USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
1
NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Request
to
Reconsider
the
Amount
Recommended
for
2006
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Orchard
Replant
DOCUMENT
NUMBER
CUN
2003/
056,
Uso6N7
DATE
August
12,
2004
TABLE
1.
REGION,
KEY
PESTS,
AND
SPECIFIC
REASON
FOR
METHYL
BROMIDE
IN
ORCHARD
REPLANT
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
Replant
problem
is
a
disease
complex
comprised
of
interactions
between
various
pathogens
and
environmental
factors.
Nematodes
(
Primary
pests):
Meloidogyne
(
root
knot);
Criconemella
(
ring);
Xiphinema
(
dagger);
Pratylenchus
(
root
lesion);
and
Tylenchulus
(
citrus)
Pathogens:
Armellaria,
Phytophthora,
and
various
fungi,
depending
on
orchard
location
and
conditions
that
are
thought
to
contribute
to
orchard
replant
disorder.
Insect:
Pollyphylla
decemlineata
(
tenlined
June
beetle)
Some
alternatives,
such
as
1,3­
D,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
where
there
are
no
legal
restriction
and
in
light,
sandy
loam
soils,
and
where
there
is
acceptable
soil
moisture.
In
other
situations,
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
is
the
only
compound
that
can
effectively
target
root
remnants
from
previous
orchard
trees.

California
Walnut
Commission
(
Central
Valley
and
coastal
valleys)
Replant
problem
caused
by
interactions
of
pests
and
environment
primarily
Nematodes:
(
in
~
85%
of
orchards)
Pratylenchus
vulnus,
Mesocriconema
xenoplax,
Meloidogyne
spp.
Township
caps
and
unacceptable
soil
moisture
(>
12%
at
over
1
meter
depths
in
medium
and
heavy
soils)
limit
1,3­
D
use
(
the
best
alternative)
to
approximately
only
30%
of
orchard
land.

Almond
Hullers
and
Processors
Association
(
California)
Replant
problem
is
a
disease
complex
comprising
an
interaction
of
pests
(
primarily
nematodes)
and
environmental
factors.
Nematodes:
Meloidogyne
incognita
(
root
knot),
Pratylenchus
vulnus
(
root
lesion),
Mesocriconema
xenoplax
(
ring),
Xiphinema
americanum
(
dagger)
Many
new
almond
orchards
were
planted
between
1979
and
1982.
These
orchards
will
soon
need
to
be
replanted
as
the
life
of
the
orchard
is
reaching
its
maximum
(
25­
30
years).
Because
no
virgin
land
is
available,
replant
problems
will
occur
in
these
locations.
Because
of
township
caps
and
water
moisture
issues,
the
best
alternative,
1,3­
D
is
not
available
or
effective
as
a
replacement.
Therefore,
MB
is
considered
critical
for
this
industry.
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
2
AMOUNT
OF
METHYL
BROMIDE
NOMINATED
TABLE
2.
AMOUNT
OF
METHYL
BROMIDE
NOMINATED
BY
THE
U.
S.
IN
2005
AND
2006.
2005
(
KG)
2006
(
KG)
DESCRIPTION
OF
DIFFERENCES
BETWEEN
YEARS
706,176
827,994
New
data
was
used
on
total
combined
impacts.
CA
anticipates
higher
use
for
the
next
few
years
due
to
cyclical
replacement
of
orchard
crops.
Reduction
in
use
rate
imposed.

FIGURE
1.
U.
S.
TOTAL,
REQUESTED,
AND
NOMINATED
HECTARES
OF
ORCHARD
REPLANT
0
1000
2000
3000
4000
5000
6000
7000
8000
9000
Orchard
Replant
Total
Requested
by
applicants
Nominated
by
U.
S.

Footnote:
Total
hectares,
based
on
United
States
Department
of
Agriculture
Statistics,
are
U.
S.
hectares
in
production
for
this
sector
in
2002.
The
requested
hectares
are
sum
total
of
all
areas
in
the
CUE
applications.
The
nominated
hectares
reflect
reductions
of
the
requested
hectares
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.
Total
kilograms
of
methyl
bromide
nominated
by
the
United
States
government
for
this
sector
are
based
on
these
nominated
hectares.
See
the
accompanying
spreadsheet
2006
Bromide
Usage
Numerical
Index
or
"
BUNI"
(
Filename:
USA
2006
BUNI
 
Refined
Nomination
Package.
xls)
for
more
detailed
information
on
how
the
nominated
amount
was
determined.

ECONOMIC
IMPACTS
The
economic
impacts
were
assessed
using
four
economic
parameters:
1.
loss
per
hectare,
2.
loss
per
kilogram
of
methyl
bromide,
3.
loss
as
a
percentage
of
gross
revenue,
and
4.
loss
as
a
percentage
of
net
revenue.
This
assessment
compares
methyl
bromide
to
the
best
available
alternative
to
determine
the
economic
feasibility
of
using
that
alternative.
A
range
of
alternatives
were
examined
to
determine
the
best
available
alternative
scenario
taking
into
account
yield
loss
estimates
and
cost
increase
estimates.
The
result
of
the
economic
impact
analysis
is
presented
in
the
BUNI
analysis.
In
this
sector,
no
alternatives
were
found
to
be
both
technically
and
economically
feasible
for
the
particular
circumstances
nominated
for
the
CUE.
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
3
REQUEST
TO
RECONSIDER
ORCHARD
REPLANT
SITUATION
Purpose.
The
United
States
requests
that
MBTOC
reconsider
the
amount
of
methyl
bromide
(
MB)
it
recommended
for
the
Orchard
Replant
sector
for
2006.
We
believe
that
there
are
circumstances
that
justify
an
allocation
of
the
nominated
amount
(
839.755
metric
tonnes)
of
MB.
Indeed,
MBTOC
itself
notes
that
the
alternatives
that
may
be
available
in
this
area
have
not
been
well
proven.
Although
we
are
committed
to
further
research
in
this
area
(
please
see
"
Research
 
Alternative
Strategies"
section
below),
we
believe
that
nominating
countries,
and
their
respective
farmers,
should
not
have
to
bear
the
substantial
risk
of
orchard
failure
until
suggested
alternatives
have
been
more
fully
tested
and
proven
to
be
effective.

Rationale.
Because
of
the
cyclic
and
long­
term
nature
of
the
replant
crops,
we
believe
that
the
use
of
MB
by
the
Orchard
Replant
sector
does
not
adhere
to
the
general
model
for
annual,
or
even
some
perennial
crops.
Almond
orchards,
for
example,
have
a
20
year,
or
longer,
production
cycle
and
replacement
of
orchards
planted
in
the
late
1970s
and
early
1980s
(
when
a
large
number
of
almond
orchards
were
established)
will
be
necessary
within
the
next
five
or
six
years.
We
believe
that
the
baseline
for
MB
use
during
the
last
five
years
is
not
representative
of
the
critical
needs
of
this
sector
since
MB
is
used
only
once
in
the
life
of
an
orchard
and
orchards
are
productive
for
20
to
40
years.
Over
25,000
hectares
of
orchards
will
have
to
be
replaced
each
year
to
maintain
current
crop
bearing
hectares,
which
is
comparable
to
the
number
of
hectares
planted
prior
to
2000
in
California
(
Tables
3
and
4).
Therefore,
comparative
use
of
MB
should
be
for
those
orchards
planted
years
ago.
Because
there
currently
does
not
appear
to
be
a
"
dropin
replacement
for
MB
for
this
sector,
it
is
likely
that
a
combination
of
chemical
and
nonchemical
strategies
will
have
to
be
used
to
successfully
manage
orchard
replant
disorder
(
McKenry,
1999).
Until
such
time
as
the
optimum
replacements
have
been
proven,
however,
we
believe
there
is
a
critical
need
for
MB
to
help
in
the
successful
establishment
of
orchard
and
vineyard
plants.

This
sector
supports
ongoing
research
to
assess
the
efficacy
of
various
disease
management
strategies,
but
now
they
must
use
a
proven
management
tool
for
new
orchards
that
will
be
productive
for
the
next
several
decades.
We
believe
that
critical
soil
and
regulatory
impacts
on
orchards
are
actually
at
the
higher
end
of
the
calculated
impact
range
of
affected
orchards,
such
that
a
greater
amount
of
MB
will
be
required
to
prevent
a
significant
economic
loss.
MBTOC
is
correct
that
the
" 
main
constraint
to
the
adoption
of
alternatives
is
the
inability
to
identify
definitively
what
is
causing
replant
disease
and
implement
appropriate
response"
and
in
the
near
future
current
research
should
help
elucidate
the
complex
nature
of
orchard
replant
disorder.
MBTOC
is
also
correct
that
" 
the
industry
is
aware
of
technically
feasible
and
available
alternatives
and
use
of
VIF
for
emission
reduction".
Unfortunately
for
orchard
producers,
this
disorder
manifests
itself
differentially,
depending
on
the
orchard
location,
type
of
crop,
type
of
soil,
and
even
type
of
crop
that
was
previously
planted
in
the
replant
site
(
McKenry,
1999;
Messenger
and
Braun,
2000).
Consequently,
the
short
term
ability
of
orchard
farmers
to
produce
acceptable
yields
will
be
reduced
without
MB,
a
proven
effective
management
tool,
in
situations
where
alternatives
have
not
been
effective
or
where
they
are
not
allowed.

Background.
The
U.
S.
Nomination
within
the
Orchard
Replant
sector
was
for
areas
where
alternatives
were
not
suitable,
either
because
of
legal
restrictions
or
physical
features
such
as
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
4
unacceptable
soil
moisture.
For
most
sites
of
orchard
replant
with
stone
fruit,
grapes,
walnuts,
and
almonds
in
California,
MB
is
a
critical
tool
for
establishing
healthy,
long
lived
orchards.
Only
some
of
the
orchard
sites
in
California
are
currently
able
to
effectively
use
alternative
measures
to
manage
orchard
replant
disorder,
the
disease
complex
that
is
associated
with
various
pathogens
(
primarily
nematodes,
some
fungi,
and
possibly
at
least
one
insect
species)
and
environmental
factors
such
as
soils,
moisture,
climate,
and
nutrition
(
Browne
et
al.,
2002;
McKenry,
1999).

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

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

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

1,3­
D
Alternative.
Fumigation
improves
the
growth
of
trees
in
the
beginning
stages
of
orchard
establishment
 
"
 
even
`
resistant'
rootstocks
grow
poorly
their
first
year
or
two
without
such
soil
treatments"
(
McKenry,
1999).
An
effective
pre­
plant
fumigation
should
kill
99.9%
of
nematode
pests
in
the
top
1.5
meters
of
orchard
soils,
and
should
kill
the
roots
remaining
from
the
previous
orchard
planting
(
McKenry,
1999).
If
growers
relied
solely
on
post­
planting
drip
treatments
it
would
be
difficult
to
achieve
greater
than
50­
75%
nematode
control
for
longer
than
6­
9
months
 
especially
since
no
remnant
roots
are
killed,
allowing
a
refuge
for
nematode
pests.
Pre­
plant
fumigation
also
provides
a
means
for
avoiding
repeated
post­
plant
nematicide
applications
during
the
years
following
planting;
thus
reducing
costs
and
further
pesticide
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
5
applications.
Thus,
the
importance
of
an
effective
pre­
plant
fumigation
treatment
is
critical
to
an
orchard's
survival
as
an
ongoing
commercial
operation.

Prior
to
1990,
1,3­
D
was
considered
at
least
as
good
as
MB
for
treatment
of
replant
problem
(
McKenry,
1999).
However,
due
to
environmental
and
health
concerns
(
it
is
a
B2
carcinogen
and
was
found
off
of
treatment
sites)
1,3­
D
was
banned
and
MB
became
the
predominant
treatment
for
orchard
replant.
With
the
re­
labeling
of
1,3­
D
in
the
mid­
1990s
there
were
new
restrictions
on
its
use
and
application
rate,
including
township
caps
in
California,
and
reduced
rates
that
were
considered
ineffective
for
some
severe
replant
situations
(
reduced
to
325
kg/
ha
from
427
kg/
ha).
MB,
therefore,
remains
the
standard
for
the
industry
when
establishing
nearly
all
of
California's
orchards,
except
in
the
few
with
light
soils,
with
appropriate
moisture
conditions,
where
lower
rates
of
1,3­
D
can
be
effective
(
McKenry,
1999).
[
Each
township
is
allowed
a
maximum
of
approximately
41,000
kg
per
year,
in
a
township
of
approximately
9300
ha;
at
225
kg/
ha,
180
ha
can
be
treated
with
1,3­
D
per
township.]

Many
areas
of
California
that
are
amenable
to
these
crops
have
soil
types
and
moisture
characteristics
that
prevent
alternatives
from
acting
effectively
to
successfully
manage
replant
disorder;
some
areas
are
also
subject
to
township
caps
for
1,3­
D,
the
best
alternative.
In
addition,
nearly
all
orchards,
due
to
location,
soil
type,
or
other
environmental
conditions,
are
susceptible
to
the
replant
problem,
and
therefore,
require
MB
fumigation
prior
to
orchard
replant.
Areas
with
soils
that
contain
less
than
12%
moisture
at
approximately
1.5
meters
and
can
be
sufficiently
moistened
in
the
top
30
cm,
and
are
not
restricted
in
their
use
of
1,3­
D,
may
find
1,3­
D
an
effective
alternative
to
MB.
In
other
situations
that
do
not
have
these
soil
and
moisture
characteristics,
MB
is
the
only
effective
treatment.

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

Recent
Decrease
in
Hectares
Planted
and
Treated.
The
orchard
hectares
planted
and
treated
has
decreased
in
recent
years
(
Table
3).
However,
in
order
to
maintain
the
bearing
hectares,
the
hectares
planted,
and
subsequently
treated,
will
have
to
increase,
which
is
why
the
U.
S.
requested
more
MB
than
was
used
since
2000.
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
6
TABLE
3.
HECTARES
PLANTED
IN
CALIFORNIA.

Hectares
Planted
1997
1998
1999
2000
2001
2002
Almond
14,055
17,328
11,977
8,011
5,900
3,992
Walnut
3,035
2,458
3,417
2,627
1,175
1,442
Grapes
3,049
2,964
2,028
2,394
1,635
848
Stone
Fruits*
3,397
3,902
2,780
3,281
2,649
2,330
Orchard
Hectares
Planted
23,536
26,652
20,201
16,312
11,359
8,612
Orchard
Hectares
Treated
with
MeBr
7,610
4,993
6,168
3,514
3,020
1,737
Percent
Hectares
Treated
32%
19%
31%
22%
27%
20%

*
Available
data
includes
peaches,
nectarines,
plums
and
prunes,
but
not
cherries.
Source:
California
Agricultural
Statistics
Service
and
California
Tree
Fruit
Association.

To
maintain
bearing
orchard
hectares
(
Table
4),
the
hectares
that
will
need
to
be
replaced
each
year
are
equal
to
the
bearing
hectares
divided
by
the
average
bearing
life
of
the
orchards.
Over
25,000
hectares
of
orchards
will
have
to
be
replaced
each
year
in
California
to
maintain
the
orchard
bearing
hectares,
which
is
comparable
to
the
number
of
California
orchard
hectares
planted
in
the
late
1990s.

TABLE
4.
BEARING
HECTARES,
CALIFORNIA.
Almonds
Walnuts
Grapes
Stone
Fruits
Total
Bearing
Hectares
2003,
California
214,575
86,235
139,271
104,453
544,534
Average
Bearing
Life
(
years)
22
36
19
18
Average
Replacement
per
Year
(
hectares)
9,753
2,395
7,330
5,803
25,282
Projected
Treated
Hectares
2006
486
810
433
2,132
3,860
Average
Percent
to
be
Treated
5%
34%
6%
37%
15%
Source:
California
Agricultural
Statistics
Service.

Research
 
Alternative
Strategies.
The
applicants
of
this
sector
are
supporting
research
for
the
development
of
technologies
and
strategies
to
improve
the
efficacy
of
alternatives,
such
as:
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
use
of
fallow,
chemical/
non­
chemical
combinations,
herbicides
to
kill
remnant
roots,
use
of
"
virgin"
soils
as
amendments
to
try
to
reduce
the
severity
of
replant
problem,
resistant
rootstocks
when
available,
and
irrigation
regimes
to
improve
consistency
of
metam­
sodium
distribution.

Because
this
sector
applies
MB
only
once
in
the
life
of
the
orchard,
use
of
alternatives
to
replace
MB
will
have
to
be
well
considered
in
light
of
their
long­
term
impacts
on
fruit
and
nut
production.
McKenry
(
1999)
has
hypothesized
that
there
are
four
distinct,
but
interacting,
components
to
the
replant
problem.
All
of
the
components
do
not
have
to
be
present
for
the
occurrence
of
replant
problem,
so
the
symptoms
vary
from
location
to
location.
Some
components
are
time­
dependent
and
do
not
occur
until
years
after
orchard
replant.
The
four
components
of
replant
problem
are
hypothesized:
1)
rejection
(
unknown
factors
resulting
in
failure
of
plants
to
thrive),
2)
physical
or
chemical
soil
barriers
to
root
development,
3)
presence
of
known
soil
pathogens
and
pests,
and
4)
nutrient
requirements
of
young
trees
and
vines.
McKenry
evaluated
136
regimes
that
included
various
rates
and
mixtures
of
fumigants,
herbicides,
fallow
periods,
cover
crops,
genetic
rootstocks,
tarps,
soil
treatments
(
e.
g.,
marigold
extract
drench),
fertilizers,
etc.
Clearly,
extensive
and
reliable
field
studies
on
these
perennial
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
7
crops
require
considerable
time
to
conduct,
and
until
replicated
trials
can
be
analyzed,
we
believe
that
MB
is
critical
to
establishing
healthy
orchards.

Research
is
currently
being
conducted
by
all
applicants
in
this
sector
to
find
increasingly
more
effective
ways
of
managing
orchard
replant
disorder
(
e.
g.,
Browne
et
al.,
2002;
Ferris
and
Walker,
2002;
Martin,
2003;
McKenry,
1999,
2001;
Schneider
et
al.,
1999,
2000;
Trout
et
al.,
2002).
From
1992
to
2002,
the
expenditures
on
research
have
included
$
430,000
(
California
Walnut
Commission),
$
250,000
(
California
Grape
and
Tree
Fruit
League),
and
$
86,000
(
Almond
Hullers
and
Processors
Association).
While
orchard
replant
uses
MB
only
once
in
the
orchard's
life,
the
research
being
conducted
will
help
integrate
new
methods
and
techniques
to
producing
high
quality
fruit
and
nuts,
as
well
as
reduction
of
MB
emissions.
The
substantial
commitment
to
research,
by
all
of
the
orchard
and
vineyard
crop
associations,
continues.

Conclusion.
The
Orchard
Replant
sector
has
a
critical
need
for
the
nominated
amount
of
MB
(
i.
e.,
839.755
metric
tonnes).
This
amount
takes
into
consideration
the
unique
nature
of
this
sector,
which
uses
MB
only
once
in
the
planting
of
new
orchards
and
vineyards
on
previously
planted
land.
Orchard
replant
use
of
MB
is
the
only
proven
means
of
disease
management
for
perennial,
high
value
crops
in
many
orchard
locations
in
California.
Because
of
the
long­
term
and
cyclical
nature
of
crops
comprising
this
sector
(
typically
20
to
40
years),
the
general
rule
of
a
five­
year
baseline
of
use
does
not
seem
applicable.
Numerous
orchards
planted
in
the
late
1970s
and
early
1980s
will
have
to
be
replanted.
Without
a
proven
alternative
to
MB
to
manage
orchard
replant
disorder,
replanted
orchards
in
the
next
few
years
still
have
a
critical
need
for
MB.
Ongoing
research
continues
to
examine
combinations
of
chemicals
and
cultural
methods
to
replace
MB,
but
until
valid
conclusions
are
reached,
growers
are
in
critical
need
of
MB.

REFERENCES
2006
Bromide
Usage
Numerical
Index
(
BUNI)
 
Refined
Nomination
Package.
Attached
to
U.
S.
Response
to
Questions
as
an
Excel
Spreadsheet.

Browne,
G.,
Trout,
T.
and
Bulluck,
R.
2002.
Cultural
control
and
etiology
of
replant
disease
of
Prunus
spp.
University
of
California,
Sustainable
Agriculture
Research
and
Education
Program.
http://
www.
sarep.
ucdavis.
edu/
grants/
reports/
mebr/
browne/
browne.
html
Ferris,
H.
and
Walker,
M.
A.
2002.
Development
of
grape
rootstocks
with
broad
and
durable
nematode
resistance.
University
of
California
Sustainable
Agriculture
Research
and
Education
Program.
Final
Report
(
updated
May,
2003).
http://
www.
sarep.
ucdavis.
edu/
Grants/
Reports/
MeBr/
Ferris/
ferris.
html
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.
http://
arjournals.
annualreviews.
org/
doi/
pdf/
10.1146/
annurev.
phyto.
41.052002.095514
USA,
Request
to
Reconsider
Orchard
Replant
Recommendation
Amount
Page
8
McKenry,
M.
2001.
Performance
of
metam
sodium
drenched
to
six
different
replant
sites.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2001).
http://
mbao.
org/

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

Messinger,
B.
and
Braun,
A.
2000
(
Sept.).
Alternatives
to
MB
for
the
control
of
soil­
borne
diseases
and
pests
in
California.
Pest
Management
Analysis
and
Planning
Program.
California
Department
of
Pesticide
Regulations.
http://
www.
cdpr.
ca.
gov/
docs/
dprdocs/
methbrom/
alt­
anal/
sept2000.
pdf
Schneider,
S.,
Ajwa,
H.,
Trout.
T.,
and
Sims,
J.
2000.
Alternatives
for
vineyard
replant
and
grapevine
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2000).
http://
mbao.
org/

Schneider,
Ajwa,
H.
Trout,
T.
and
Sims,
J.
1999.
Grape
replant
disorder
 
an
integrated
management
approach.
USDA,
Agricultural
Research
Service,
Methyl
Bromide
Alternatives.
http://
www.
ars.
usda.
gov/
is/
np/
mba/
oct99/
grape.
htm
Trout.
T.,
Ajwa,
H.,
Schneider,
S.,
Gartung,
J.
2002.
Fumigation
and
fallowing
effects
on
replant
problems
in
California
peach.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/;
http://
mbao.
org/
2002proc/
058TroutT%
20mbp­
conf02­
peach.
pdf
