
a
typical
grower
fumigates
and
plants
approximately
20­
25%
of
the
acreage
he
or
she
controls
each
year).

OTHER
RELEVANT
FACTORS:
The
perennial
nature
of
the
crop
requires
pest
control
to
a
depth
of
1.5
meters.
Certification
requires
commercially
clean
stock.
In
tree
nursery
production,
there
must
be
99.9%
nematode
control
in
the
first
30
to
60
days
to
meet
this
requirement
(
McKenry,
2000).
Page
34
CALIFORNIA
NURSERY
ROSES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE+

MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
Plant
Hardiness
Zone
9a
RAINFALL
(
mm)*
16.0
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
Land
prep
X
PLANTING
SCHEDULE
X
X
KEY
MARKET
WINDOW
+
The
planting
and
fumigation
schedule
are
for
1
year
roses.
The
schedules
vary
for
other
rose
crops.
*
Data
for
Jan­
Aug,
2003
and
Sep­
Dec
2002
for
Fresno,
California.

For
a
particular
parcel
of
land,
the
overall
cycle
is
shown
below
(
Table
11.3).
This
schedule
will
vary
depending
on
the
type
of
rose
crop
grown.
For
example,
two
year
rose
crops
would
be
grown
an
additional
year
before
harvesting.

CALIFORNIA
NURSERY
ROSES
­
TABLE
11.3
MULTI­
YEAR
ROSE
CROP
SCHEDULE
SPR*
SUM
FAL
WNT
SPR
SUM
FAL
WNT
SPR
SUM
FAL
WNT
SPR
SUM
FAL
WNT
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
HARVEST
SCHEDULE
X
X
FALLOW
X
X
X
X
COVER
CROP
X
X
X
X
X
*
spr
=
spring;
sum
=
summer;
fal
=
fall;
wnt
=
winter
CALIFORNIA
NURSERY
ROSES
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

No
characteristics
were
identified
that
would
prevent
the
uptake
of
any
relevant
alternative.
Page
35
CALIFORNIA
NURSERY
ROSES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
NURSERY
ROSES
­
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)
611
600
609
647
645
584
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
205,613
201,803
204,933
217,588
219,938
183,396
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shanked
10
inches
deep
and
tarped
Shanked
10
inches
deep
and
tarped
Shanked
10
inches
deep
and
tarped
Shanked
10
inches
deep
and
tarped
Shanked
10
inches
deep
and
tarped
Shanked
10
inches
deep
and
tarped
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
336
336
336
336
341
314
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
343
343
343
343
343
343
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
34.3
34.3
34.3
34.3
34.3
34.3
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
36
CALIFORNIA
NURSERY
ROSES
­
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
NURSERY
ROSES
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
NURSERY
ROSES
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
Dichloropropene
1,3­
D
is
technically
feasible
in
some
situations,
such
as
areas
with
sandy
soils
where
the
soil
moisture
can
be
reduced
to
12
percent
or
less.
According
to
California
certification
regulations,
this
alternative
is
not
acceptable
on
soils
known
to
be
infested
with
nematodes
(
CDFA,
1996).

Nematodes
were
not
controlled
at
deeper
depths
in
several
studies.
In
a
tree
nursery
study,
nematodes
were
controlled
at
deeper
depths
with
1,3­
D
and
its
combinations.
Control
is
comparable
to
methyl
bromide
in
sandier
soils
because
the
soil
moisture
can
be
reduced
to
12
percent
or
less
(
McKenry,
2000;
McKenry,
2001).
In
a
nursery
rose
trial,
preliminary
results
demonstrate
that
only
methyl
bromide
can
control
the
entire
nematode
complex
to
the
depth
required
(
Schneider
et
al,
2002a).
Results
with
1,3­
D
are
inconsistent,
as
other
studies
have
shown
control
of
nematodes
with
1,3­
D
plus
chloropicrin.
1,3­
D
plus
chloropicrin
did
not
control
Verticillium
dahliae,
Pythium
spp.,
or
weeds
in
a
rose
trial
(
Karlick
et
al,
1998).

Township
caps
are
in
place
for
1,3­
D.
Almost
all
of
California
nursery
growers
are
located
within
two
townships
in
one
county,
and
rose
growers
compete
for
the
use
of
1,3­
D
with
growers
of
almonds,
carrots,
and
other
crops
for
this
acreage
(
Trout,
2001).
Buffer
zones
of
300
feet
apply
in
California,
reducing
the
amount
of
acreage
that
can
be
treated
with
1,3­
D.
No
Dazomet
(
Basamid)
Dazomet
is
not
a
technically
feasible
alternative
because
it
does
not
adequately
control
target
pests
at
deep
enough
levels
in
the
soil
in
a
rose
trial
(
Schneider
et
al,
2002a).
Dazomet
and
metamsodium
are
both
MITC
generating
substances
and
the
inability
of
MITC
from
metam
sodium
to
penetrate
deep
enough
at
the
maximum
allowed
application
rate
is
likely
to
also
be
true
for
dazomet.
No.

Metam­
sodium
Metam­
sodium
is
not
a
technically
feasible
alternative
alone
because
it
results
in
nursery
rose
shipments
that
are
not
certifiable.
Research
indicates
that
a
non­
certifiable
crop
occurs
because
metam­
sodium
did
not
move
deep
enough
into
the
soil
(
at
the
1.2
to
1.5
meter
depth
metam
sodium
did
not
control
the
nematodes)
(
Schneider
et
al,
2002a).
Metam
sodium
provides
inconsistent
control
(
McKenry,
1999).
Metam
sodium
also
does
not
control
Pythium
spp.
(
Karlick
et
al,
1998).
No.
Page
37
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

NON
CHEMICAL
ALTERNATIVES
Solarization,
Steam
Sterilization,
Biological
Control
Under
proper
climatic
conditions,
solarization
will
control
pests
to
a
depth
of
30
cm.
This
depth
is
far
short
of
the
1.5
meters
required
for
nursery
roses
(
Pizano,
2001;
Braun
and
Supkoff,
1994).
In
addition,
these
treatments
would
not
allow
a
nursery
rose
grower
to
meet
the
California
certification
standard
(
CDFA,
1996).
No.

General
IPM,
Grafting/
Resistant
Rootstock/
Plant
Breeding,
Physical
Removal/
Sanitation,
Resistant
Cultivars
Although
these
"
not
in­
kind"
alternatives
are
being
used
by
nursery
rose
growers
to
reduce
pest
pressure,
in
general,
by
themselves
and
in
combination,
each
have
not
been
successful
at
achieving
adequate
pest
control.
In
addition,
these
"
not
in­
kind"
alternatives
alone
would
not
allow
a
nursery
rose
grower
to
meet
the
California
certification
standard.
No.

Substrates/
Plug
Plants
Use
of
"
plug
plants"
is
not
technically
feasible
for
nursery
growers
because
virtually
all
production
is
by
grafting
onto
resistant
rootstock,
not
by
the
use
of
cuttings.

Substrate
production
in
CA
is
technically
infeasible
for
two
reasons.
One,
roses
are
a
deep
rooted
crop.
Rose
rootstock
is
grown
for
18
months
(
called
1­
year
by
the
market)
or
2
years
resulting
in
root
systems
of
3
feet.
The
containers
do
not
allow
full
development
of
the
root
systems
which
then
reduces
the
rigor/
vigor
of
the
plant.
Second,
production
in
CA
is
technically
infeasible
based
on
the
scale
of
production.
Plants
are
spaced
6"
apart
on
thousands
of
acres.
Research
would
need
to
be
conducted
to
determine
the
commercial
feasibility
of
a
change
of
this
magnitude
to
a
soilless
culture.
No.

COMBINATIONS
OF
ALTERNATIVES
1,3­
Dichloropropene
+
chloropicrin
and/
or
metam
sodium
See
the
regulatory
and
technical
limitations
for
1,3­
Dichloropropene
above.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

CALIFORNIA
NURSERY
ROSES
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Iodomethane
+
chloropicrin
Iodomethane
plus
chloropicrin
appears
to
be
the
best
solution
to
replace
the
use
of
methyl
bromide.
Studies
have
shown
the
control
of
all
nematode
genera
found
on
roses
at
a
depth
of
1.5
meters
(
Schneider
et
al,
2002a).
This
treatment
is
likely
to
require
some
additional
weed
control
measures,
but
does
provide
weed
control
that
is
comparable
to
methyl
bromide
in
many
cases.
This
alternative
is
not
registered.
Page
38
CALIFORNIA
NURSERY
ROSES
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
NURSERY
ROSES
 
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
Yes
Unknown
Sodium
azide
Not
registered
Registration
package
not
submitted
Unknown
Propargyl
bromide
Not
registered
Registration
package
not
submitted
Unknown
CALIFORNIA
NURSERY
ROSES
­
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
Research
on
MB
alternatives
for
the
nursery
rose
industry
is
described.
Growers
need
to
achieve
nematode
control
to
a
depth
of
1.5
meters
to
meet
regulation
requirements.
Other
pests,
such
as
Verticillium,
Pythium,
and
weeds
also
need
to
be
controlled.
Some
studies
on
tree
nurseries
have
been
included
since
growers
must
meet
the
same
certification
requirement
for
stock.
Not
all
studies
contained
yield
information,
pest
pressure,
and
comparison
to
methyl
bromide
or
statistical
analyses.

Evaluation
of
Alternatives
to
Methyl
Bromide
for
Roses
(
Schneider
et
al,
2002a;
Schneider
et
al,
2003b).
Preliminary
data
from
a
study
by
the
Agricultural
Research
Service,
USDA
were
submitted.
Nematodes
were
sampled
in
250
cc
soil
at
the
following
depths:
0­
12
inches
(
0­
0.3
meters),
12­
24
inches
(
0.3­
0.6
meters),
24­
36
inches
(
0.6­
0.9
meters),
36­
48
inches
(
0.9­
1.2
meters),
and
48­
60
inches
(
1.2­
1.5
meters).
Stunt
nematode
(
Tylenchorhynchus
spp.)
was
predominantly
found
at
the
site,
but
populations
of
root
knot
nematode
(
Meloidogyne
spp.)
and
stubby
root
nematode
(
Paratrichodorus
spp.)
were
also
present
at
low
levels.
The
only
alternatives
that
provided
control
to
the
lowest
depth
(
1.2
to
1.5
meters)
were
methyl
bromide
and
iodomethane
drip
applications,
although
these
results
were
not
statistically
different
from
many
of
the
other
alternatives.
The
following
year,
additional
data
were
collected,
including
weed
ratings.
Methyl
bromide
had
the
best
weed
rating
of
all
the
alternatives.
Additional
data,
including
summer/
fall
nematode
and
fungal
populations
in
the
soil
and
plant
quality
at
harvest,
are
yet
to
be
collected.
The
results
are
shown
in
Tables
16.3
and
16.4.
Page
39
Jackson
and
Perkins
Fumigant
Tests,
2003.
Preliminary
data
submitted
by
Jackson
and
Perkins
Operation,
Inc.
showed
yield
losses
of
2
 
8%
for
metam­
sodium
(
Vapam
HL,
701
L/
ha),
yield
losses
of
5%
for
1,3­
D
(
Telone
II,
309
L/
ha),
and
for
methyl
bromide
(
336
kg/
ha)
yield
gains
of
up
to
10%
to
yield
losses
of
6%
The
data
submitted
gave
yields
compared
to
historic
yields
for
numerous
rose
varieties.
The
first
year
results
indicated
that
there
was
no
nematode
pressure
in
the
trials.
There
was
no
statistical
analysis
on
the
results.

Other
studies
submitted
were
conducted
on
orchard
and
vineyard
crops.
Some
the
results
are
included
in
the
tables
below.
These
studies
demonstrate
that
the
alternative
do
not
provide
the
same
level
of
nematode
control
as
methyl
bromide
to
the
depth
required.

CALIFORNIA
NURSERY
ROSES
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
NEMATODES
KEY
PEST:
NEMATODES
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
TOTAL
#
NEMATODES
AT
A
DEPTH
ACROSS
ALL
REPLICATES
(
The
results
have
been
added
across
the
4
replicates
 
there
is
no
statistical
analysis
on
these
results).
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
REPLICATIONS
DEPTH
#
OF
NEMATODES
MB
+
CP
(
75/
25)
535
lb/
ac
(
599
kg/
ha),
tarped
4
0­
1
feet
(
0­
0.3
meters)
1­
2
feet
(
0.3­
0.6
meters)
2­
3
feet
(
0.6­
0.9
meters)
3­
4
feet
(
0.9­
1.2
meters)
4­
5
feet
(
1.2­
1.5
meters)
0
0
0
2
15
Dual
application
Telone
C­
35
@
65
gpa
(
608
L/
ha)
or
approx.
650
lb/
acre
(
728
kg/
ha)
4
0­
1
feet
(
0­
0.3
meters)
1­
2
feet
(
0.3­
0.6
meters)
2­
3
feet
(
0.6­
0.9
meters)
3­
4
feet
(
0.9­
1.2
meters)
4­
5
feet
(
1.2­
1.5
meters)
2
1
0
2
47
1,3­
D
(
330
lb/
ac
(
370
kg/
ha))
then
metam
sodium
drench
(
110
lb/
ac
(
123
kg/
ha))
4
0­
1
feet
(
0­
0.3
meters)
1­
2
feet
(
0.3­
0.6
meters)
2­
3
feet
(
0.6­
0.9
meters)
3­
4
feet
(
0.9­
1.2
meters)
4­
5
feet
(
1.2­
1.5
meters)
5
0
1
40
103
1,3­
D
(
330
lb/
ac
(
370
kg/
ha))
then
Basamid
drench
(
200
lb/
ac
(
224
kg/
ha))
4
0­
1
feet
(
0­
0.3
meters)
1­
2
feet
(
0.3­
0.6
meters)
2­
3
feet
(
0.6­
0.9
meters)
3­
4
feet
(
0.9­
1.2
meters)
4­
5
feet
(
1.2­
1.5
meters)
0
0
0
2
16
Non­
treated
check
4
0­
1
feet
(
0­
0.3
meters)
1­
2
feet
(
0.3­
0.6
meters)
2­
3
feet
(
0.6­
0.9
meters)
3­
4
feet
(
0.9­
1.2
meters)
4­
5
feet
(
1.2­
1.5
meters)
98
455
416
836
216
McKenry,
2000
(
this
study
was
conducted
on
tree
nurseries).
Page
40
CALIFORNIA
NURSERY
ROSES
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
 
PHYTOPHTHORA
KEY
PEST:
PHYTOPHTHORA
CITRICOLA
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
TOTAL
NUMBER
OF
COLONIES
FORMED
OUT
OF
10
INOCULUM
PIECES
PLATED
AT
CERTAIN
DEPTHS
ACROSS
ALL
REPLICATES
(
max
#
is
40
 
4
reps
x10
pieces.
No
statistical
analysis
on
these
results)
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
REPLICATIONS
DEPTH
#
OF
COLONIES
MB
+
CP
(
75/
25)
535
lb/
ac
(
599
kg/
ha),
tarped
4
0.5
feet
(
0.2
meters)
2.0
feet
(
0.6
meters)
4.0
feet
(
1.2
meters)
0
10
40
Dual
application
Telone
C­
35
@
65
gpa
(
608
L/
ha)
or
approx.
650
lb/
acre
(
728
kg/
ha)
4
0.5
feet
(
0.2
meters)
2.0
feet
(
0.6
meters)
4.0
feet
(
1.2
meters)
0
0
20
1,3­
D
(
330
lb/
ac
(
370
kg/
ha))
then
metam
sodium
drench
(
110
lb/
ac
(
123
kg/
ha))
4
0.5
feet
(
0.2
meters)
2.0
feet
(
0.6
meters)
4.0
feet
(
1.2
meters)
5
20
38
1,3­
D
(
330
lb/
ac
(
370
kg/
ha))
then
Basamid
drench
(
200
lb/
ac
(
224
kg/
ha))
4
0.5
feet
(
0.2
meters)
2.0
feet
(
0.6
meters)
4.0
feet
(
1.2
meters)
0
0
40
Non­
treated
check
4
0.5
feet
(
0.2
meters)
2.0
feet
(
0.6
meters)
4.0
feet
(
1.2
meters)
37
30
30
McKenry,
2000
(
This
study
was
conducted
on
tree
nurseries).
Page
41
CALIFORNIA
NURSERY
ROSES
 
TABLE
16.3:
EFFECTIVENESS
OF
ALTERNATIVES
 
STUNT
NEMATODE
KEY
PEST:
STUNT
NEMATODE
Disease
(%
or
rating)
Mean
of
6
replications
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
REPS
0­
12
INCHES
(
0
 
0.3
METERS)
24­
36
INCHES
(
0.6­
0.9
METERS)
48­
60
INCHES
(
1.2
 
1.5
METERS)

Untreated
6
1.0
b*
29.8
a
5.8
ab
Methyl
bromide
 
350
lb/
acre
(
392
kg/
ha),
tarped
 
noble
plow
6
0.0
b
0.0
b
0.0
c
30%
Iodomethane
70%
Chloropicrin
 
400
lb/
acre
(
448
kg/
ha),
tarped
 
noble
plow
6
0.0
b
0.0
b
0.4
bc
Telone
C35
 
48
gal/
acre
(
449
L/
ha)
 
noble
plow
6
0.0
b
0.9
b
6.2
ab
Telone
C35
 
48
gal/
acre
(
449
L/
ha);
untarped
 
telone
rig
6
0.0
b
0.3
b
3.5
abc
Inline
 
50
gal/
acre
(
468
L/
ha),
drip
6
0.0
b
0.3
b
2.4
abc
Telone
EC
 
35
gal/
acre
(
327
L/
ha),
drip
6
0.0
b
0.9
b
6.9
ab
Chloropicrin
 
200
lb/
acre
(
224
kg/
ha),
drip
6
0.0
b
3.0
b
13.3
a
Chloropicrin
 
400
lb/
acre
(
448
kg/
ha),
drip
6
0.0
b
1.4
b
4.8
abc
Chloropicrin
 
200
+
200
lb/
acre
(
224
+
224
kg/
ha),
drip
6
0.0
b
0.0
b
4.2
abc
30%
Iodomethane
70%
­
400
lb/
acre
(
448
kg/
ha),
drip
6
0.0
b
0.0
b
0.0
c
50%
Iodomethane
50%
Chloropicrin
 
300
lb/
acre
(
336
kg/
ha),
drip
6
0.2
b
0.0
b
0.0c
Metam
sodium
 
75
gal/
acre
(
701
L/
ha)
(
42%
a.
i.),
drip
6
0.2
b
0.0
b
10.0
a
Iota
(
a
bacterial
suspension
from
FUSION
360,
Turlock,
CA)
6
5.5
a
47.8
a
7.9
ab
Schneider
et
al,
2002b
*
Statistical
analysis
conducted
on
log
transformed
(
ln(
n+
1))
data.
Data
presented
are
the
antilogs
of
the
means.
Stunt
Nematode
Populations
per
250cc
soil
sampled
at
planting
in
a
commercial
rose
trial.
Results
at
other
depths
(
12­
24
inches
(
0.3­
0.6
meters)
and
36­
48
inches
(
0.9­
1.2
meters)
are
also
available
in
the
study.
Page
42
CALIFORNIA
NURSERY
ROSES
 
TABLE
16.4:
EFFECTIVENESS
OF
ALTERNATIVES
 
ROOT
KNOT
NEMATODE
KEY
PEST:
ROOT
KNOT
NEMATODE
ROOT
KNOT
NEMTAODE
POPULATIONS
PER
100
CC
SOIL
SAMPLED
AT
PLANTING
IN
A
COMMERCIAL
ROSE
TRIAL
MARCH
2003
DISEASE
(%
OR
RATING)
#
OF
NEMATODES
(
SOIL
SAMPLED
TO
A
DEPTH
OF
24
INCHES
(
0.6
METERS))
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
REPS
MEAN
RANGE
Untreated
6
18.0
a
0­
805
Methyl
bromide
 
350
lb/
acre
(
392
kg/
ha),
tarped
 
noble
plow
6
0
c
0­
0
30%
Iodomethane
70%
Chloropicrin
 
400
lb/
acre
(
448
kg/
ha),
tarped
 
noble
plow
6
0
c
0­
0
Telone
C35
 
48
gal/
acre
(
449
L/
ha)
 
noble
plow
6
0.8
bc
0­
32
Telone
C35
 
48
gal/
acre
(
449
L/
ha);
untarped
 
telone
rig
6
6.4
ab
0­
354
Inline
 
50
gal/
acre
(
468
L/
ha),
drip
6
0
c
0­
0
Telone
EC
 
35
gal/
acre
(
327
L/
ha),
drip
6
0
c
0­
0
Chloropicrin
 
200
lb/
acre
(
224
kg/
ha),
drip
6
0
c
0­
0
Chloropicrin
 
400
lb/
acre
(
448
kg/
ha),
drip
6
0
c
0­
0
Chloropicrin
 
200
+
200
lb/
acre
(
224
+
224
kg/
ha),
drip
6
0
c
0­
0
30%
Iodomethane
70%
­
400
lb/
acre
(
448
kg/
ha),
drip
6
0
c
0­
0
50%
Iodomethane
50%
Chloropicrin
 
300
lb/
acre
(
336
kg/
ha),
drip
6
0
c
0­
0
Metam
sodium
 
75
gal/
acre
(
701
L/
ha)
(
42%
a.
i.),
drip
6
0.5
bc
0­
12
Iota
(
a
bacterial
suspension
from
FUSION
360,
Turlock,
CA)
6
10.8
a
0­
213
Schneider
et
al,
2003b
Statistical
analyses
conducted
on
log
transformed
(
log(
n+
1))
data.
Data
presented
are
antilogs
of
the
means,
as
well
as
the
range
of
values.
Means
followed
by
the
same
letter
are
not
significantly
different
at
the
P=.
05
level.
Page
43
CALIFORNIA
NURSERY
ROSES
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
Although
yield
and
quality
losses
may
occur
due
to
key
pests,
the
only
studies
for
nursery
roses
are
ongoing.
Because
these
studies
are
in
progress
and
the
crop
is
perennial,
yield
losses
have
not
been
determined.
However,
the
crop
must
meet
certification
requirements
or
the
stock
will
not
be
accepted.
The
pests
must
be
controlled
or
the
growers
will
not
be
able
to
sell
their
product.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
See
paragraph
above.
Nematodes
Not
applicable
Not
applicable
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
Not
applicable;
certification
issues
CALIFORNIA
NURSERY
ROSES
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

The
industry
is
developing
technologies
to
improve
efficacy
of
alternatives
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
experience
with
virtually
impermeable
films
to
increase
efficacy
and
decrease
emissions.
Between
2001
and
2003,
$
60,000
was
devoted
to
nursery
rose
alternatives
research
at
USDA
and
on
farm
research.

Iodomethane
will
control
the
target
pests
but
is
not
currently
registered.

CALIFORNIA
NURSERY
ROSES
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

1,3­
D
can
be
used
in
some
situations,
such
as
areas
with
sandy
soils
where
the
soil
moisture
can
be
reduced
to
12
percent
or
less.
According
to
California
certification
regulations,
this
alternative
is
not
acceptable
on
soils
known
to
be
infested
with
nematodes
(
CDFA,
1996).
Township
caps
also
limit
the
use
of
this
alternative.
A
grower
that
tried
using
1,3­
D
found
that
weeds
were
not
controlled
satisfactorily.

Some
growers
are
able
to
control
their
planting
ground
for
long
periods
of
time
thus
avoiding
crops
and
weeds
that
are
hosts
to
nematodes.
However,
re­
infestation
is
always
a
threat
through
contaminated
irrigation
water,
runoff
water,
or
weeds.
In
addition,
the
income
from
the
rotational
crop,
often
a
cereal
crop,
is
about
1/
3
of
that
received
for
roses.
Page
44
CALIFORNIA
NURSERY
ROSES
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Although
1,3­
D
with
chloropicrin
has
been
demonstrated
as
an
effective
alternative
in
some
situations,
in
many
cases
it
does
not
control
the
target
pests.
In
soils
with
moisture
levels
above
12
percent,
1,3­
D
does
not
provide
control
of
nematodes.
In
addition,
1,3­
D
does
not
control
Verticillium
dahilae,
Pythium
spp.,
or
weeds.
Also,
there
are
regulatory
limitations
to
the
use
of
1,3­
D.
Growers
must
meet
certification
requirements.
Only
under
specific
circumstances,
such
as
an
area
with
sandy
soils
(
moisture
levels
below
12
percent)
with
no
known
nematode
problems,
may
this
alternative
be
used.
In
addition,
township
caps
may
limit
the
availability
of
this
alternative
to
growers,
especially
since
nursery
roses
are
primarily
produced
in
two
townships,
where
other
crops
that
use
1,3­
D
are
also
grown.

Other
alternatives,
such
as
metam
sodium
and
dazomet
do
not
provide
consistent
control
of
target
pests
to
a
depth
of
1.5
meters.

Although
iodomethane
provides
good
control
of
the
target
pests,
it
is
not
currently
registered.
Page
45
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.
VIF
might
be
a
feasible
means
of
reducing
emissions
if
physical
properties
of
VIF
can
be
improved,
especially
the
ability
to
successfully
and
consistently
roll
the
film
over
beds
without
breakage
and
ability
to
glue
the
material.
Most
nurseries
have
reduced
MB
amounts
to
lower
rate
formulations.
Between
1997
and
2001,
the
U.
S.
has
achieved
a
36%
reduction
in
use
rates.
From
2%
to
33%
or
25%
(
for
some
nurseries)
No
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
Research
is
underway
to
develop
use
of
a
50%
MB
formulation
where
pest
pressure
allows.
Research
is
underway
to
develop
use
of
a
50%
MB
formulation
where
pest
pressure
allows.
Not
likely
OTHER
MEASURES
(
please
describe)
Unidentified
Unidentified
Unidentified
Fumigation
once
every
2
 
3
years
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
Reduction
technology
is
being
addressed
by
this
sector.
For
example,
VIF
products,
use
of
advanced
delivery
techniques,
such
as
deep
injection,
to
make
alternative
chemicals
more
effective
at
deeper
soil
levels,
and
reduction
in
use
rate
of
MB
to
50:
50.
While
new
mixtures
and
formulations
can
be
effective
at
controlling
target
pests,
especially
at
low
pest
pressure,
the
long
term
efficacy
of
these
mixtures
is
unknown.
Page
46
PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
This
table
is
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

22.
GROSS
AND
NET
REVENUE
TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
These
tables
are
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
WESTERN
RASPBERRY
NURSERIES
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
DECIDUOUS
FRUIT
&
NUT
TREE
GROWERS
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
NURSERY
ROSES
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
These
tables
are
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

SUMMARY
OF
ECONOMIC
FEASIBILITY
An
economic
analysis
was
not
done
because
most
of
the
losses
cannot
be
quantified
because
there
are
no
data
to
substantiate
the
magnitude
of
these
losses.

Certification
requirements.
The
requested
amount
of
methyl
bromide
in
the
U.
S.
nomination
includes
only
those
areas
where
1,3
dichloropropene
(
1,3­
D)
would
not
meet
the
certification
requirements
or
would
be
limited
by
township
caps.
The
requirement
that
the
nursery
stock
be
certified
as
pest
free
is
what
makes
the
alternatives
economically
infeasible.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
in
order
to
qualify
for
a
California
Department
of
Food
and
Agriculture
(
CDFA)
Nursery
Stock
Certificate
for
Interstate
and
Intrastate
Shipments
(
CDFA,
1996).
If
an
approved
fumigation
is
not
used
in
the
nursery,
a
costly
nematode
sampling
procedure
is
Page
47
imposed
by
CDFA,
and
if
nematodes
are
found
all
nursery
stock
in
an
area
should
be
destroyed
resulting
in
a
complete
loss.
Methyl
bromide
meets
the
certification
guidelines.
Also,
in
certain
soil
conditions,
1,3­
D
meets
certification
guidelines;
however,
California
township
caps
imposed
by
the
CDPR
(
California
Department
of
Pesticide
Regulation)
may
limit
the
use
of
1,3­
D.

If
an
approved
fumigation
is
not
used
and
a
nematode
sampling
procedure
is
imposed
by
CDFA,
it
is
likely
that
nematodes
would
be
found
because:
 
1,3
D
is
less
effective
in
soil
conditions
where
1,3
D
does
not
meet
the
certification
guidelines,
or
 
There
is
no
effective
nematicide
if
1,3
D
cannot
be
used
due
to
California
township
caps.

If
nematodes
are
found
and
the
nursery
stock
cannot
be
certified
"
free
of
especially
injurious
pests
and
disease
symptoms",
then
a
total
loss
is
likely
because
the
nursery
stock:
 
Would
not
qualify
for
a
CDFA
Nursery
Stock
Certificate
for
Interstate
and
Intrastate
Shipments,
 
Would
probably
not
be
marketable,
since
resale
for
planting
is
severely
restricted
by
the
CDFA.
 
Should
be
destroyed
to
prevent
further
infestation.

Yield
loss.
It
is
likely
that
yield
losses
would
also
occur
where
soil
conditions
are
not
ideal,
but
little
data
are
available.
The
yield
loss
could
be
100%
if
the
nursery
stock
cannot
be
certified
as
pest
free.

Reduced
pesticide
use.
An
effective
fumigation
results
in
a
growth
response
that
allows
an
initial
growth
spurt.
This
growth
response
helps
maintain
a
healthy
plant,
which
is
able
to
better
handle
the
stress
induced
by
pathogens
and
pests.
A
healthier
plant
consequently
requires
a
fewer
number
of
pesticide
sprays
during
the
season.

Beyond
the
nursery.
Healthier
plants
and
trees
provide
benefits
beyond
the
nursery
in
terms
of
higher
yields
of
fruit
and
nuts
and
reduced
infestations.
One
hectare
of
nursery
stock
provides
these
benefits
to
many
hectares
producing
fruits
and
nuts.
Page
48
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Primarily,
development
of
technologies
to
improve
efficacy
of
alternatives
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
experience
with
virtually
impermeable
films
to
increase
efficacy
and
decrease
emissions,
while
allowing
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.
For
roses,
future
research
is
planned
for
nematodes,
Pythium
and
weeds.
For
2001­
2003,
$
60,000
is
devoted
to
alternatives
research
at
USDA
and
on
farm
research.
Raspberry
nurseries
have
spent
$
100,000
on
research,
including
$
20,000
on
screening
resistance
for
Phytophthora
and
Verticillium,
and
over
$
60,000
over
the
last
decade
studying
various
alternatives
in
the
large
Watsonville,
California
area.
Between
1999
and
2000,
the
California
fruit,
vine,
and
nut
industries
have
spent
$
378,467
on
numerous
research
projects.
From
2002­
2003,
$
262,002
were
granted
to
researchers
by
this
industry.
In
addition,
an
equal
amount
has
been
granted
by
government
and
universities.

The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
orchard
seedlings
research
will
require
1506
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
two
year
field
study
testing
the
comparative
performance
of
methyl
bromide,
1,3­
D,
iodomethane,
sodium
azide,
resistant
cultivars,
and
fallow
for
control
of
nematodes
and
weeds.
Another
example
is
a
five
year
field
study
comparing
methyl
bromide
to
1,3­
D,
chloropicrin,
iodomethane,
fallow,
cover
crops,
solarization,
and
other
treatments
for
control
of
nematodes
and
soil
borne
pathogens.

24.
ARE
THERE
PLANS
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

As
stated
in
Section
23,
minimizing
use
of
MB
can
be
achieved
through
the
development
of
technologies
to
improve
efficacy
of
alternatives
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
experience
with
virtually
impermeable
films
to
increase
efficacy
and
decrease
emissions,
and
still
have
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.
As
described
in
Section
23,
considerable
resources
are
being
devoted
to
finding
MB
alternatives.
Plans
to
develop
VIF,
deep
injection,
1,3­
D
efficacy,
and
reduction
of
MB
use
rates
are
all
ongoing.
Transferring
these
technologies
to
field
situations
requires
additional
time.
Until
these
alternatives
can
be
relied,
MB
is
critical
for
this
sector.
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
Page
49
many
years
to
reduce
use
rates
and
emissions.
We
will
continue
to
work
with
the
user
community
in
each
sector
to
identify
further
opportunities
to
reduce
methyl
bromide
use
and
emissions.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

This
methyl
bromide
critical
use
exemption
nomination
for
raspberry,
rose,
and
deciduous
tree
nurseries
has
been
reviewed
by
the
United
States
government
and
meets
the
guidelines
of
The
Montreal
Protocol
on
Substances
That
Deplete
the
Ozone
Layer.
This
use
is
considered
critical
because
there
are
no
technically
and
economically
feasible
alternatives
or
substitutes
available
for
nurseries
that
have
heavy
soils,
are
restricted
by
township
caps
of
1,3­
D,
and/
or
have
state
mandated
certification
standards
that
require
the
use
of
MB
in
situations
where
1,3­
D
is
not
allowed
or
effective.
The
loss
of
MB
under
these
circumstances
would,
therefore,
result
in
a
significant
market
disruption
and
provides
the
basis
for
nomination
of
this
sector
for
critical
use
exemption
of
MB.
Page
50
26.
CITATIONS
Braun,
A.
L.
and
D.
M.
Supkoff,
1994.
Options
to
Methyl
Bromide
for
the
Control
of
Soil­
Borne
Diseases
and
Pests
in
California
with
Reference
to
the
Netherlands.
Pest
Management
Analysis
and
Planning
Program,
California
Department
of
Pesticide
Regulation.

California
Department
of
Food
and
Agriculture.
1996.
Approved
treatment
and
handling
procedures
to
ensure
against
nematode
pest
infestation
of
nursery
stock.
California
Code
of
Regulations,
Title
3,
Section
3060,
et
seq.
Nursery
Inspection
Procedures
Manual,
Item
#
12.
18
pp.
http://
www.
cdfa.
ca.
gov/
phpps/
pe/
NIPM.
htm;
http://
www.
cdfa.
ca.
gov/
phpps/
pe/
nipm_
pdfs/
nipm_
7.
pdf
Federal
Register,
February
5,
1998,
40
CFR,
part
82.
Control
of
methyl
bromide
emissions
through
use
of
tarps.
http://
frwebgate5.
access.
gpo.
gov/
cgibin
waisgate.
cgi?
WAISdocID=
826484320000+
6+
0+
0&
WAISaction=
retrieve.

Gan,
J.
and
Yates,
S.
R.
1998.
Ammonium
thiosulfate
fertilizer
reduces
methyl
bromide
emissions
from
soil.
Methyl
Bromide
Alternatives,
USDA,
ARS.
vol
4
(
3),
July,
1998.
http://
www.
ars.
usda.
gov/
is/
np/
mba/
july98/
ammonium.
htm
Gullino,
M.
L.,
Minuto,
A.,
Camponogara,
A.,
Minuto,
G.,
and
Garibaldi,
A.
2002.
soil
disinfestations
in
Italy:
status
two
years
before
the
phase­
out
of
methyl
bromide.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/

Jackson
and
Perkins
Operations,
Inc.
2003.
in­
house
trials.

Karlick,
J.,
J.
Becker,
U.
Schuch,
G.
Browne,
1998,
Beyond
Methyl
Bromide:
Development
and
Implementation
of
Integrated
Bare
Root
Rose
Production
Systems.

Larson,
K.
D.
and
Shaw,
D.
V.
2000.
Soil
fumigation
and
runner
plant
production:
A
synthesis
of
four
years
of
strawberry
nursery
field
trials.
HortScience
35:
642­
646.

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

McKenry,
M.
V.
2000.
Evaluation
of
alternatives
to
methyl
bromide
for
soil
fumigation
at
commercial
fruit
and
nut
tree
nurseries.
Contractor
for
California
Association
of
Nurseryman.
Prepared
for
California
Department
of
Pesticide
Regulation.
(
See
CUE
03­
0035
request
package
of
California
Fruit
and
Nut
Growers
Consortium.)
Page
51
McKenry,
M.
2001.
Performance
of
metam
sodium
drenched
to
six
different
replant
sites.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2001).
http://
mbao.
org/

McKenry,
M.
V.
1999.
The
replant
problem
and
its
management.
Contractor
for
California
Association
of
Nurseryman.
Prepared
for
California
Department
of
Pesticide
Regulation.
Catalina
Publishing,
Fresno,
California,
USA.
(
See
CUE
03­
0035
request
package
of
California
Fruit
and
Nut
Growers
Consortium.)

Pizano,
M.
2001.
Floriculture
and
the
Environment:
Growing
Flowers
without
Methyl
Bromide,
United
Nations
Environment
Programme.

Schneider,
S.,
E.
Rosskopf,
J.
Leesch,
D.
Chellemi,
C.
Bull,
and
M.
Mazzola.
2003a.
United
States
Department
of
Agriculture
 
Agricultural
Research
Service
Research
on
Alternatives
to
Methyl
Bromide:
Pre­
plant
and
Post­
harvest,
Pest
Management
Science
59:
814­
826.

Schneider,
S.,
T.
Trout,
J.
Gerik,
D.
Ramming,
and
H.
Ajwa.
2003b.
Methyl
Bromide
Alternatives
for
Perennial
Field
Nurseries
 
1st
and
2nd
Year
Performance,
Proceeding
from
the
2003
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
www.
mbao.
org
Schneider,
S.,
J.
Gerik,
Trout,
T.
2002a.
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Roses
(
Presentation),
USDA
ARS
Parlier.

Schneider,
S.,
Trout,
T.,
Gerik,
J.
and
Ajwa,
H.
2002b.
Methyl
bromide
alternatives
for
tree,
vine,
and
rose
field
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/

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

Shaw,
D.
V.
and
Larson,
K.
D.
2000.
A
meta­
analysis
of
strawberry
yield
response
to
preplant
soil
fumigation
with
combinations
of
methyl
bromide
 
chloropicrin
and
four
alternative
systems.

Trout,
T.
2001.
Impact
of
Township
Caps
on
Telone
Use
in
California.
(
See
CUE
03­
0028
request
package
of
California
Rose
Nurseries.)

Westerdahl,
B.
B.,
Buchner,
R.
P.,
Loftus,
R.,
and
Loftus,
T.
2002.
Tarped
metam
sodium
for
nematode
and
weed
control
in
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/
Page
52
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).

Methyl
Bromide
Critical
Use
Exemption
Process
2001
&
2002
Average
%
of
2001
&

2002
Average
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
10,952
47
235
78%

20,167
61
328
90%

31,903
95
336
86%

63,225
203
311
87%

87%
86%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
253
235
0
0
0
0
100
100
0
0
0
0
0
0
337
328
0
0
0
0
100
100
44
31
0
0
0
0
336
336
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
No
Yes
Tarp
Yes
+
Yes
2­
3
yr
No
Yes
Yes
Tarp
Yes
­
Yes
3­
5
yr
No
No
Yes
Tarp
Yes
0
Yes
3­
5
yr
Conversion
Units:
1
Pound
=
Kilograms
Hectare
Date:
2/
26/
2004
Average
Hectares
in
the
US:
not
available
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Sector:
FRUIT,
NUT,
&
FLOWER
NURSERY
%
of
Average
Hectares
Requested:

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

REGION
49,879
197
253
27,379
117
235
60%

209,975
622
337
201,667
615
328
90%

633
336
85%

224,528
668
336
212,689
TOTAL
OR
AVERAGE
484,382
1,487
309
441,735
1,364
300
78%

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

(­)
QPS
HIGH
LOW
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
49,879
­
20,363
2,137
16,427
10,952
10,952
209,975
­
2,526
5,782
181,500
20,167
20,167
180,786
31,903
31,903
224,528
­
11,839
­

Nomination
Amount
484,382
484,382
449,655
441,735
63,022
63,022
63,022
87%
87%
87%

%
Reduction
from
Initial
Request
0%
0%
7%

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

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

Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
REGION
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
REGION
REGION
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
Other
Considerations
Adjustments
to
Requested
Amounts
not
available
not
appicable
not
applicable
100%
100%
100%

Quality/
Time/
Market
Window/
Yield
Loss
(%)
not
applicable
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
not
available
0.453592
1
Acre
=
0.404686
100%
100%
100%

9%
or
14%
or
30%
1,3­
D
or
1,3­
D+
Pic
or
Metam+
Pic
not
appicable
Marginal
Strategy
not
available
Combined
Impacts
(%)

HIGH
LOW
Regional
Hectares**

%
of
Requested
Hectares
MOST
LIKELY
IMPACT
VALUE
not
available
not
available
Page
53
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
Page
54
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
topography
 
Percent
karst
topography
is
the
proportion
of
the
land
area
in
a
nomination
that
is
characterized
by
karst
formations.
In
these
areas,
the
groundwater
can
easily
become
contaminated
by
pesticides
or
their
residues.
Regulations
are
often
in
place
to
control
the
use
of
pesticide
of
concern.
Dade
County,
Florida,
has
a
ban
on
the
use
of
1,3D
due
to
its
karst
topography.
17.
(%)
100
ft
Buffer
Zones
 
Percentage
of
the
acreage
of
a
field
where
certain
alternatives
to
methyl
bromide
cannot
be
used
due
the
requirement
that
a
100
foot
buffer
be
maintained
between
the
application
site
and
any
inhabited
structure.
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
example,
the
key
pest
in
Michigan
peppers,
Phytophthora
spp.
infests
approximately
30%
of
the
vegetable
growing
area.
In
southern
states
the
key
pest
in
peppers
is
nutsedge.
19.
Regulatory
Issues
(%)
­
Regulatory
issues
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
their
use.
20.
Unsuitable
Terrain
(%)
 
Unsuitable
terrain
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance)
or
terrain
configuration,
such
as
hilly
terrain.
Where
the
use
of
alternatives
poses
application
and
coverage
problems.
21.
Cold
Soil
Temperatures
 
Cold
soil
temperatures
is
the
proportion
of
the
requested
acreage
where
soil
temperatures
remain
too
low
to
enable
the
use
of
methyl
bromide
alternatives
and
still
have
sufficient
time
to
produce
the
normal
(
one
or
two)
number
of
crops
per
season
or
to
allow
harvest
sufficiently
early
to
obtain
the
high
prices
prevailing
in
the
local
market
at
the
beginning
of
the
season.
22.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
soil
impacts,
temperature,
etc.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
For
example,
if
50%
of
the
requested
area
had
moderate
to
severe
key
pest
pressure
and
50%
of
the
requested
area
had
karst
topography,
then
75%
of
the
area
was
assumed
to
require
methyl
bromide
rather
than
the
alternative.
This
was
calculated
as
follows:
50%
affected
by
key
pests
and
an
additional
25%
(
50%
of
50%)
affected
by
karst
topography.
23.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
24.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2006
or
the
historic
average
use
rate.
25.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
26.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
27.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
28.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
29.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
30.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
31.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
Page
55
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
56
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
57
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
