USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
1
NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
STRAWBERRIES
GROWN
FOR
FRUIT
IN
OPEN
FIELDS
ON
PLASTIC
TARPS
DOCUMENT
NUMBER
CUN
2003/
059,
USc6N11
DATE
August
12,
2004
TABLE
1.
REGION,
KEY
PESTS,
AND
SPECIFIC
REASON
FOR
METHYL
BROMIDE
IN
ORNAMENTALS
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
California
Diseases:
Black
root
rot
(
Rhizoctinia
and
Pythium
spp.),
crown
rot
(
Phytophthora
cactorum),
Nematodes:
root
knot
nematode
(
Meloidogyne
spp.)
Sting
nematode
(
Belonolaimus
spp.)
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
purple
nutsedge
(
Cyperus
rotundus),
ryegrass,
and
winter
annual
weeds.
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
California,
specifically
in
areas
where
hilly
terrain
would
provide
less
efficacy
from
the
alternatives.
Uses
of
alternatives
are
limited
by
regulatory
restrictions
such
as
the
township
caps
on
the
amount
of
1,3­
dichloropropene
that
can
be
used.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
57:
43
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
196
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

Eastern
U.
S.
Diseases:
Black
Root
Rot
(
Pythium,
Rhizoctonia),
Crown
rot
(
Phytopthora
cactorum),
Nematodes:
Root
knot
nematode
(
Meloidogyne
spp.)
Weeds:
Yellow
nutsedge
(
Cyperus
escultentus),
Purple
nutsedge
(
Cyperus
rotundus)
Ryegrass
(
Lolium
spp.)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
Eastern
United
States.
In
addition,
buffer
zones
associated
with
the
use
of
alternatives
prevents
their
use
in
some
situations.
Related
dosage
rates
of
151
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

Florida
Diseases:
Phytophthora,
Crown
Rot
(
P.
citricola,
P.
cactorum)

Nematodes:
Sting
(
Belonolaimus
longicaudatus),
Root­
knot
(
Meloidogyne
spp.)

Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
Purple
nutsedge
(
Cyperus
rotundus),
Carolina
Geranium
(
G.
carolinianum),
Cutleaf
Evening
Primrose
(
Onoethera
laciniata)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
Florida.
In
addition,
the
use
of
alternatives
are
limited
in
some
areas
because
the
soil
overlays
a
vulnerable
water
table
(
karst
topography).
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
185
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
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
2,187,535
1,918,400
The
amount
of
methyl
bromide
nominated
for
California
was
reduced
for
2006
because
of
increased
use
of
alternatives.
The
estimates
of
key
pest
pressure
in
Florida
and
eastern
U.
S.
were
adjusted
upwards
based
on
new
survey
data.
The
U.
S.
imposed
a
reduction
in
use
rate
on
California
and
Florida.
*
2005
Nomination
includes
2005
Supplemental
Requested
nomination
amount.

FIGURE
1.
U.
S.
TOTAL,
REQUESTED,
AND
NOMINATED
HECTARES
OF
STRAWBERRY
FRUIT
0
5000
10000
15000
20000
25000
Strawberry
Fruit
Total
Requested
by
applicants
Nominated
by
U.
S.

Footnote:
Total
hectares,
based
on
United
States
Department
of
Agriculture
Statistics,
are
national
acreage
in
production
for
this
sector.
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
pounds
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,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
3
RESPONSE
TO
QUESTIONS
In
general,
there
are
a
variety
of
alternatives
to
MB
for
production
of
strawberry
fruit.
The
application
is
based
on
the
technical
grounds
that
no
alternatives
are
available
for
moderate
to
severe
pest
pressure
for
root
rot
(
e.
g.
Phytophthora)
and
nutsedge
in
certain
areas,
and
that
certain
topographies
and
regulatory
issues
prevent
the
use
of
possible
alternatives
in
several
areas.

MBTOC
considers
several
alternatives
are
technically
feasible
for
the
spectrum
of
target
pests.
This
is
recognized
in
the
CUN.
It
accepts
that
use
of
1,3­
D
and
its
mixtures
with
chloropicrin
are
presently
restricted
by
local
air
quality
regulations
and
certain
topographies.
MBTOC
considers
that
other
alternatives
(
e.
g.
Pic
EC,
metham
sodium
in
combination
with
PIC)
are
technically
suitable
in
at
least
some
areas
where
regulatory
issues,
karst
topography
or
slopes
affect
the
use
of
1,3­
D.

MBTOC
Question
1
­
Further
detail
is
requested
on
the
dosage
rates
of
MB
used
in
the
various
regions
covered
by
this
CUN,
with
particular
reference
to
scope
for
reduction
in
MB
usage
through
adoption
of
mixtures
of
MB
and
chloropicrin
containing
high
proportions
of
chloropicrin
and
use
of
tarping
of
low
MB
permeability.
Clarification
is
also
requested
on
proportion
of
the
CUN
that
can
use
strip
fumigation,
with
consequent
dosage
reductions,
and
the
proportion
of
uptake
of
strip
fumigation
affected
by
State
regulations.

U.
S.
Response
­
The
2001
and
2002
average
dosage
(
use)
rate
information
and
2006
CUE
nomination
information
for
the
regions
covered
by
this
CUN
are
presented
in
Table
3.
All
of
the
regions
in
the
U.
S.
are
using
rates
below
200
kg/
ha
of
methyl
bromide.
MBTOC
has
asked
for
the
scope
for
potential
reductions
using
higher
proportions
of
chloropicrin
and
tarping
with
low
methyl
bromide
permeable
film.
Research
on
fumigant
combinations
with
higher
concentrations
of
chloropicrin
are
being
conducted
in
several
locations
throughout
the
U.
S.
However,
to
date
these
alternative
combinations
have
not
always
been
as
effective
as
methyl
bromide.
Table
4
shows
an
evaluation
of
combination
fumigant
studies
comparing
their
yield
to
methyl
bromide.
In
those
studies
only
44%
of
the
fumigant
combinations
had
yields
equal
to
at
least
95%
of
the
methyl
bromide
treatment.
This
suggests
that
switching
to
combinations
of
fumigants
and
using
higher
levels
of
chloropicrin
may
not
provide
yields
similar
to
methyl
bromide,
in
particular
with
respect
to
the
areas
nominated
by
the
U.
S.
because
pest
pressure
is
moderate
to
severe
in
these
areas.
Low
permeability
tarping
has
not
been
widely
adopted
in
the
U.
S.
for
a
number
of
reasons.
Tarps
are
currently
used
on
93%
of
the
California
and
100%
of
the
Florida
soil
applications.
Regulations
restrict
low
permeability
film
in
California
which
accounts
for
approximately
76%
of
the
total
U.
S.
strawberry
soil
use.
Under
U.
S.
conditions
VIF
has
poor
application
characteristics:
it
must
be
unrolled
slower
to
prevent
tearing,
photodegradation
is
a
problem
when
used
for
multiple
crops,
and
there
are
problems
with
disposal
in
many
localities.
In
addition,
to
date
field
trials
testing
strip
treatments
using
equivalent
amounts
of
methyl
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
4
bromide
have
not
provided
clear
evidence
that
lower
permeability
films
reduce
emissions
relative
to
other
films.
MBTOC
asked
about
the
proportion
of
the
CUN
where
strip
treatments
are
used.
Currently
strip
treatments
are
used
in
the
Southeast
U.
S.
and
Florida
which
account
for
~
24%
of
the
U.
S.
CUN
(
see
Table
3).
The
use
of
strip
fumigation
is
limited
in
California
by
air
quality
standards
because
strip
treatments
can
lead
to
higher
rates
of
methyl
bromide
emissions.

Recent
research
in
California
has
indicated
that
strip
treatments
may
increase
overall
methyl
bromide
emissions
compared
to
equivalent
flat
fumigations.
Therefore,
while
strip
treatments
might
reduce
the
total
amount
of
methyl
bromide
used,
it
may
increase
overall
air
emissions.
The
U.
S.
is
reviewing
the
air
emissions
information
for
a
number
of
soil
fumigants
and
hopes
to
make
those
findings
available
later
this
year.
In
addition
to
the
emission
of
methyl
bromide
to
the
atmosphere,
is
the
practical
issue
of
the
reduction
in
weed
populations
on
a
whole
field
scale.
The
control
of
perennial
weed
species
in
strip
fumigation
will
allow
the
weeds
to
increase
in
the
untreated
portions
of
the
field.
While
herbicides
are
available
(
see
Table
7)
for
this
use
they
posse
additional
costs,
phytotoxicity
concerns,
and
management
challenges
for
the
growers.

TABLE
3.
METHYL
BROMIDE
2001
AND
2002
TWO
YEAR
AVERAGE
USE
INFORMATION
AND
2006
NOMINATION.
2001
&
2002
Average
2006
Nomination
Applicant
Kilograms
Hectares
Use
Rate
(
kg/
ha)
Kilograms
Hectares
Use
Rate
(
kg/
ha)

CA
Strawberry
Commission
1,601,966
8,184
196
1,452,732
7,422
196
SouthEast
Strawberry
Consortium
278,957
1,851
151
152,294
1,010
151
Florida,
FFVA
 
Strawberry
501,446
2,711
185
310,997
1,682
185
Footnote:
Information
taken
from
2006
Bromide
Usage
Numerical
Index
(
BUNI)
tables.

TABLE
4.
SUMMARY
OF
RESEARCH
RESULTS
FOR
METHYL
BROMIDE
ALTERNATIVES
ON
U.
S.
STRAWBERRY.

Alternatives
Total
Number
of
Studies
Number
of
Studies
with
Yield
at
Least
95%
of
Methyl
Bromide
Basamid
(
Dazomet)
and
combinations
27
12
Chloropicrin
and
combinations
58
36
Metam
sodium
(
Vapam)
and
combinations
73
24
Solarization
and
Combinations
22
6
Telone
(
1,3­
dichloropropene)
and
combinations
93
41
Average
Number
of
Studies
Showing
Yield
At
Least
95%
of
Methyl
Bromide
119/
273
=
44%

MBTOC
Question
2
­
The
part
of
the
CUN
relating
to
Californian
production
was
based
on
a
1X
township
cap
for
1,3­
D.
An
estimate
is
requested
for
scope
for
further
reduction
in
nominated
quantity
if
a
2X
cap
is
allowed.
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
5
U.
S.
Response
­
Out
of
environmental
concerns
regarding
the
quality
of
the
ambient
air,
California
regulates
the
amount
of
Telone
 
that
can
be
used
in
each
township
within
the
state.
Specifically,
Telone
 
has
been
found
by
the
State
of
California
to
be
a
carcinogen
and
regulations
have
been
put
in
place
to
limit
the
cumulative
lifetime
exposure
to
bystanders.
There
are
over
four
thousand
townships
(
36
square
miles
or
9,300
ha
each)
represented
in
the
California
township
assessment.
The
information
used
to
develop
the
estimate
of
area
impacted
by
township
caps
in
California
was
from
papers
by
Carpenter,
Lynch,
and
Trout,
cited
below,
supplemented
by
discussions
with
Dr.
Trout
to
ensure
that
any
recent
regulatory
changes
have
been
properly
accounted
for.

The
current
rule
in
effect
for
California
Telone
 
use
was
used
for
the
2006
U.
S.
CUE
nomination.
This
is
based
on
Telone
 
usage
being
allowed
at
the
baseline
amount
(
1X
level),
not
the
short
term
exemption
limits
(
2X).
The
California
Department
of
Pesticide
Regulations
(
Cal
DPR)
was
contacted
for
clarification
on
the
Telone
 
township
cap
question.
Cal
DPR
explained
the
use
of
Telone
 
starting
in
2005
and
beyond
would
be
based
on:
current
and
historic
use
patterns
in
each
individual
township,
future
enhancements
to
the
air
concentration
model
and
health
impact
models,
and
assumptions
on
the
use
of
adjacent
land
in
the
models.
Because
of
the
uncertainties
in
all
of
these
parameters
they
are
currently
unable
to
speculate
what
the
future
Telone
 
township
caps
will
be
in
California.
Accordingly,
we
believe
that
the
CUE
must
cover
the
level
of
MeBr
needed
to
meet
the
existing
1X
regulatory
limit.

MBTOC
Question
3
­
Application
of
some
alternatives
through
drip
irrigation
systems
may
be
less
successful
than
MB
treatment
on
steeply
sloping
ground.
As
MB
injection
equipment
can
be
used
on
slopes
at
present,
are
there
any
reasons
why
injection
equipment
cannot
also
be
used
for
alternative
fumigants,
including
1,3­
D
mixtures.

U.
S.
Response
 
Shank
injection
of
alternatives
such
as
1,3­
D
or
1,3­
D
with
chloropicrin
are
feasible
on
hilly
terrain.
However,
research
results
from
California
have
suggested
that
this
type
of
application
is
less
effective
than
when
applied
through
drip
irrigation
equipment.
The
technical
and
economic
assessment
for
the
eastern
U.
S.
and
Florida
indicted
a
14%
yield
loss
and
$
47
and
$
62
loss
per
kilogram
of
methyl
bromide
respectively
with
the
best
1,3­
D
and
chloropicrin
application
techniques.
Because
of
the
lower
efficacy,
the
California
strawberry
growers
would
need
to
use
flat
fumigation
for
effective
pest
control
which
would
require
40%
more
material
to
be
used
than
in
a
typical
drip
irrigation
application
to
the
beds.
Growers
with
weed
control
problems
would
need
to
factor
in
the
additional
cost
of
a
companion
herbicide.
In
addition,
the
township
cap
issue
would
need
to
be
evaluated
again
since
more
1,3­
D
injected
uses
a
different
township
cap
multiplier
than
1,3­
D
applied
through
drip
irrigation
equipment.

Question
4
­
The
Party
is
requested
to
supply
data
on
MB
usage
in
this
sector
for
2003
for
the
areas
for
which
a
CUE
is
sought
and
to
provide
information
on
changes
to
that
consumption
as
reflected
in
the
nomination
for
2006.
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
6
U.
S.
Response
 
Available
methyl
bromide
usage
information
is
presented
in
Table
3
above.
Unfortunately
2003
data
is
not
yet
available.
The
total
hectares
of
strawberries
for
fruit
in
the
U.
S.
were
19,486
in
2002.
Estimates
of
future
plantings
suggest
that
the
total
will
increase
to
21,900
hectares
or
3%
per
year
(
the
historical
average
increase
from
1997
to
2002.
Therefore,
while
the
U.
S.
strawberry
area
is
estimated
to
increase
by
a
total
of
13%
between
2002
and
2006
the
CUE
requested
is
20%
lower
than
the
amount
used
in
2001
and
2002.
Between
1997
and
2000
the
U.
S.
had
already
reduced
the
use
of
methyl
bromide
in
strawberries
grown
for
fruit
production
by
24%.

MBTOC
Question
5
­
For
the
part
of
the
CUN
relating
to
Florida
and
SE
USA
the
Party
is
requested
to
describe
the
technical
basis
for
the
estimate
that
moderate/
severe
nutsedge
affects
40%
and
30%
CUN
area
in
Florida
and
SE
respectively.

US
Response
­
A
critical
use
of
MB
in
this
region
is
to
control
yellow
and
purple
nutsedge.
While
it
is
generally
accepted
by
scientific
experts
that
the
incidence
of
these
weeds
in
the
southern
USA
is
very
high,
exact
figures
have
been
difficult
to
obtain.
The
U.
S.
estimate
of
moderate
to
severe
nutsedge
distribution
is
estimated
to
be
between
30
to
40%
of
the
area
for
both
Florida
and
the
eastern
U.
S.

Earlier
this
year,
Dr.
Stanley
Culpepper
of
the
University
of
Georgia
submitted
to
EPA
the
results
of
a
survey
intended
to
characterize
the
incidence
of
nutsedge
in
vegetable
operations.
In
this
survey,
extension
agents
in
34
Georgia
vegetable
producing
counties
were
polled
to
better
understand
the
level
of
nutsedge
infestation
in
eggplants
and
peppers,
among
other
vegetable
crops.
Their
responses
are
based
on
their
extensive
interactions
with
vegetable
growers
in
their
jurisdictions.
The
portion
of
the
survey
data
related
to
eggplants
and
peppers,
used
as
a
surrogate
for
strawberries,
is
summarized
below
(
see
Table
5
&
6).

TABLE
5.
PERCENT
CURRENT
NUTSEDGE
INFESTATION
IN
GEORGIA
COUNTIES
WHILE
METHYL
BROMIDE
IS
AVAILABLE
(
CULPEPPER,
2003).*

Crop
No
Infestation
Light
Infestation
Moderate
Infestation
Severe
Infestation
Pepper
1.3
18.9
65.6
14.2
Eggplant
1.0
40.6
39.0
19.4
*
Footnote:
No
infestation
=
no
nutsedge
infesting
production
area.
Light
infestation
=
<
5
nutsedge
plants
per
square
yard.
Moderate
infestation
=
5
to
30
nutsedge
plants
per
square
yard.
Severe
infestations
=
>
30
nutsedge
plants
per
square
yard.
In
the
BUNI
"
High
Key
Pest
Distribution"
was
calculated
by
added
the
moderate
plus
severe
infestation.
Low
Key
Pest
Distribution
was
calculated
by
adding
the
severe
infestation
plus
one
half
the
moderate
infestation.

TABLE
6.
PERCENT
ANTICIPATED
NUTSEDGE
INFESTATION
THE
YEAR
AFTER
THE
INABILITY
TO
USE
METHYL
BROMIDE
(
CULPEPPER,
2003).
*

Crop
No
Infestation
Light
Infestation
Moderate
Infestation
Severe
Infestation
Pepper
0.0
9.1
31.6
59.3
Eggplant
0.2
11.9
50.3
37.6
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
7
*
Footnote:
No
infestation
=
no
nutsedge
infesting
production
area.
Light
infestation
=
<
5
nutsedge
plants
per
square
yard.
Moderate
infestation
=
5
to
30
nutsedge
plants
per
square
yard.
Severe
infestations
=
>
30
nutsedge
plants
per
square
yard.
In
the
BUNI
"
High
Key
Pest
Distribution"
was
calculated
by
added
the
moderate
plus
severe
infestation.
Low
Key
Pest
Distribution
was
calculated
by
adding
the
severe
infestation
plus
one
half
the
moderate
infestation.

While
this
survey
focused
on
Georgia,
the
US
believes
it
is
reasonable
to
expect
that
the
levels
of
nutsedge
infestations
reported
for
these
crops
is
likely
to
be
representative
of
other
areas
of
the
southern
USA.

MBTOC
Question
6
­
In
Florida,
according
to
the
CUN,
karst
topography
prevents
use
of
1,3­
D
on
40%
of
the
MB­
using
area.
The
Party
is
requested
to
describe
the
technical
basis
of
this
estimate
or
provide
survey
data
to
substantiate
this
area
is
impacted
and
to
clarify
the
actual
proportion
of
current
strawberry
crop
CUN
that
cannot
use
1,3­
D
due
to
restrictions
relating
to
karst
topography.
Further
detail
is
sought
why
other
effective
alternatives
(
e.
g.
Pic
formulations,
metham
sodium
in
combination
with
Pic),
assisted
by
specific
herbicides
if
necessary,
cannot
be
used
to
manage
pests
in
these
areas.
Are
there
barriers
to
adoption
of
the
combinations,
with
and
without
herbicides?

US
Response
 
The
estimates
of
the
area
impacted
by
karst
geology
in
Florida,
restricting
the
use
of
1,3­
D,
were
developed
and
mapped
by
the
Florida
Department
of
Agriculture
(
1984).
The
estimates
of
karst
geology
for
Georgia
and
the
southeast
U.
S.
were
developed
from
applicant
and
university
survey
information.
In
addition
see
the
Reregistration
Eligibility
Decision
(
RED)
for
1,3­
D
(
U.
S.
EPA,
1998).
A
map
of
the
karst
geology
in
the
U.
S.
is
available
online
at
http://
www2.
nature.
nps.
gov/
nckri/
map/
maps/
engineering_
aspects/
davies_
map_
PDF.
pdf
.
The
proportion
of
the
current
Florida
strawberry
crop
that
cannot
use
1,3­
D
because
of
karst
geology
is
40%
(
see
BUNI,
2006).

The
comparative
performance
of
additional
alternatives
such
as
1,3­
D
plus
chloropicrin,
metam
sodium
with
chloropicrin
are
presented
below
in
Table
7.
Based
on
these
studies
under
moderate
to
severe
pest
pressure
the
alternatives
would
lead
to
an
overall
yield
loss
of
25%.
Chloropicrin
alone
was
not
specifically
evaluated
because
it
does
not
provide
adequate
control
of
nematodes
or
weeds.
Table
8
below
lists
the
herbicides
currently
registered
in
the
U.
S.
for
strawberries.
Of
the
registered
herbicides
only
s­
metolachlor
will
provide
suppression
of
yellow
nutsedge,
but
will
provide
no
control
of
purple
nutsedge
at
current
label
rates.
One
of
the
key
barriers
to
adoption
of
a
fumigant
and
herbicide
combination
is
the
lack
of
selective
herbicides
for
strawberry
weed
control.

TABLE
7
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
8
1,3­
Dichloropropene/
Chloropicrin
Weeds,
nematodes
and
diseases
1%
gain
to
14%
loss
14.4%
(
Shaw
and
Larson,
1999)
Chloropicrin/
Metam
sodium
Multiple
pests
6.6­
47%
27%
Locascio,
1999
Metam
sodium
Weeds,
nematodes
and
diseases
16%­
29.8%
29.8%
(
Shaw
and
Larson,
1999)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
25%

TABLE
8:
HERBICIDES
LABELED
AND
IR­
4
DESIGNATED
IN
THE
US
TO
CONTROL
NUTSEDGE
IN
STRAWBERRIES
HERBICIDE
REGISTERED
MAJOR
COMMENTS
Glyphosate
YES
Non­
selective,
will
not
control
nutsedge
in
the
plant
rows,
no
residual
control
S­
metolachlor
YES
24(
c)
Florida.
&
California,
suppression
of
yellow
nutsedge
at
label
rates,
does
not
control
purple
nutsedge,
high
water
solubility,
low
Koc
Paraquat
YES
Non­
selective,
will
not
control
nutsedge
in
the
plant
rows,
no
residual
control
Terbacil
YES
Only
suppresses
nutsedge,
crop
rotation
restrictions,
Organic
Matter
restrictions,
not
for
use
in
Calf.,
used
in
Canada
Acifluorfen
NO*
Potential
injury
in
strawberry,
yellow
nutsedge
control
only
Halosulfuron­
methyl
NO
Potential
crop
injury,
crop
rotation
restrictions,
variable
cultivar
tolerances
Rimsulfuron
NO
Only
suppresses
nutsedge,
crop
rotation
restrictions
Thiazopyr
NO*
"
Nutsedge"
suppression,
can
be
used
in
low
Organic
Matter
soils
Footnote:
*
IR­
4
listed
chemical
MBTOC
Question
7
­
In
SE
USA,
in
the
area
growing
strawberries
according
to
the
CUN,
buffer
zones
restrict
use
of
1,3­
D
on
90%
of
CUN
area.
The
Party
is
requested
to
describe
the
technical
basis
of
this
estimate
or
provide
survey
data
to
substantiate
this
area
is
impacted
and
to
clarify
the
actual
proportion
of
current
strawberry
crop
CUN
that
cannot
use
1,3­
D
due
to
these
restrictions.
Further
detail
is
sought
why
other
effective
alternatives
(
e.
g.
Pic
formulations,
metham
sodium/
Pic,
dazomet/
Pic),
assisted
by
specific
herbicides
if
necessary
cannot
be
used
to
manage
pests
in
these
areas.

US
Response
 
The
U.
S.
estimates
of
the
area
impacted
by
100
foot
(
30.5
m)
buffer
zones
are
40%
for
the
eastern
U.
S.
and
1%
for
Florida.
The
2006
CUN
request
used
an
estimate
of
90%
regulatory
impacts
in
the
eastern
U.
S.
because
the
regulations
required
a
300
foot
(
91.4
m)
buffer
which
has
since
been
reduced
to
100
feet
on
the
alternative
1,3­
dichloropropene.
The
current
estimates
used
information
from
applicants
and
alternatives
manufacturers
including:
average
field
size,
the
density
of
habitable
structures
near
strawberry
fields,
population
distributions,
and
surveys
of
extension
agents.
That
information
was
used
to
make
a
professional
judgment
on
the
impact
of
buffers.
For
example,
the
eastern
U.
S.
has
many
small
pick­
your­
own
strawberry
farms
(
less
than
4
hectares)
where
the
impact
of
a
100
foot
buffer
is
more
pronounced
than
on
the
larger
farms
in
California
or
Florida.
Because
of
the
significant
impact
that
these
estimates
have
on
the
overall
request
for
methyl
bromide,
the
U.
S.
EPA
is
evaluating
additional
methods
to
further
substantiate
and
quantify
the
impacts
of
buffer
zones.

One
of
the
key
barriers
to
adoption
of
a
fumigant
and
herbicide
combination
(
using
fumigants
such
as
chloropicrin,
metam
sodium
with
chloropicrin)
is
the
lack
of
selective
herbicides
for
USA,
Strawberry
Fruit
Grown
in
Open
Fields,
Response
to
June
2004
Questions
Page
9
strawberry
weed
control.
Table
8
above
lists
the
herbicides
currently
registered
in
the
U.
S.
for
strawberries.
Of
the
registered
herbicides
only
s­
metolachlor
will
provide
suppression
of
yellow
nutsedge,
but
will
provide
no
control
of
purple
nutsedge
at
current
label
rates.
An
additional
constraint
is
that
under
moderate
to
severe
pest
pressure
there
is
an
average
of
25%
yield
loss
with
the
alternatives
(
Table
7).

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

Carpenter,
Janet,
Lori
Lynch
and
Tom
Trout.
2001.
Township
Limits
on
1,3­
DC
will
Impact
Adjustment
to
Methyl
bromide
Phase­
out.
California
Agriculture,
Volume
55,
Number
3.

Carpenter,
Janet
and
Lori
Lynch.
1999.
Impact
of
1,3­
D
Restrictions
in
California
after
a
Ban
on
Methyl
Bromide.
Presentation
at
the
1999
Annual
International
Conference
of
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Culpepper,
S.
2004.
Infestations
of
Nutsedge
in
Georgia
Vegetable
Crops.
Supporting
survey
information.
University
of
Georgia
supporting
survey
information.
Email
of
January
23,
2004.

Florida
Department
of
Agriculture.
May
1984.
Summary
of
soil
hydrogeological
and
other
environmental
conditions
in
the
state
of
Florida
related
to
the
use
of
pesticides.

Karst
Gelogy
Map.
2004.
Available
online
at
http://
www2.
nature.
nps.
gov/
nckri/
map/
maps/
engineering_
aspects/
davies_
map_
PDF.
pdf
Locascio
S.
J.,
Olson
S.
M.,
Chase
C.
A.,
Sinclair
T.
R.,
Dickson
D.
W.,
Mitchell
D.
J.
and
Chellemi
D.
O.
1999.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Shaw
V.
S.,
and
Larson
K.
D.,
1999.
A
meta­
analysis
of
Strawberry
Yield
Response
to
Pre­
plant
Soil
Fumigation
with
Combinations
of
Methyl
Bromide­
chloropicrin
and
Four
Alternative
Systems.
HortScience
34:
839­
845.

U.
S.
EPA.
1998.
Reregistration
Eligibility
Decision
(
RED),
1,3­
Dichlorpropene
http://
www.
epa.
gov/
REDs/
0328red.
pdf
