USA,
Strawberry
Nurseries,
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
on
Strawberries
Nurseries
Grown
in
Open
Fields
or
in
Protected
Environments
DOCUMENT
NUMBER
CUN
2003/
060,
Usc6N12
DATE
August
12,
2004
CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
SPECIFIC
REASON
FOR
METHYL
BROMIDE
IN
STRAWBERRY
NURSERIES
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Southeastern
US
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
Purple
nutsedge
(
Cyperus
rotundus)

Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.);
Crown
rot
(
Phytophthora
cactorum);
root­
knot
nematodes
(
Meloidogyne
spp.)
None
of
the
available
alternatives
provide
an
acceptable
level
of
control
of
nutsedge;
the
affected
states'
regulatory
requirements
to
meet
certification
standards
which
amount
to
virtually
complete
control
of
fungal
diseases
and
nematodes,
is
only
attainable
with
methyl
bromide
California
Diseases:
Phytophthora
Crown
and
Root
Rots
(
Phytophthora
spp.);
Red
Stele
(
Phytophthora
fragariae);
Verticillium
Wilt
(
Verticillium
dahliae);
and
possibly
others
Nematodes:
Root­
knot
(
Meloidogyne
spp.);
sting
(
Belonolaimus
spp.);
dagger
(
Xiphinema
spp.);
lesion
(
Pratylenchus
spp.);
foliar
(
Aphelenchoides
spp.);
needle
(
Longidorus
spp.);
stem
(
Ditylenchus
spp.)

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

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

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
54,988
56,291
We
estimated
a
more
representative
average
historical
use
for
2006
than
2005.
Research
amount
included
in
increase.
USA,
Strawberry
Nurseries,
Response
to
June
2004
Questions
Page
2
FIGURE
1.
U.
S.
REQUESTED,
QUARANTINE
AND
PRESHIPMENT
AND
NOMINATED
HECTARES
OF
STRAWBERRY
NURSERIES
0
200
400
600
800
1000
1200
1400
1600
1800
2000
Strawberry
Nurseries
Requested
by
applicants
QPS
Nominated
by
U.
S.

Footnote:
The
requested
hectares
are
sum
total
of
all
acreages
in
the
CUE
applications.
QPS
=
number
of
hectares
qualifying
as
quarantine
and
pre­
shipment.
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.

RESPONSE
TO
QUESTIONS
MBTOC
Comment
­
A
large
amount
(
88%)
of
MB
use
has
been
exempted
to
meet
certification
requirements
for
QPS
as
determined
under
U.
S.
regulatory
controls.
Technical
data
provided
with
the
nomination
indicates
that
metam­
sodium
and
chloropicrin
are
providing
effective
disease
control
for
runner
production,
but
1,3­
D/
Pic
or
1,3­
D
alone
followed
by
metam­
sodium,
are
reported
not
to
be
fully
effective."
USA,
Strawberry
Nurseries,
Response
to
June
2004
Questions
Page
3
MBTOC
Question
1
­
The
Party
is
requested
to
clarify
how
that
part
of
the
nomination
that
is
not
classified
under
the
QPS
exemption
differs
from
that
categorized
as
QPS.
In
particular
information
is
sought
on
whether
it
is
required
to
meet
the
same
performance
standards
as
that
categorized
as
QPS.

US
Response
­
The
same
quality
standards
apply
to
the
non­
QPS
nursery
stock
as
the
QPS
plants,
since
in­
county
or
in­
state
fruit
grower
customers
would
not
want
to
purchase
lesser
quality
plants
and
would
be
expected
to
obtain
high
quality
plants
elsewhere
in
the
country
to
ensure
they
were
the
most
robust
specimens.
This
is
based
in
part
on
available
data
that
seems
to
indicate
that
runner
plants
produced
in
fields
where
lower
yields
and/
or
smaller
plants
were
produced
as
a
result
of
using
less
effective
alternatives
results
in
carryover
losses
at
the
fruit
production
level.
Additionally,
if
one
or
more
growers
in
the
same
general
production
area
were
trying
to
produce
two
quality
levels
of
plants
they
would
run
the
risk
of
having
the
mobile
pests
moving
from
the
lesser
quality
plants
to
the
high
quality
plants
and
possibly
lose
their
certification
status
on
the
high
quality
plants.

MBTOC
Question
2
­
Clarification
is
requested
on
why
metam
sodium
and
chloropicrin
as
an
alternative
cannot
be
adopted
more
widely.
The
Party
is
requested
to
supply
data
to
support
the
claimed
lack
of
effectiveness
of
1,3­
D/
Pic
to
the
necessary
depth.

US
Response
­
The
data
summarized
in
the
nomination
document,
which
appear
to
indicate
that
metam­
sodium
and
chloropicrin
are
suitable
alternatives,
are
derived
from
tests
which
all
lacked
a
full
spectrum
of
the
potential
pest
types
(
weeds,
nematodes,
diseases)
and
generally
did
not
appear
to
have
adequate
and
uniform
levels
of
those
pests
that
were
present.
This
weakness
appears
to
be
true
for
all
or
most
of
the
available
studies
designed
for
strawberry
nursery
uses,
as
well
as
those
designed
for
fruit
production
situations.
Accordingly,
the
results
from
such
studies
will
give
a
number
of
false­
positives
for
certain
alternatives
simply
because
they
were
able
to
provide
adequate
control
when
limited
pest
species
were
present,
or
when
non­
uniform
or
low
pest
levels
were
present.
Numerous
studies
exist
for
strawberries
and
other
crops
that
indicate
the
strengths
and
weaknesses
of
the
various
alternatives
under
different
pest
control
situations.
Collectively
these
data
have
value
in
providing
an
overview
of
the
strengths
and
weaknesses
of
each
potential
alternative.
The
U.
S.
has
not
been
able
to
find
a
comprehensive
analysis
of
this
nature.
Such
an
analysis
would
be
extremely
time
consuming,
but
would
be
the
only
way
to
validate
the
comparative
performance
opinions
of
the
available
researchers.

Although
fumigation
in
the
Southeastern
States
is
generally
accomplished
in
the
fall,
delays
associated
with
a
late
harvest
of
the
preceding
crop
and/
or
cold
weather
often
necessitate
that
fumigation
be
conducted
in
March
and
April,
which
is
immediately
prior
to
planting.
A
similar
situation
exists
in
California.
Use
of
the
alternative
metam­
sodium
will
result
in
an
additional
1­
2
week
plant
back
delay
when
applied
alone
and
longer
planting
delays
when
applied
sequentially
before/
after
another
fumigant
(
e.
g.,
Telone,
chloropicrin).
Southeastern
States
have
historically
experienced
10­
15%
plant
yield
(
runner)
losses
as
a
result
of
a
1­
week
planting
delay.
Therefore
even
greater
losses
are
possible
with
the
longer
plant
back
delays
associated
with
metam­
sodium
use,
even
if
metam­
sodium
were
capable
of
providing
levels
of
pest
control
USA,
Strawberry
Nurseries,
Response
to
June
2004
Questions
Page
4
comparable
to
methyl
bromide
at
the
required
soil
depths.

Another
consideration
is
that
certain
studies
indicate
that
chloropicrin
can
increase
nutsedge
weed
populations
rather
than
control
them.
Nutsedge
is
the
principal
weed
pest
in
the
Southeastern
States
and
it
is
projected
to
become
a
problem
in
California
nurseries
when
methyl
bromide
is
no
longer
available.

Long
term
performance
of
these
alternatives
is
still
not
available.
The
applicants
in
California
stated
that
they
intend
to
look
for
additional
studies,
which
better,
defined
the
comparative
efficacy
and/
or
performance
of
chloropicrin,
metam­
sodium,
and
other
alternatives
at
the
deeper
soil
depths.
They
intend
to
submit
such
studies
with
their
next
application.

MBTOC
Question
3
­
The
rate
of
MB
used
in
the
Southeastern
States
in
MB/
Pic
mixtures
is
very
high
(
413
kg/
ha)
by
world
standards.
Clarification
is
sought
as
to
why
such
a
high
rate
is
required
and
what
scope
there
is
for
reduction
to
more
normal
levels,
perhaps
combined
with
emission
reduction
technologies
such
as
barrier
film
use.
[
Note:
Originally
this
comment
was
linked
with
Michigan
growers;
subsequently
MBTOC
was
contacted
and
it
was
learned
that
this
comment
pertained
to
the
SE
States,
rather
than
Michigan]

US
Response
­
The
methyl
bromide
rates
currently
used
in
the
Southeastern
States
(
413
kg/
ha)
are
about
57
percent
higher
than
those
currently
used
in
California
(
263
kg/
ha).
The
applicant
has
stated
that
the
higher
use
rate
is
required
because
of
their
need
to
control
nutsedge.
This
weed
is
currently
not
present
in
California
nurseries.
Their
experiences
have
shown
that
in
many
cases
rates
as
high
as
487
kg/
ha
of
methyl
bromide
have
been
needed
to
control
nutsedge.
Previously,
the
Southeastern
states
indicated
that
they
intend
to
evaluate
the
performance
of
methyl
bromide
rates
as
low
as
310
kg/
ha,
so
that
growers
could
conceivably
switch
from
the
67:
33
to
the
50:
50
formulation.
However,
until
these
performances
are
fully
evaluated,
it
would
not
be
possible
to
lower
methyl
bromide
rates
and
ensure
efficacy.
In
any
case,
all
methyl
bromide
use
is
done
under
tarps,
and
emissions
and
use
have
been
controlled
to
the
extent
feasible.

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