UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
Under
the
Clean
Air
Act
and
the
international
treaty
to
protect
the
ozone
layer
(
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer),
the
production
and
import
of
methyl
bromide
will
be
phased
out
in
the
United
States
on
January
1,
2005.
This
application
seeks
information
to
support
a
U.
S.
request
to
produce
and
import
methyl
bromide
for
certain
critical
uses
and
circumstances
beyond
this
2005
phaseout
date.

The
information
in
this
application
will
be
used
to
review
whether
your
use
of
methyl
bromide
is
"
critical"
because
no
technically
and
economically
feasible
alternatives
are
available.
In
order
to
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available,
EPA
needs
to
compare
data
(
yields,
crop/
commodity
prices,
revenues
and
costs)
for
your
use
of
methyl
bromide
with
uses
of
alternative
pest
control
regimens.

If
you
submit
a
well
documented
application
with
sound
reasons
why
alternatives
are
not
technically
and
economically
feasible,
the
U.
S.
government
can
be
a
better
advocate
for
your
exemption
request
internationally.

OMB
Control
#
2060­
0482
WHY
IS
THIS
INFORMATION
NEEDED?
Application
for
Critical
Use
Exemption
of
Methyl
Bromide
for
Use
in
2005
in
the
United
States
Click
on
the
Instructions
tab
located
at
the
bottom
of
the
screen
for
additional
information.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
STATE
CONTACTS
HOW
DO
I
APPLY?

OMB
Control
#
2060­
0482
States
that
have
agreed
to
participate
in
the
exemption
process
are
listed
on
EPA's
website
at
www.
epa.
gov/
ozone/
mbr/
cueqa.
html
Worksheet
4.
Alternatives
­
Research
Plans
Worksheet
5.
Additional
Information
Fumigation
Cycle
Climate
Zone
Map
Worksheet
6.
Application
Summary
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Revenue
3­
D.
Alternatives
­
Other
Operating
Costs
Research
Summary
Worksheet
Example
Research
Sum
(
Summary)
Worksheet
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
2­
F.
Methyl
Bromide
­
Fixed
and
Overhead
Costs
Worksheet
3.
Alternatives
­
Feasibility
of
Alternatives
to
Methyl
Bromide
3­
A.
Alternatives
­
Technical
Feasibility
Please
contact
your
local,
state,
regional
or
national
commodity
association
and/
or
state
representative
agency
to
find
out
if
they
plan
on
submitting
an
application
on
behalf
of
your
commodity
group.

2­
B.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Revenue
1997­
2000
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Revenue
2001
2­
D.
Methyl
Bromide
Use
and
Costs
for
2001
INSTRUCTIONS
Each
worksheet
number
corresponds
to
the
tab
number
in
the
electronic
version
of
the
application.
Instructions
specific
to
each
worksheet
are
provided
at
the
top
of
each
sheet.
A
header
row
is
included
on
each
worksheet
to
include
an
application
ID
number
that
EPA
will
assign.
You
may
either
complete
an
electronic
(
Microsoft
Excel)
or
a
printed
version
of
the
application.
Please
fill
out
each
form
or
worksheet
in
the
application
as
completely
as
possible.
If
you
are
completing
the
printed
version
and
need
extra
space
you
may
attach
additional
sheets
as
needed.
Additional
information
may
be
available
from
your
local
state
department
of
agriculture
or
at
the
sites
listed
below
or
by
calling
1­
800­
296­
1996.

Instructions
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
Worksheet
2.
Methyl
Bromide
­
Historical
Data
If
you
anticipate
that
you
will
need
methyl
bromide
in
2005
because
you
believe
there
are
no
technically
and
economically
feasible
alternatives,
then
you
should
apply
for
the
critical
use
exemption.
This
application
may
be
submitted
either
by
a
consortium
representing
multiple
users
or
by
individual
users.
We
encourage
users
with
similar
circumstances
of
use
to
submit
a
single
application
(
for
example,
any
number
of
pre­
plant
users
with
similar
soil,
pest,
and
climactic
conditions
can
submit
a
single
application.)

If
a
consortium
is
applying
for
multiple
methyl
bromide
users,
the
economic
data
should
be
for
a
representative
or
typical
user
within
the
consortium
unless
otherwise
noted.
If
economic
or
technical
factors
(
such
as
size
of
the
farm)
affecting
the
ability
of
this
"
representative
user"
to
use
alternatives
are
significantly
different
than
other
users
in
the
consortium,
more
than
one
application
should
be
submitted
to
reflect
these
differences.
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
2­
A.
Methyl
Bromide
Use
1997­
2000
(
i)
The
specific
use
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
that
use
would
result
in
a
significant
market
disruption;
and
(
ii)
There
are
no
technically
and
economically
feasible
alternatives
available
to
the
user
that
are
acceptable
from
the
standpoint
of
environment
and
health
and
are
suitable
to
the
crops
and
circumstances
of
the
nomination
 "

WHO
APPLIES?

SECTIONS
OF
WORKBOOK
The
information
provided
by
you
in
this
application
will
be
used
to
evaluate
the
requested
methyl
bromide
use.
The
U.
S.
and
other
countries
that
are
parties
to
the
Montreal
Protocol
On
Substances
That
Deplete
The
Ozone
Layer
decided
that:
"
a
use
of
methyl
bromide
should
qualify
as
"
critical"
only
if
the
nominating
Party
determines
that:
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
IS
MY
INFORMATION
CONFIDENTIAL?

WHEN
IS
THE
INFORMATION
NEEDED?

1­
800­
296­
1996
phone:
(
202)
564­
9410
If
you
have
general
questions
about
this
application
call:

Stratospheric
Ozone
Hotline
Methyl
Bromide
Critical
Use
Exemption
Global
Programs
Division
Global
Programs
Division,
Mail
Code
6205J
1200
Pennsylvania
Ave,
NW
501
3rd
St.
NW
Washington,
DC
20001
Washington,
DC
20460­
0001
Address
for
applications
being
sent
by
courier
or
non­
U.
S.
Postal
overnight
express
delivery
to
EPA:

US
Environmental
Protection
Agency
(
When
submitting
an
application
electronically,
you
should
also
print
a
hard
copy,
sign
the
copy,
and
submit
it
by
mail)

Mailing
Address
for
applications
being
submitted
by
mail
directly
to
the
EPA:
US
Environmental
Protection
Agency
Methyl
Bromide
Critical
Use
Exemption
The
applicant
may
assert
a
business
confidentiality
claim
covering
part
or
all
of
the
information
in
the
application
by
placing
on
(
or
attaching
to)
the
information,
at
the
time
it
is
submitted
to
EPA,
a
cover
sheet,
stamped
or
typed
legend,
or
other
suitable
form
of
notice
employing
language
such
as
trade
secret,
proprietary,
or
company
confidential.
Allegedly
confidential
portions
of
otherwise
non­
confidential
documents
should
be
clearly
identified
by
the
applicant,
and
may
be
submitted
separately
to
facilitate
identification
and
handling
by
EPA.
If
the
applicant
desires
confidential
treatment
only
until
a
certain
date
or
until
the
occurrence
of
a
certain
event,
the
notice
should
so
state.
Information
covered
by
a
claim
of
confidentiality
will
be
disclosed
by
EPA
only
to
the
extent,
and
by
means
of
the
procedures
set
forth
under
40
CFR
Part
2
Subpart
B;
41
FR
36902,
43
FR
400000.
50
FR
51661.
If
no
claim
of
confidentiality
accompanies
the
information
when
it
is
received
by
EPA,
it
may
be
made
available
to
the
public
by
EPA
without
further
notice
to
the
applicant.
Applicants
submitting
their
application
via
e­
mail
assume
respo
This
application
must
be
postmarked
to
the
EPA
address
below
no
later
than
120
days
after
the
Notice
was
published
in
the
Federal
Register
requesting
critical
use
exemption
applications.

Electronic
Address
for
applications:

methyl.
bromide@
epa.
gov
HOW
CAN
I
RECEIVE
ADDITIONAL
INFORMATION?
WHERE
DO
I
SUBMIT
THE
APPLICATION?
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
1
To
add
additional
blank
worksheets
in
the
Excel
file,
go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Insert"
then
"
worksheet"

2
A
tab
with
the
name
"
Sheet
1"
will
appear
at
the
bottom
of
the
worksheet
and
will
be
highlighted
in
white.
Take
the
cursor
and
double
click
the
"
new
tab"

3
By
double
clicking
in
the
tab
you
can
now
rename
the
worksheet
to
the
appropriate
number
letter
designation
(
e.
g.,
3­
A(
1),
3­
A(
1)(
a),
etc.)

4
To
move
a
newly
inserted
worksheet,
simply
drag
the
worksheet
with
your
mouse
to
the
desired
location.

5
Once
you
add
a
new
worksheet,
Excel
will
automatically
name
each
subsequently
added
worksheet
as
Sheet
2,
Sheet
3,
Sheet
4,
etc 
Follow
the
instructions
above
to
rename
the
new
blank
worksheets
as
appropriate.

1
Select
the
worksheet
to
be
copied
by
clicking
on
the
worksheet
tab
at
the
bottom
of
the
screen.
The
tab
will
turn
white
in
color
when
it
has
been
selected.

2
Select
the
top
left
corner
of
the
worksheet
(
this
is
the
space
to
the
left
of
the
column
A
and
above
the
row
1.
You
will
know
that
the
entire
worksheet
has
been
selected
because
the
row
and
column
marks
as
well
as
the
worksheet
itself
will
change
to
a
different
color.

3
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Copy".

4
Go
to
the
blank
worksheet
where
you
want
the
copied
information
to
be
pasted.

5
Again,
select
the
top
left
corner
of
the
worksheet
(
left
of
column
A
and
above
row
1)
to
select
the
entire
worksheet.

6
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Paste"

7
Change
the
title
row
of
the
newly
pasted
worksheet
from
the
old
worksheet
number
to
be
consistent
with
the
worksheet
tab.
Inserting
a
blank
worksheet:

Note:
This
is
the
only
way
you
can
copy
a
worksheet
and
not
lose
portions
of
the
text
instructions.

Viewing
worksheets
The
set
of
four
arrows
on
the
bottom
left
of
the
screen
will
help
you
navigate
between
worksheets.
This
is
necessary
to
access
the
remaining
worksheet
tabs
in
the
workbook
that
are
not
viewable.
The
two
arrows
with
vertical
lines
to
either
the
left
or
right
will
take
you
to
the
first
worksheet
and
to
the
last
worksheet
respectively
in
the
workbook.
The
inner
two
arrows
allow
you
move
the
worksheet
tabs
to
the
right
or
to
the
left
incrementally.
Copying
and
pasting
an
entire
worksheet's
contents
into
a
blank
worksheet:

If
you
would
like
to
print
all
worksheets
that
are
contained
in
this
workbook,
go
to
the
menu
bar
at
the
top
of
the
screen
and
select
"
File"
and
then
"
Print."
Then
in
the
section
of
the
menu
that
appears
called
"
Print
what,"
select
"
Entire
Workbook."
EXCEL
USER
TIPS
The
two
arrows
on
the
bottom
right
of
the
screen
allow
you
to
move
the
worksheet
that
you
are
viewing
to
the
right
or
to
the
left.
This
is
useful
if
the
viewable
area
of
on
the
screen
is
smaller
than
the
entire
page
that
is
in
the
worksheet.
Worksheets
are
best
viewed
in
"
Page
Break
Preview."
To
select
the
view
of
the
worksheet,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Page
Break
Preview."
Page
break
preview
shows
only
the
printable
area
of
the
worksheet,
with
the
blue
lines
that
surround
the
screen
indicating
the
edges
of
each
page.

To
increase
or
decrease
the
size
of
the
page
that
is
viewable
on
the
screen,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Zoom".

Navigating
between
worksheets
Printing
worksheets
1.

2.

3.

4.

Light
80%
Medium
10%
Heavy
10%

0
to
2%
70%
2
to
5
%
30%
over
5%

5.

6.
Specialty
(
check
one)

7.
agronomic
8.
economic
9.
Daytime
phone
10.
FAX
11.

List
an
additional
contact
person
if
available.
Specialty
(
check
one)

12.
agronomic
13.
economic
14.
15.
FAX
16.
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Sacramento,
CA
95814
Anne
Downs
(
916)
443­
2793
(
916)
443­
3071
adowns@
exponent.
com
Location
(
Enter
the
state,
region,
or
county.
Provide
more
detail
about
the
location
if
relevant
to
the
feasibility
of
alternatives
to
methyl
bromide.)

Crop/
commodity
(
Include
all
crops/
commodities
that
benefit
from
the
application
of
methyl
bromide
in
a
fumigation
cycle.
A
fumigation
cycle
is
the
period
of
time
between
methyl
bromide
fumigations.)

Climate
(
Individual
users
should
enter
their
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
climate
zone.
This
map
is
located
at
the
end
of
this
workbook
or
it
can
be
reviewed
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html).

The
climate
zones
(
taken
from
the
U.
S.
climate
zone
map)
are
6a,
6b
and
7a
for
high
elevation
locations,
9a
and
9b
for
low
elevation
locations.
High
elevation
nurseries
are
between
3200
feet
to
4200
feet
above
sea
level.
Rain
fall
for
the
high
elevation
sites
ranges
from
10.8
to
18.9
inches
per
year.
Maximum
average
temperatures
in
July
is
85F
with
and
average
yearly
temperature
at
46.8F.
Low
elevation
nurseries
sites
are
between
39
feet
to
550
feet
above
sea
level.
Rain
fall
in
the
low
elevation
sites
ranges
from
15
­
30
inches
per
year.
Average
maximum
temperatue
in
these
locations
in
July
is
78.3F
which
the
average
yearly
temperature
is
61.3F.
Most
growers
have
both
high
and
low
elevation
nursery
locations.
High
elevation
is
just
under
75%
of
the
acreage,
low
elevation
just
above
25%
of
the
acreage.
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
The
following
information
will
be
used
to
determine
the
amount
of
methyl
bromide
requested
and
the
contact
person
for
this
request.
It
is
important
that
we
know
whom
to
contact
in
case
we
need
additional
information
during
the
review
of
the
application.

Other
geographic
factors
that
may
affect
crop/
commodity
yield
(
e.
g.,
water
table).

California
Strawberry
Nursery
Association
High
Elevation
Nuseries
are
in
Northern
California
and
Southern
Oregon.

Strawberry
Nursery
Production
is
the
main
commodity.
However
other
commodities
that
are
used
in
the
rotation
crop
also
benefit
from
the
use
of
methyl
bromide.
These
commodities
include
registered
grain
seed,
onions,
garlic,
endive,
horseradish,
mint,
potatoes,
sugarbeets,
alfalfa,
barley,
oats,
wheat,
and
triticale.

Soil
Type:

Organic
Matter:
Low
Elevation
Nuseries
the
Sacramento
Valley
and
Northern
San
Joaquin
Valley.

Soil
type
Check
the
box(
es)
for
the
soil
types
and
percent
organic
matter
that
apply
to
your
area.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
soil
type.

Sacramento,
CA
95814
jwells@
exponent.
com
E­
mail
910
K
Street,
Suite
325
Soils
tend
to
be
cool
and
wet
in
the
spring.
About
40%
of
the
acreage
is
fumigated
in
the
spring
to
allow
for
flexibility
to
react
to
market
demand.
High
elevation
nursery
locations
provide
the
chilling
hours
in
early
fall
neacessary
for
plant
dormancy.
Dormancy
is
necessary
to
promote
plant
vigor.

(
916)
443­
3071
Contact
name
Address
James
W.
Wells
Consortium
name
910
K
Street,
Suite
325
(
916)
443­
2793
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
lbs.

17a.
acres
units
18.
Yes
X
No
18a.

19.

20.

20a.

OMB
Control
#
2060­
0482
Since
there
are
so
few
growers
involved
in
strawberry
nursery
production,
the
typical
growers
is
the
average
of
the
total
growers.
How
much
active
ingredient
(
ai)
of
methyl
bromide
are
you
requesting
for
2005?

If
a
consortium
is
submitting
this
application,
the
data
for
question
17
and
17a.
should
be
the
total
for
the
consortium.

In
the
question
below,
area
is
defined
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post
harvest
operations,
and
square
feet
for
structural
applications.

Year
3,360
For
EPA
Use
Only
ID#

Explain
why
this
user
represents
the
typical
user
in
the
consortium.
3,360
Applications
will
be
made
at
a
rate
of
235
lbs
of
ai
per
acre.
Use
is
reqested
for
the
California
strawberry
There
are
twelve
certified
strawberry
nursery
growers
with
a
total
of
3,200
acres
planted
at
high
and
low
elevation
locations
in
2002.
The
representative
grower
is
the
average
of
all
twelve
nursery
growers.
The
California
Strawberry
Nursery
Narrative
describes
the
representative
user
and
the
standard
nursery
growing
practices.
If
applying
as
a
consortium
for
many
users
of
methyl
bromide,
please
define
a
representative
user
.
Define
exactly,
issues
such
as
size
of
the
operation
(
acres
treated
with
methyl
bromide
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications),
whether
the
representative
user
owns
or
rents
the
land
or
operation,
intensity
of
methyl
bromide
use
(
treat
regularly
or
only
when
pest
reaches
a
threshold),
pest
pressure,
etc.
Target
Pest(
s)
or
Pest
Problem(
s):
(
Be
as
specific
as
possible
about
the
species
or
classes
of
pests
relevant
to
the
feasibility
of
alternatives.)
acres
acres
2007
In
the
table
below,
area
is
defined
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post
harvest
operations,
and
square
feet
for
structural
applications.

2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
790,000
Area
to
be
Treated
3,360
If
yes,
please
list
year
and
quantity
active
ingredient
(
ai)
of
methyl
bromide
requested
in
the
table
below
and
explain
why
you
need
authorization
for
multiple
years.

domestic
and
international
nursery
and
fruit
production
fields)
until
a
viable
fumigation
alternative
is
identified.

If
a
consortium
is
submitting
this
application,
the
data
below
should
be
the
total
for
the
consortium.
Are
you
requesting
methyl
bromide
for
additional
years
beyond
2005?

See
Tables
1,
2
and
3
in
California
Strawberry
Nursery
Narrative.
790,000
Unit
of
Area
Treated
790,000
nursery
through
2007
in
order
to
continue
production
of
pest
and
disease
free
planting
stock
(
for
This
allows
for
a
small
amount
of
industry
increase
(
5%)
between
2002
and
2005.
How
much
area
will
this
be
applied
to?
Please
list
units.
Introduction
The
strawberry
plant
nursery
stock
produced
annually
in
California
represents
one
of
the
largest
and
most
widely
distributed
nursery
products
in
the
world.
Nearly
a
billion
plants
are
produced
by
the
California
strawberry
nursery
system
each
year,
and
plants
are
annually
distributed
from
California
to
every
continent
with
a
temperate
climate
suitable
for
fruit
production.
In
addition,
many
nursery
systems
in
other
parts
of
the
United
States
and
throughout
the
world
rely
on
California
strawberry
stock
as
a
source
for
their
propagation
systems.
The
integrity
of
California
strawberry
nursery
systems
directly
influences
the
global
success
of
strawberry
fruit
as
a
viable
crop.

Description
of
Strawberry
Nursery
Production
System
Due
to
the
complex
genetic
structure
of
the
modern
strawberry,
plants
do
not
replicate
true
to
type
from
seed,
and
must
be
asexually
propagated
by
rooting
runners
produced
from
source
plants.
The
California
strawberry
nursery
industry
is
responsible
for
providing
genetically
pure
and
clean
planting
material
essential
to
the
success
of
strawberry
fruit
growers
and
other
nursery
systems.
Strawberry
nurseries
annually
plant
source
stocks
in
fumigated
fields,
root
the
runners
that
form,
and
harvest
these
runner
plants
as
a
final
product.

The
strawberry
nursery
industry
is
a
very
complex
system.
A
typical
nursery
system
includes
both
high
and
low
elevation
nursery
locations,
chosen
to
provide
a
cold
site
for
October
harvest,
and
a
warmer
site
for
December
 
January
harvest.

The
high
elevation
nurseries
are
located
in
Northern
California
and
Southern
Oregon
at
elevations
of
3,200
to
4,200
feet,
and
produce
the
plants
used
for
October
planting
in
California,
throughout
the
United
States,
and
internationally.

Low
elevation
nurseries
(
below
600
feet)
are
located
in
the
Sacramento
and
northern
San
Joaquin
valleys
of
California.
These
low
elevation
nurseries
produce
plants
for
both
propagation
and
fruit
plantings.
The
propagation
stock
is
used
by
nurseries
in
California,
throughout
the
United
States,
and
internationally.
The
balance
of
the
low
elevation
production
is
stored
for
distribution
through
the
spring
and
summer
months
as
frigo
plants,
and
supplies
fruit
production
systems
throughout
the
world.

The
typical
strawberry
nursery
system
is
diagrammed
in
(
Figure
1).
This
shows
that
nurseries
must
propagate
plants
in
the
field
for
multiple
years
before
the
plants
are
sold
to
customers.
Guidelines
established
and
enforced
by
the
California
Department
of
Food
and
Agriculture
must
be
followed
by
all
strawberry
nurseries.
The
nursery
stock
regulations
include
fumigation
standards,
as
well
as
standards
for
virus,
pathogen
and
insect
control.

Figure
1.
Overall
California
Nursery
System
Year
1
Plants
are
grown
in
a
screenhouse
as
nuclear
stock.
The
source
plants
have
been
heat
treated
and
meristemed
in
order
to
insure
a
virus
and
disease
free
stock
for
this
first
cycle
of
nursery
production.
Nurserymen
may
heat
treatment
and
meristem
stock
in
their
own
facilities,
or
may
purchase
meristem
stock
plants
from
the
Foundation
Plant
Material
Services
located
at
the
University
of
California,
Davis,
California.

Year
2
Meristemed
stock
is
planted
in
an
enclosed
screenhouse
structure,
designed
to
exclude
insect
vectors
preventing
plant
contamination.
These
plants
are
planted
into
fumigated
soil
or
media.
The
plants
produce
about
100
daughter
plants
per
mother
plant.
CDFA
inspectors
examine,
and
laboratory
test
screenhouse
stocks
to
insure
that
the
plants
are
virus
and
nematode
free.
They
closely
inspect
for
other
possible
insect
and
disease
pressures.
There
is
no
tolerance
for
virus,
nematodes,
and
plant
diseases
in
screenhouse
propagation.
The
screenhouses
are
generally
located
in
low
elevation
nursery
sites.

Year
3
Plant
increases
harvested
from
screenhouses
are
planted
in
low
elevation
nursery
fields.
The
increase
ratio
at
this
level
is
about
50:
1.
These
low
elevation
fields
are
called
Foundation
increases,
and
are
planted
outside
in
carefully
fumigated
soils.
The
CDFA
samples
these
fields
for
nematodes
and
virus
intrusion,
and
inspects
carefully
for
full
control
of
insect
and
disease
levels.
There
is
no
tolerance
for
nematodes
and
virus
in
foundation
plantings.
These
stocks
are
rarely
sold
as
a
market
item.

Year
4
Plants
from
the
Foundation
are
planted
into
low
elevation
fields
that
have
been
fumigated.
Fields
at
this
level
are
referred
to
as
Registered
increases.
The
increase
ratio
at
this
level
is
about
50:
1.
These
fields
are
inspected
by
the
CDFA
and
are
sampled
for
nematode
infection.
Diseases
and
insects
are
also
carefully
monitored
at
this
level.
There
is
a
zero
tolerance
for
nematodes
and
virus
symptoms
at
this
level.
These
plants
are
often
sold
worldwide
as
propagative
stocks
to
nursery
systems
and
to
fruiting
systems
with
critical
needs
for
pathogen
control.

Year
5
Plants
from
the
Registered
Fields
are
planted
into
high
and
low
elevation
fields
that
have
been
fumigated.
Propagation
at
this
level
can
be
registered
as
Certified
Field
increases.
Plants
in
certified
fields
are
increased
at
a
level
of
about
30:
1.
The
CDFA
inspections
make
sure
that
the
fields
are
clean
of
nematode
and
virus
infections,
and
evaluate
insect
and
disease
pressures
for
phytosanitary
clearances.
These
plants
are
sold
and
planted
for
fruit
production
both
domestically
and
internationally.

About
70%
of
the
ground
used
for
strawberry
nursery
production
is
owned
by
the
nursery
grower,
and
the
other
30%
is
leased.
Nurseries
need
sandy
loam
soils
to
allow
for
the
deep
rooting
pattern
produced
by
strawberry
plants.
Strawberry
roots
may
grow
three
feet
or
more
into
the
soil
during
a
growing
season.
There
are
a
few
heavier
soils
used
in
the
strawberry
nursery
industry
which
are
more
difficult
to
manage.

The
total
high
elevation
nursery
acreage
averages
2,450
acres
per
year,
and
the
low
elevation
acreage
averages
750
acres
per
year.
The
locations
where
strawberry
nurseries
are
grown
are
dry
and
hot
in
the
summer
months
and
cold
in
the
winter
months.
Rainfall
averages
about
20
inches
per
year
in
the
high
elevation
locations
and
30
inches
per
year
in
the
low
elevation
locations.

Strawberry
nursery
fields
are
planted
in
the
spring,
and
may
be
fumigated
in
the
previous
fall
(
August
and
September)
on
fallow
ground,
or
may
be
fumigated
in
the
spring
(
March
and
April)
prior
to
planting.
The
majority
of
the
fumigation
is
done
in
the
fall
(
60%),
but
the
spring
fumigation
is
a
very
important
option
to
provide
the
flexibility
to
adjust
acreage
based
on
a
later
projected
demand.
While
some
of
the
nursery
growers
fumigate
their
own
fields,
about
65%
of
the
growers
have
contract
fumigators
apply
the
material.

Strawberry
nursery
culture
is
labor
intensive.
Nurseries
maintain
a
sizeable
permanent
staff,
and
hire
thousands
of
workers
on
a
seasonal
basis.

Nursery
fields
are
spring
planted
using
crews
on
four
row
mechanical
transplanters.
In
high
elevation
nurseries,
about
12,000
plants
are
placed
per
acre,
and
low
elevation
fields
with
longer
growing
seasons
are
planted
with
about
6,000
plants
per
acre.
As
the
plants
grow,
runners
are
produced
and
are
set
by
hand.
Field
weeds
that
survive
fumigation
are
also
removed
by
hand.
During
the
season,
the
runners
produced
form
a
solid
canopy
of
leaf
cover
over
the
field.
Before
the
plant
canopy
fills
in,
tractors
can
be
used
in
the
field
to
spray
if
necessary.
Overhead
sprinkler
irrigation
systems
are
used
to
irrigate,
as
well
as
to
fertigate
the
fields
as
necessary.
As
the
canopy
fills
in,
tractors
are
no
longer
able
to
drive
through
the
field,
and
chemicals
can
also
be
applied
through
the
overhead
sprinkler
system.

High
elevation
fields
are
harvested
starting
in
late
September
when
the
temperatures
begin
to
fall
and
the
strawberry
plants
begin
to
go
dormant.
High
elevation
harvests
continue
through
late
October.
Low
elevation
plants
are
harvested
in
December
or
January
after
the
plants
are
fully
dormant.
Several
pieces
of
equipment
are
used
during
the
harvest
process.
The
strawberry
plant
leaves
are
removed
with
a
mulching
mower,
and
interconnecting
runners
are
broken
apart
with
a
mechanical
rake.
The
strawberry
harvester
is
a
custom
designed
machine
that
undercuts
the
plants,
lifts
the
plants
from
the
soil,
and
shakes
remaining
soil
free
from
the
root
system.
Plants
are
placed
in
burlap
bags
or
bin
containers
on
the
back
of
the
harvesters,
and
are
loaded
for
transport.

During
this
process,
about
50%
of
the
crop
biomass
is
left
in
the
field.
This
remaining
biomass
consists
mainly
of
leaf
tissue,
root
tissue,
and
crowns
of
smaller
plants.

Harvested
plants
are
removed
from
the
field,
placed
in
pre­
cooled
trucks
and
transported
promptly
from
the
field
to
the
trim
shed.
At
the
trim
shed,
the
plants
are
held
briefly
in
cold
storage
and
then
graded
by
large
processing
crews.
This
stage
requires
a
large
amount
of
skilled
and
qualified
labor
to
achieve
reasonable
production
output
rates.

The
hand­
trimmed
plants
are
graded
for
quality
based
on
crown
size
and
root
development,
and
are
packed
into
boxes
containing
1,000
to
1,500
plants.
Only
plants
that
meet
the
quality
grade
standards
are
packed,
and
the
other
plants
are
discarded.
These
boxes
are
placed
back
into
cold
storage
(
28
­
32?
F)
for
final
cooling,
and
are
shipped
on
pre­
cooled
trucks,
refrigerated
ocean
containers,
or
by
fast
air
shipments
to
customers.

Nursery
fields
are
rotated
out
of
strawberries
and
into
cover
crops
for
an
average
of
two
years
between
strawberry
planting
cycles.
The
cover
crops
used
are
generally
grains,
and
may
be
harvested,
but
are
primarily
used
to
increase
the
organic
matter
in
the
soil.
Other
cover
crops
include
endive,
garlic,
onions,
horseradish,
and
mint.

Fumigation
and
Pathogen,
Nematode
and
Weed
Control
in
Strawberry
Nurseries
Methyl
Bromide/
Chloropicrin
fumigation
currently
used
at
the
strawberry
nursery
controls
soil
borne
pathogens,
nematodes,
and
weeds.
Deep,
uniform
fumigation
is
necessary
to
provide
the
nursery
with
a
strong
base
for
producing
clean
planting
stock.
Methyl
bromide
is
an
ideal
fumigant
due
to
the
small
molecular
size
of
the
gas,
which
allows
the
fumigant
to
move
easily
through
the
soil
and
penetrate
deeply
into
the
soil
profile.

The
combination
of
Methyl
Bromide
and
Chloropicrin
thoroughly
and
completely
sterilizes
the
soil
from
the
surface
to
beyond
the
penetrable
depth
of
the
nursery
crop
root
system.
There
are
over
60
identified
fungal
diseases
and
seven
major
nematode
groups
that
infect
strawberry,
and
the
Methyl
Bromide/
Chloropicrin
combination
is
highly
effective
against
all
of
them.
There
are
many
weed
types
common
to
strawberry
nursery
growing
areas,
and
Methyl
Bromide
is
by
far
the
most
effective
soil
treatment
to
eliminate
them
in
nursery
plantings.
Some
of
the
most
important
nematode,
disease,
and
weed
pests
are
listed
and
discussed
below.

The
major
soil
born
diseases
that
are
a
problem
in
strawberries
and
are
controlled
by
methyl
bromide
at
the
nursery
level
are
shown
in
Table
1.
Methyl
Bromide
readily
kills
pathogens
in
plant
debris
left
in
the
field
after
harvest
as
well
as
common
soil
borne
diseases.

Table
1.
Major
problem
diseases
in
Strawberry
Nursery
Production
Disease
Causal
Organism
Red
Stele
Phytophthora
fragariae
Crown
Rot
Phytophthora
cactorum
Root
Rot
Phytophthora
citricola
Anthracnose
Colletotrichum
acutatum
Verticillium
wilt
Verticillium
dahliae
Powdery
Mildew
Sphaerotheca
macularis
Angular
Leaf
Spot
Xanthomonas
fragariae
Common
Leaf
Spot
Ramularia
tulasneii
Black
Root
Pythium
Rot
Rhizoctonia
Cylindrocarpon
Fumigation
is
also
used
to
control
nematodes
(
Table
2).
Because
fumigation
is
used
in
strawberry
nurseries,
nematodes
have
not
been
a
problem
in
nurseries
or
production
fields
since
the
1960'
s
when
Methyl
Bromide
fumigations
were
first
used.
The
effectiveness
of
Methyl
Bromide/
Chloropicrin
mixture
in
controlling
nematodes
contributed
to
the
adoption
of
the
California
Nursery
Stock
Regulations.
These
regulations
do
not
permit
nursery
stock
infested
with
nematodes
to
be
shipped
from
the
nursery.
All
certified
nursery
plantings
are
sampled
parasitic
nematodes,
and
if
any
are
found,
the
infected
area
is
rejected
for
harvest.

Table
2.
Nematodes
controlled
in
Strawberry
Nursery
Production
Common
Name
Scientific
Name
Root
Knot
Nematode
Meloidogyne
hapla
Sting
Nematode
Belonolaimus
longicaudatus
Dagger
Nematode
Xiphinema
americanum
Stem
Nematode
Ditylenchus
dipsaci
Root
Lesion
Nematode
Pratylenchus
penetrans
Needle
Nematode
Longidorus
elongatus
Foliar
Nematode
Aphelenchoides
ritzemabosi
Fumigation
is
also
used
to
control
weeds
(
Table
3)
found
in
California
strawberry
nurseries.
Several
of
the
weeds
types
in
California
strawberry
nurseries
areas
are
classified
as
noxious
weeds
by
the
state
of
California.
It
is
important
to
use
a
fumigant
that
can
effectively
control
weeds
to
prevent
spread
of
seed
adhering
to
soil
particles
on
plants
that
are
shipped
both
domestically
and
internationally
by
strawberry
nursery
growers.

An
additional
benefit
is
the
complete
control
of
strawberry
seed
from
previous
plantings
that
might
germinate
in
a
nursery
field.
If
strawberry
seed
germinates
in
a
nursery
planting,
variety
mixes
are
created
rendering
the
planting
unsaleable.
Table
3.
Common
weeds
present
in
Strawberry
Nurseries
Common
Name
Scientific
Name
Annual
bluegrass
Poa
annua
Bur
clover
Medicago
hispida
Carpetweed
Mollugo
verticillata
Chickweed
Stellaria
media
Field
bindweed
Convolvulus
arvensis
*

Filaree
Erodium
Botrys
Goat
Grass
Aegilops
triuncialis
Hairy
Nightshade
Solanun
villosum*

Lambsquart
er
Chenopodium
album
Malva
Malva
parviflora
Nutsedge
Cyperus
rotundus*
Pig
Weed
Amaranthus
retroflexus
Portulaca
Oleracae
Prostrate
Spurge
Euphorbia
humistrata
Puncture
vine
Tribulus
terrestris*

Purslane
Portulaca
oleracea
Vetch
Vicia
sativa
*
Considered
noxious
weeds
by
the
California
Department
of
Food
and
Agriculture.

Methyl
Bromide
and
Strawberry
Nursery
Culture
The
challenges
in
strawberry
nursery
production
are
considerable.
All
customers
for
strawberry
stock
depend
on
the
nurseries
to
provide
stock
free
of
pests
and
pathogens
for
planting.
Since
the
nurseries
have
the
plants
for
multiple
production
cycles
before
the
plants
are
sent
to
the
fruit
growers
and
nursery
customers,
any
tiny
problem
or
minute
infection
that
occurs
in
the
nursery
system
can
be
multiplied
many
times,
and
over
several
years
before
the
plants
are
sold
(
Table
4).

Table
4.
Amplification
Schedule
for
Short
Day
and
Day
Neutral
Cultivars
at
Year
Nursery
Locations
Short
Day
Cultivars
Day
Neutral
Cultivars
0
Low
Elevation
 
Meristem
Plant
1
1
1
Low
Elevation
 
Screenhouse
100
100
2
Low
Elevation
 
Foundation
Field
50
35
3
Low
Elevation
 
Registered
Field
50
35
4
High
Elevation
 
Certified
Field
25
20
Total
Increase
Ratio
6,250,000
2,450,000
The
challenge
in
growing
clean
strawberry
nursery
stock
is
easy
to
visualize
from
Table
4.
From
the
usual
four­
year
process,
a
single
plant
placed
in
a
screenhouse
increase
on
year
1
can
be
increased
to
as
many
as
six
million
plants
by
the
end
of
year
4.
The
tiniest
contamination
level
in
years
1
and
2
can
have
a
very
broad
effect
on
the
general
cleanliness
status
of
the
nursery
in
years
three
and
four.
Even
if
diseases
did
not
spread
to
other
plants
in
a
field,
an
infection
on
year
one
could
yield
six
million
infected
plants
by
harvest
in
year
4.
Unfortunately,
spread
rates
in
field
conditions
for
fungal
diseases
are
very
high,
and
any
minute
disease
intrusion
in
propagation
years
1
and
2
will
lead
to
a
general
infection
in
production
stock.
Because
of
rapid
spread
rates,
even
minute
disease
intrusion
into
propagation
in
year
3
will
introduce
considerable
disease
exposure
in
propagation
in
year
4.

The
challenge
is
even
larger
when
the
disease
organisms
affecting
strawberry
are
considered.
In
referring
to
table
4,
most
of
the
fungal
diseases
affecting
strawberry
are
capable
of
multiplying
as
many
times
per
day
as
we
might
expect
to
multiply
in
plant
numbers
for
the
year.
Most
of
the
nematode
pests
can
multiply
themselves
weekly
by
what
could
be
multiplied
annually
in
plant
numbers.

The
challenge
is
thus
defined.
A
strawberry
nursery
must
increase
stock
in
the
system
over
a
four
year
period,
and
end
the
process
with
uncontaminated
stock.
To
do
this,
a
strawberry
nursery
must
do
more
than
manage
disease
pressure.
To
be
successful,
the
strawberry
nursery
must
very
effectively
manage
disease
Approximate
Amplification
incidence.
Apparent
plant
health
and
acceptable
disease
thresholds
are
not
part
of
the
language
of
successful
strawberry
nursery
culture.
A
strawberry
nursery
is
successful
only
if
major
plant
disease
incidences
are
controlled.
The
success
of
the
nursery
product
provided
to
customers
is
directly
related
to
the
nursery's
ability
to
exert
this
control.

As
mentioned,
the
California
strawberry
nurseries
produce
around
one
billion
plants
annually,
and
production
distribution
is
worldwide.
In
addition,
propagation
in
strawberry
in
many
countries
depends
on
California
produced
nursery
stocks.
Canadian
and
Mexican
nurseries
use
almost
80
percent
California
source
stocks,
and
a
high
percentage
(
40­
60%)
of
Spanish
and
South
American
propagation
is
based
on
California
sources.
Most
strawberry
systems
in
the
world
are
using
some
stocks
with
origin
from
California
nurseries.

Because
the
strawberry
plants
from
California
are
so
widely
distributed,
any
disease
and
insect
problems
that
are
not
controlled
by
the
California
nurseries
will
become
international
control
and
quarantine
issues.

The
strawberry
nursery
use
is
possibly
the
most
critical
of
the
applications
that
will
be
considered
in
the
Critical
Use
Exemption
process.
In
any
test
evaluation
that
considers
the
spectrum
of
disease
control
important
to
strawberry,
every
chemical
and
every
combination
and
every
alternative
scheme
has
proved
inferior
to
the
broad
efficacy
of
Methyl
Bromide
Fumigation.
There
has
been
no
data
produced
that
would
suggest
alternative
soil
fumigation
regimes
provide
the
short
and
long
term
disease
control
integrity
required.
Worksheet
Title
Instructions
specific
to
each
worksheet
are
located
at
the
top
of
each
sheet.

2­
A
Methyl
Bromide
Use
for
1997
­
2000
This
worksheet
provides
data
in
actual
usage
for
1997­
2000.

2­
B
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
1997­

2000
This
worksheet
provides
crop/
commodity
yield
and
gross
revenue
for
1997
through
2000.

2­
C
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
2001
This
data
provides
historical
information
on
crop/
commodity
yield
and
gross
revenue
for
2001.

2­
D
Methyl
Bromide
Use
and
Costs
for
2001
This
worksheet
isolates
use
and
cost
data
for
2001.

2­
E
Methyl
Bromide
­
Other
Operating
Costs
for
2001
This
data
is
needed
to
estimate
a
baseline
for
operating
costs
in
order
to
estimate
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

2­
F
Methyl
Bromide
­
Fixed
And
Overhead
Costs
for
2001
This
data
is
needed
to
estimate
a
baseline
for
total
costs
in
order
to
estimate
the
impact
on
profitability
and
long­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

Purpose
of
Data:
To
establish
a
baseline
estimate
of
crop/
commodity
yields,
gross
revenues,
and
costs
using
methyl
bromide.
Worksheet
2.
Methyl
Bromide
­
Historical
Use
of
Methyl
Bromide
Col
A:
Formulation
of
Methyl
Bromide
Col
B,
E,
H,
K:
Actual
Area
Treated
Col
C,
F,
I,
L:
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Col
D,
G,
J,
M:
Actual
Average
lbs.
ai
Applied
per
Area
A
B
C
D
E
F
G
H
I
J
K
L
M
Total
Actual
Area
Treated
in
acres
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
over
95%
methyl
bromide
75%
methyl
bromide,
25%
chloropicrin
500
144,000
288
478
134,318
281
492
132,840
270
67%
methyl
bromide,
33%
chloropicrin
2,098
493,030
235
2,175
511,125
235
2,459
577,865
235
3,005
706,175
235
50%
methyl
bromide,
50%
chloropicrin
80%
methyl
bromide,
20
%
chloropicrin
190
43,890
231
195
45,045
231
180
41,580
231
165
38,115
231
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
2,788
680,920
244
2,848
690,488
242
3,131
752,285
240
3,170
744,290
235
Comments:

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Worksheet
2­
A.
Methyl
Bromide
­
Use
1997­
2000
Enter
the
appropriate
data
in
Col
B­
M
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations.
If
you
enter
only
the
total
and
averages
for
all
formulations
in
the
last
row
of
the
table,
please
describe
in
the
comments
section
the
formulations
typically
used,
or
the
approximate
proportions
of
the
formulations
used.

If
a
consortium
is
submitting
this
application,
all
data
should
reflect
the
actual
data
for
the
consortium.

The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
area
are
automatically
calculated
from
the
previous
2
columns.
2000
Enter
the
total
actual
area
treated.
Note:
This
number
should
be
the
total
actual
area
treated
by
the
individual
user
or
total
actual
area
for
the
entire
consortium,

for
the
year
indicated.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Formulation
of
Methyl
Bromide
Enter
the
actual
total
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied.
Note:
This
number
should
be
the
total
pounds
ai
applied
by
the
individual
user
or
the
entire
consortium,
for
the
year
indicated.

1997
1998
1999
For
EPA
Use
Only
ID#

A
C
D
E
F
Year
Methyl
Bromide
was
Applied
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
acre)

1997
Boxes
of
1,000
plants
436
$
45.00
$
19,620.00
1997
Boxes
of
1,000
plants
343
$
55.00
$
18,865.00
1998
Boxes
of
1,000
plants
528
$
44.00
$
23,232.00
1998
Boxes
of
1,000
plants
350
$
57.00
$
19,950.00
1999
Boxes
of
1,000
plants
467
$
50.00
$
23,350.00
1999
Boxes
of
1,000
plants
341
$
65.00
$
22,165.00
2000
Boxes
of
1,000
plants
427
$
53.00
$
22,631.00
2000
Boxes
of
1,000
plants
320
$
65.00
$
20,800.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
for
1997
$
19,242.50
Total
Revenue
for
1998
$
21,591.00
Total
Revenue
for
1999
$
22,757.50
Total
Revenue
for
2000
$
21,715.50
Average
Revenue
Per
Year
$
21,326.63
Comments:

The
average
grower
has
208
acres
of
high
elevation
stock,
and
60
acres
of
low
elevation
stock.

OMB
Control
#
2060­
0482
High
Elevation
Stock
Low
Elevation
Stock
High
Elevation
Stock
Low
Elevation
Stock
High
Elevation
Stock
Low
Elevation
Stock
High
Elevation
Stock
Low
Elevation
Stock
B
Col.
E:
Price
Col.
F:
Revenue
Crop/
Commodity
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Average
Revenue
per
Year:
The
average
revenue
per
year
is
calculated
automatically
using
the
summary
data
you
enter
for
each
year.

Total
Revenue
for
1997­
2000
Enter
the
total
revenue
per
year
by
adding
the
revenue
for
all
crops
for
that
year.

Col.
A:
Year
Col.
B:
Crop/
Commodity
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Worksheet
2­
B.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
1997­
2000
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
actual
averages
for
the
consortium.

Enter
the
average
prices
received
by
the
users
for
the
year
and
crop/
commodity
indicated
(
1997­
2000).

This
number
is
calculated
automatically
using
the
values
you
entered
in
Cols.
D
and
E.
You
may
override
the
formula
to
enter
a
different
revenue.
Please
explain
why
the
revenue
amount
is
different
in
the
comment
section
below.

Enter
the
unit
of
measurement
for
each
crop/
commodity.

Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
commodities
in
the
fumigation
cycles
from
1997
to
2000.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
each
fumigation
cycle.
(
For
example,
if
normally
methyl
bromide
is
applied
and
tomatoes
are
grown
and
harvested
followed
by
peppers
without
an
additional
treatment
of
methyl
bromide,
then
both
tomatoes
and
peppers
would
be
part
of
the
same
fumigation
cycle.)
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

Enter
the
number
of
units
of
crop/
commodities
produced
per
area.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
1997
­
2000
when
using
methyl
bromide.
Post­
harvest
and
structural
users
may
work
with
EPA
to
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
boxes
per
acre)
Price
(
per
box
of
1,000
plants)
Revenue
(
per
acre)

Low
Elevation
Stock
market
boxes
of
1,000
plants
425
$
50.00
$
21,250.00
High
Elevation
stock
market
boxes
of
1,000
plants
332
$
62.00
$
20,584.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
$
20,917.00
Comments:

Plants
are
graded
as
they
are
trimmed.
Only
plants
making
grade
are
packed
into
boxes
for
sale.

OMB
Control
#
2060­
0482
The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
2001when
using
methyl
bromide.
Post­
harvest
users
may
modify
this
form
to
accommodate
differences
when
providing
gross
revenue
data.
If
2001
was
not
a
typical
year
for
the
individual
or
for
the
representative
user
of
a
consortium,
the
applicant
may
provide
additional
data
for
a
different
year.
However,

all
applicants
must
complete
this
worksheet
for
the
year
2001
regardless.
Please
explain
in
the
comment
section
at
the
bottom
of
the
worksheet
why
2001
is
not
considered
a
typical
year,

if
that
is
the
case.
Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
the
fumigation
cycle
(
interval
between
fumigations)
beginning
with
the
treatment
of
methyl
bromide
in
2001.
If
multiple
crops
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
crops
during
the
entire
interval.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Col.
A:
Crop/
Commodity
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

Enter
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

Revenue
is
automatically
calculated
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
the
comment
section
below.

Enter
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,

grade,
market
(
e.
g.
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
row.
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
in
making
the
case
that
the
use
of
methyl
bromide
affects
these
price
factors.

Enter
the
unit
of
measurement
for
each
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor.
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Acre
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Acre
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Acre
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Number
of
Acres
Cost
per
Acre
over
95%
methyl
bromide
$
0.00
75%
methyl
bromide,
25%
chloropicrin
$
0.00
67%
methyl
bromide,
33%
chloropicrin
235
$
3.11
$
500.00
$
200.00
3025
$
1,430.85
50%
methyl
bromide,
50%
chloropicrin
$
0.00
80%
methyl
bromide,
20%
chloropicrin
234
$
3.11
$
500.00
$
200.00
175
$
1,427.74
__%
methyl
bromide,
__%
chloropicrin
$
0.00
$
0.00
All
formulations
of
methyl
bromide
$
1,429.30
Comments:

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

If
2001
was
not
a
typical
year
for
the
individual
or
for
the
representative
user
of
a
consortium,
the
applicant
may
provide
additional
data
for
a
different
year.
However,
all
applicants
must
complete
this
worksheet
for
the
year
2001
regardless.
If
you
provide
an
additional
year's
data,
please
explain
in
the
comment
section
at
the
bottom
of
the
worksheet
why
2001
is
not
considered
a
typical
year.

If
the
methyl
bromide
is
custom
applied
then
put
the
cost
per
area
in
Column
G
and
fill
in
the
average
lb
ai
of
methyl
bromide
applied
per
area
(
Col
B)
and
the
Total
Actual
Area
Treated
(
Col
F).

Worksheet
2­
D.
Methyl
Bromide
­
Use
and
Costs
for
2001
If
a
consortium
is
submitting
this
application,
the
data
in
Cols.
B,
C,
D,
and
E
should
reflect
the
representative
user
in
the
consortium.
The
data
in
Col.
F
should
reflect
the
actual
area
treated
by
all
users
in
the
consortium.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Enter
the
appropriate
data
in
Col
B­
G
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations
of
methyl
bromide.
If
you
just
enter
data
in
the
bottom
row
in
the
table
(
All
formulations
of
methyl
bromide),
please
describe
in
the
comments,
the
relative
usage
of
the
various
formulations,
to
the
extent
known.

Enter
the
average
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied
per
area.

Enter
the
average
price
per
pound
active
ingredient
(
ai)
of
methyl
bromide
in
Col.
C
and
the
average
cost
of
applying
methyl
bromide
per
area
treated
in
Col.
D.
In
Col.
E,
enter
the
average
other
costs
per
area
associated
with
applying
methyl
bromide
(
e.
g.,
tarps).
Column
G
will
be
calculated
automatically
using
the
values
you
entered
in
columns
B­
E.
If
methyl
bromide
is
custom
applied,
enter
the
cost
per
area
in
Col.
G
and
fill
in
Cols.
B
and
F.

Enter
the
actual
area
treated.
Note:
This
number
should
be
the
total
area
treated
by
all
users
in
the
consortium.
For
EPA
Use
Only
ID#

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Acre
Labor
Cost
per
Acre
Total
Cost
per
Acre
Typical
Equipment
Used
Preplant,
Disk
and
Roll
$
6.00
$
4.00
$
10.00
Plant
Strawberry
Plants
$
25.00
$
145.00
$
170.00
Lay
Soild
Set
Pipes
$
43.00
$
43.00
Irrigate
$
145.00
$
51.00
$
196.00
Release
Predators
(
Biological
Control)
$
48.00
$
5.00
$
53.00
Rally
for
Mildew
$
8.00
$
37.00
$
45.00
Pull
Back
Runners
$
7.00
$
145.00
$
152.00
Rototil
two
times
$
17.00
$
20.00
$
37.00
Set
Runners
$
7.00
$
145.00
$
152.00
Aliette
Applications
$
32.00
$
234.00
$
266.00
Gypsum
and
Nitrogen
Applications
$
29.00
$
4.00
$
33.00
Pull
Pipe
$
5.00
$
44.00
$
49.00
Cut
tops
off
plants
$
10.00
$
10.00
$
20.00
Harvest
with
Digger
#
1
$
44.00
$
296.00
$
340.00
Fork
Lift
$
10.00
$
26.00
$
36.00
Haul
to
Trim
Shed
$
600.00
$
600.00
Custom
Trim
$
1,000.00
$
4,600.00
$
5,600.00
Haul
to
Market
$
400.00
$
400.00
Interest
on
Operating
Capital
@
8%
$
155.00
Total
Custom
per
Area
$
1,040.00
User
Total
per
area
$
8,357.00
OMB
Control
#
2060­
0482
Operation
Done
by
User
Worksheet
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Custom
Operation
Cost
per
Acre
Operations
for
California
Strawberry
Nurseries
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Do
not
include
methyl
bromide
costs.
Identify
the
typical
equipment
used
for
operations
done
by
user.
Please
be
specific,
such
as
tractor
horsepower.
No
cost
data
is
required
in
this
column.

If
you
do
not
incur
custom
operation
costs,
enter
the
material
cost
per
area.

The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.

If
you
do
not
incur
custom
operation
costs,
enter
the
labor
cost
per
area.

Enter
all
operating
costs
except
methyl
bromide
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Enter
these
costs
in
Col
B
for
custom
operations,
or
in
Col
C
and
D
for
operations
done
by
user.

Identify
in
Col
A
the
operations
(
except
methyl
bromide)
to
which
the
costs
apply.
For
growers,
these
operations
should
include
but
are
not
limited
to
(
1)
prepare
soil,
(
2)
fertilize,
(
3)
irrigate,
(
4)
plant,
(
5)
harvest,
(
6)
other
pest
controls,
etc.
You
must
include
all
other
operating
costs.

If
you
incur
custom
operation
costs,
enter
those
costs
in
Col.
B.

Submit
crop
budgets
for
each
crop,
if
available.
You
may
submit
crop
budgets
electronically
or
in
hard
copy.
If
your
costs
are
significantly
different
than
the
crop
budgets,

please
explain
in
the
comments.
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Cost
Item
Description
Allocation
Method
Cost
per
Acre
Office/
Marketing
$
333.00
Land
Lease
$
250.00
Mechanic
$
333.00
Year
1
(
Foundation
Costs)
To
produce
plants
for
next
cycle
$
1,715.00
Year
2
(
Registered
Costs)
To
produce
plants
for
next
cycle
$
5,983.00
Property
Taxes
1%
of
average
land
value
$
9.00
Property
Insurance
$
6
per
$
1,000
of
assets
over
their
useful
life
$
54.00
Investment
and
Repairs
$
25.00
Shop
$
95.00
Office
$
40,000
per
yea
are
needed
for
an
entire
farm
$
46.00
Tools
$
45.00
Wheel
Line
with
30'
spacing
to
irrigate
rotation
crop
$
255.00
Solid
Set
Pipe
36
sections
of
pipe
for
a
30'
x
40'
spacing
$
266.00
3
Leased
Pickups
$
220.00
Quad
Runner
$
18.00
Equipment
$
1,350.00
Total
$
10,997.00
Comments:

OMB
Control
#
2060­
0482
Worksheet
2­
F.
Methyl
Bromide
Fixed
and
Overhead
Costs
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,
(
4)

management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.

Enter
all
fixed
and
overhead
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Worksheet
Title
3­
A
Alternatives
­
Technical
Feasibility
This
form
is
used
to
obtain
information
on
the
chemical
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
that
are
registered
for
use
in
the
United
States,
as
well
as
the
non­
chemical
alternatives
identified
by
the
MBTOC.
Applicants
must
address
the
technical
feasibility
of
all
the
chemical
and
non­
chemical
alternatives
identified
on
the
list.

3­
B
Alternatives
­
Pest
Control
Regimen
Costs
This
form
is
used
to
estimate
the
cost
of
using
alternative
pest
control
regimens.

3­
C
Alternatives
­
Crop/

Commodity
Yield
and
Gross
Revenue
This
form
is
used
to
estimate
the
crop/
commodity
yields
and
gross
revenues
when
using
alternative
pest
control
regimens.

3­
D
Alternatives
­
Changes
in
Other
Costs
This
form
is
used
to
estimate
change
in
any
other
costs
as
a
result
of
using
the
alternatives.

Complete
each
of
the
worksheets
below
(
3­
A,
3­
B,
3­
C,
and
3­
D)
for
each
alternative
pest
control
regimen
listed
in
the
"
U.
S.
Matrix"
for
chemical
controls
(
www.
epa.
gov/
ozone/
mbr/
cueqa.
html)
and
the
"
International
Matrix"
for
non­
chemical
pest
controls
(
www.
epa.
gov/
ozone/
mbr/
cue).
Each
worksheet
contains
a
place
holder
in
the
title
for
you
to
insert
the
name
of
the
specific
alternative
pest
control
regimen
addressed.
You
should
add
additional
worksheets
as
required.
Please
add
a
number
designation
to
each
worksheet
title
to
indicate
a
different
alternative.
For
example,
for
the
first
alternative
pest
control
regimen
label
the
worksheets
as
3­
A(
1),
3­
B(
1),
3­
C(
1),
and
3­
D(
1).
For
the
second
alternative
pest
control
regimen
label
the
worksheets
3­
A(
2),
3­
B(
2),
3­
C(
2),
and
3­(
D)(
2).

Purpose
of
Data
on
Alternative
Pest
Control
Regimens:
To
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available.
EPA
needs
to
compare
data
(
yields,
crop/
commodity
prices,
gross
revenues
and
costs)
on
the
use
of
methyl
bromide
and
alternative
pest
control
regimens.

Worksheet
3.
Alternatives
­
Feasibility
of
Alternative
Pest
Control
Regimens
Enter
all
alternative
pesticides
and
pest
control
methods
(
and
associated
cost
and
yield
data)
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
fumigation
cycle
worksheet
for
a
comprehensive
definition.
Telone,
Telone
+
Metam
Sodium
and
Telone
+
Chloropicrin
+
Metam
Sodium
for
Use
as
an
Alternative
Fumigant
in
California
Strawberry
Nurseries
California
strawberry
nurseries
participate
in,
and
are
regulated
by
the
California
Department
of
Food
and
Agriculture
strawberry
certification
program.
This
program
requires
that
ground
be
fumigated
before
mother
plants
are
placed
in
the
field
(
2).
The
certification
standards
further
require
that
all
nursery
stock
be
kept
commercially
clean
of
insects,
pests
and
diseases.
Nursery
stock
must
be
free
of
nematodes
as
per
section
3055.1­
3055.6
of
the
nursery
stock
nematode
certification
regulations.
California
strawberry
varieties
account
for
more
than
50%
of
the
world
strawberry
acreage.
California
strawberry
nurseries
provide
planting
stock
for
other
nurseries
worldwide
(
see
Strawberry
Nursery
Narrative).
There
are
wide
and
specific
destination
quarantine
restrictions
to
be
met
for
shipping
planting
stock
outside
the
United
States,
which
include
most
of
the
identified
fungal
pathogens
and
nematodes
that
can
infect
strawberry.

Studies
have
been
done
in
the
California
strawberry
nurseries
with
Telone
and
Telone/
Metam
Sodium
(
23,
36),
Telone/
Chloropicrin
(
grower
studies),
and
Chloropicrin
alone
(
23).
Studies
evaluating
all
the
above
combinations
have
been
conducted
in
strawberry
fruit
production
fields
in
California
and
in
Canadian
strawberry
nursery
fields.
One
draw
back
for
most
of
the
studies
in
strawberries
and
other
commodities
is
that
the
studies
have
been
conducted
on
ground
previously
fumigated
with
MeBr
(
18).
This
makes
the
long
term
use
of
the
alternatives
difficult
to
predict,
as
the
alternatives,
do
not
penetrate
the
soil
as
readily
as
Methyl
Bromide
(
6)
and
do
not
deliver
the
deep
soil
control
now
obtained
with
Methyl
Bromide
in
nursery
crops
(
6,
26,
27).
Many
of
the
studies
have
been
conducted
in
areas
with
low
pest
and
disease
pressure
(
18,
25),
and
it
is
necessary
to
test
the
alternatives
under
high
disease
pressure
conditions
to
evaluate
the
true
effectiveness
and
long
term
viability
of
each
alternative
regime.
As
an
example,
Canadian
nursery
fumigation
trials
are
generally
based
on
single
year
increases
of
California­
provided
source
stocks
that
have
been
fumigated
with
Methyl
Bromide.

California
strawberry
nurseries
must
control
all
nematodes,
and
the
complete
range
of
pathogens
to
ensure
that
strawberry
fruit
growers
receive
stock
free
of
pests
and
diseases
(
18,
23).
When
fruit
growers
receive
healthy
nursery
stock,
little
is
required
in
the
form
of
pest
control
during
the
fruiting
cycle
(
18).

Strawberries
respond
with
increased
plant
vigor
when
fungal
diseases
are
highly
controlled.
When
fungal
diseases
are
controlled
by
fumigation,
plants
show
an
increase
in
shoot
growth,
berry
yield,
and
root
development
when
compared
to
plants
produced
from
non­
fumigated
soil
were
fungal
pathogens
not
controlled
(
12).

Production
Yield
Factors:

In
studies
that
have
been
done
at
the
nursery,
Telone
fumigated
soils
did
not
produce
as
many
runners
per
mother
plant
(
5,
23),
nor
as
many
marketable
plants
per
acre
as
soils
fumigated
with
methyl
bromide
(
14).
Telone/
Metam
Sodium
combination
studies
have
also
shown
reduced
numbers
of
runner
plants
produced
per
acre
in
comparison
to
a
standard
Methyl
Bromide/
Chloropicrin
fumigation
(
5).

A
complex
study
was
undertaken
by
the
University
of
California,
Davis
in
cooperation
with
nursery
and
fruit
growers
to
study
the
effect
of
fumigation
from
one
production
cycle
to
the
next.
Plants
from
various
fumigation
regimes
at
low
elevation
nursery
fields
were
increased
the
following
year
in
high
elevation
nurseries
with
multiple
fumigation
regimes.
These
plants
were
moved
into
fruit
production
fields
with
treated
with
various
fumigation
regimes.
While
the
latest
fumigations
had
the
largest
effect
on
the
actual
fruit
yield,
there
was
still
a
significant
benefit
when
Methyl
Bromide
fumigation
was
used
in
the
low
elevation
nursery
two
years
earlier
vs.
the
use
of
any
other
alternative
(
23).

In
another
study,
Methyl
Bromide
not
only
gave
better
overall
nursery
runner
production
than
stocks
fumigated
with
Telone
in
the
nursery,
but
also
yielded
higher
fruit
production
when
transplanted
into
fruiting
fields,
suggesting
the
carryover
benefit
of
Methyl
Bromide
fumigation
in
nursery
culture
(
16).
This
has
also
been
the
case
when
Chloropicrin
has
been
used
as
a
nursery
fumigant
(
23).

Repeated
uses
of
Telone
in
fruit
production
test
plots
resulted
in
declining
yield
each
season
in
relation
to
the
Methyl
Bromide/
Chloropicrin
treated
plots
(
35).
In
this
same
study,
using
Chloropicrin
in
combination
with
Telone
did
not
increase
yield
relative
to
Telone
used
alone.
Growers
have
also
reported
less
consistent
yield
and
weed
control
with
the
alternative
fumigants,
including
Telone,
as
compared
to
Methyl
Bromide
(
25).

Control
of
Nematodes:

Control
of
nematodes
is
essential
to
strawberry
producers.
The
California
nursery
stock
nematode
certification
regulations
require
that
nursery
stock
be
free
of
nematodes.
In
order
to
achieve
this,
nematodes
must
be
controlled
in
the
soil
to
a
level
of
99.9%
(
26,
27).
Control
needs
to
be
achieved
at
the
level
of
approaching
3
feet
in
order
to
produce
clean
strawberry
planting
stock.
While
Telone,
and
Telone
combinations
have
been
effective
in
controlling
nematodes
in
some
cases
(
3),
in
an
on­
going
strawberry
nursery
study
Telone
did
not
control
free
living
nematodes
in
the
first
6"
of
soil,
while
methyl
bromide
controlled
citrus
nematode
and
all
free
living
nematodes
to
a
depth
of
36"
(
14).

Telone
in
combination
with
Chloropicrin
was
less
effective
than
methyl
bromide
in
controlling
root
knot
nematodes
in
tomatoes
in
Florida
(
19).
In
other
nursery
crop
studies,
Telone
has
shown
control
in
some
cases
where
the
soil
is
light
and
shallow
(
3),
but
this
is
not
always
the
case
(
21).
Strawberry
nurseries
require
a
fumigant
that
can
give
very
deep,
extremely
consistent
control
of
nematodes
over
time.
Alternative
fumigants
and
alternative
combinations
in
test
results
to
date
have
not
consistently
demonstrated
this
level
of
control.

Control
of
Pathogens:

An
equally
important
aspect
of
nursery
production
is
maintenance
of
pathogen
free
stock.
Complete
control
of
the
full
spectrum
of
pathogenic
fungi
is
a
life
or
death
issue
in
strawberry
nursery
culture.
Telone
does
control
fungi
or
insects
(
6)
and
therefore
is
not
of
use
to
the
strawberry
nurseries
as
a
stand­
alone
fumigant.

Verticillium
wilt
is
historically
one
of
the
main
pathogens
affecting
strawberry
production
in
California.
The
sclerotia
are
extremely
long
lived
in
the
soil
and
can
remain
viable
for
up
to
20
years
(
6).
Added
to
this,
very
low
levels
of
infections
(
0.5
ms/
g
soil)
can
result
in
significant
disease
levels
(
13a).
Control
of
Verticillium
dahliae
in
the
strawberry
nurseries
has
been
most
effective
with
Methyl
Bromide/
Chloropicrin
fumigations.
While
Methyl
Bromide/
Chloropicrin
fumigations,
killed
all
buried
inoculum
at
15
and
50
cm
depths
(
at
these
depths
Phytophthora
cactorum
was
also
completely
controlled),
Telone
reduced
the
level
of
Verticillium
dahliae
but
did
not
completely
eliminate
the
pathogen
at
any
depth
(
11,
14)
or
only
in
the
top
few
inches
(
18).
These
results
have
been
verified
in
other
locations
(
28)
where
Telone/
Chloropicrin
combinations
did
not
control
the
soil
pathogens
at
deeper
soil
depths.
While
VIF
films
improved
the
efficacy
of
Telone,
Methyl
Bromide/
Chloropicrin
fumigation
was
still
superior
in
control
of
both
Verticillium
and
Phytophthora
(
10,
28).
Control
of
Phytophthora
cactorum
at
the
nurseries
and
commercial
fruiting
field
sites
with
either
Telone
or
Telone/
Chloropicrin
combinations
have
been
inconsistent
and
appear
to
be
sensitive
to
rates,
mulching
systems
and
the
emulsifiers
used
in
the
drip
formulations
(
7).
Methyl
Bromide/
Chloropicrin
typically
killed
all
the
Phytophthora
at
a
depth
of
1.5
to
2
feet,
while
the
results
with
Telone
mixtures
were
not
consistently
lethal
(
8)
or
only
lethal
in
the
top
6"
of
the
field
(
14).

In
other
studies
Methyl
Bromide/
chloropicrin
controlled
Phytophthora
cactorum
as
deep
as
36",
well
exceeding
the
performance
of
Telone
(
14).
Telone
has
also
been
less
effective
in
controlling
the
other
important
pathogens,
Colletotrichum
acutatum
(
18),
Fusarium
oxysporum
,
Rhizoctonia
solani
,
Sclerotinia
sclerotiorum
(
28).

Control
of
Weeds:

Weeds
compete
with
the
strawberry
plants
in
nursery
and
production
fields.
Noxious
weeds
must
be
controlled
at
nursery
locations
to
prevent
unintential
shipment
of
weed
seed
adhering
to
plant
parts
to
new
locations.
While
Telone
and
Telone
combinations
have
been
effective
in
controlling
the
weed
populations
in
the
nurseries
in
Nova
Scotia
(
MBTOC,
1998,
20),
these
alternatives
have
only
been
somewhat
effective
in
controlling
the
spectrum
of
weeds
found
in
the
California
strawberry
nurseries
(
36),
California
fruit
production
fields
(
15,
30)
and
in
Florida
tomato
fields
(
19).
At
the
nursery,
tarping
improved
the
performance
of
all
fumigants
tested
(
36).
In
these
same
studies,
Metam
Sodium
alone
did
not
provide
effective
surface
weed
control,
but
Telone
alone
or
in
combination
with
Metam
Sodium
provided
good
weed
control
if
the
treatments
were
tarped
(
36).
Telone
has
been
effective
in
controlling
chickweed,
hairy
nightshade,
pigweed
and
annual
bluegrass.
It
was
less
effective
then
Methyl
Bromide
in
controlling
purslane
and
prostrate
(
15).
The
addition
of
Metam
Sodium
in
association
with
Telone
did
not
improve
weed
control
over
the
use
of
Telone
alone
(
14).
Neither
Methyl
Bromide/
Chloropicrin
nor
Telone
(
alone
or
in
combination
with
Chloropicrin
and
Metam
Sodium)
were
effective
in
controlling
little
mallow
(
15).
Shank
applied
Telone
(
the
method
of
application
most
applicable
to
nursery
culture),
resulted
in
higher
weeding
costs
in
production
fields
(
14).
This
has
been
verified
by
studies
conducted
by
individual
California
nurseries.

Telone
Township
Caps:

There
are
township
caps
limiting
the
amount
of
Telone
that
can
be
applied
in
any
given
year
in
a
particular
township
due
to
potential
problems
with
air
quality
standards.
These
townships
caps
would
be
a
problem
in
both
high
and
low
elevation
nursery
locations,
since
the
area
in
which
strawberry
nurseries
are
gown
is
fairly
restricted
thus
they
are
concentrated
in
particular
townships
that
would
be
impacted
(
9,
32,
33).
Telone
also
requires
a
300"
buffer
zone
around
the
application
area,
which
reduces
the
actual
field
area
that
can
be
fumigated
using
this
product.

Movement
of
Fumigant
through
the
soil:
Where
Telone
has
been
shown
to
have
deep
efficacy,
the
soils
tend
to
be
light
and
sandy
(
26,
27,
28).
Since
the
molecular
structure
of
Methyl
Bromide
is
small
relative
to
the
molecular
structure
of
Telone,
Methyl
bromide
can
move
more
easily
through
the
soil
and
this
results
in
deeper
penetration
of
the
fumigant
(
6).
In
order
for
Telone
applications
to
be
effective,
the
soil
moisture
level
should
not
exceed
12%.
In
heavy
rainfall
years
and
deeper
in
the
soil
profile,
this
can
be
difficult
to
achieve
(
26,
27).
The
problem
is
amplified
by
the
California
requirement
that
moisture
be
added
to
the
surface
of
the
soil
prior
to
fumigation
with
Telone.

Other
Effects
of
Alternative
Fumigants:

Phytotoxic
effects
have
been
noted
with
higher
rates
of
Telone
(
21).
In
strawberry
production
fields,
when
Metam
sodium
was
applied
at
the
same
time
as
Telone
there
was
a
negative
interaction
(
34).
Results
have
been
improved
with
sequential
application
of
the
materials,
but
this
increases
the
amount
of
time
required
to
complete
the
fumigation
cycle.
When
the
strawberry
nurseries
fumigate
in
the
spring,
there
is
a
small
window
of
opportunity
to
fumigate
and
plant.
For
this
fumigation,
it
is
necessary
to
have
a
fumigant
that
can
be
applied
quickly
with
short
plant
back
requirements.
In
high
elevations
nurseries,
it
is
impossible
to
string
treat
with
Telone
or
Metam
Sodium
combinations
due
to
cold
soil
temperatures
and
higher
deep
moisture
levels
in
the
soil.

Use
of
Non­
Chemical
Alternatives:

The
non­
chemical
alternatives
included
for
consideration
include:
Biofumigation,
Solarization,
Steam
Heat,
BioControl,
Cover
crop/
Mulch,
Crop
Rotation,
Flood
and
Water
Management,
Graft
Resistant
Rootstocks,
Organic
Amendments,
Physical
Removal/
Sanitation,
Resistant
Cultivars,
Soilless
culture,
and
Substrates/
plug
plants.
None
of
these
alternatives
meet
the
requirements
of
the
California
Department
of
Food
and
Agriculture
nursery
stock
certification
program.
While
nurseries
have
spent
time
and
money
exploring
the
alternatives
(
both
chemical
and
non­
chemical),
they
have
not
found
any
alternatives
that
can
provide
the
high
level
of
cleanliness
for
nematodes,
pathogens
and
weeds
that
are
required
for
nursery
culture.

California
strawberry
nursery
growers
do
use
cover
crops
as
part
of
their
rotation
program
to
provide
a
non­
host
period
for
nematodes
and
pathogens
and
to
increase
the
organic
matter
in
the
soil.

While
ongoing
breeding
efforts
continue
in
California,
and
commercially
viable
strawberry
cultivars
used
in
California
differ
in
their
susceptibility
to
Verticillium
wilt
and
Phytophthora
induced
diseases,
none
of
these
cultivars
is
completely
resistant.
Since
strawberries
are
octopolids,
breeding
for
resistance
while
maintaining
yield
and
fruit
quality
characteristics
is
an
extremely
long­
term
process.

It
would
not
be
possible
to
produce
the
nearly
1
billion
plants
currently
produced
in
the
strawberry
nurseries
in
non­
soil
media
since
the
cost
associated
with
the
necessary
greenhouse
space
would
be
astronomical.
The
high
elevation
nurseries
provide
natural
chilling
to
induce
dormancy
in
the
plants
before
strawberry
plants
are
shipped
to
fruit
producers.
It
would
be
impossible
to
artificially
reproduce
these
conditions
in
a
greenhouse
environment.

Conclusions:

While
Telone
and
Telone
combinations
may
be
viable
options
for
some
commodities,
data
strongly
suggests
this
is
not
the
case
with
strawberry
nurseries.
The
uncertainly
and
erratic
control
of
pathogens
and
nematodes
currently
seen
with
Telone
and
Telone
mixtures
render
them
as
an
unstable
long
term
option
for
the
strawberry
nursery
industry.

It
is
imperative
that
California
strawberry
nurseries
have
clean,
pathogen
and
pest
free
stock
to
distribute
not
only
to
the
California
fruit
producers
(
both
conventional
and
organic
growers)
but
also
to
fruit
and
nursery
producers
worldwide.

California
strawberry
nurseries
are
not
attempting
to
suppress
levels
of
pathogens
and
nematodes,
but
are
trying
to
completely
eliminate
nematodes
and
pathogens
from
the
nursery
stock.
The
fact
that
successful
commercial
production
depends
on
pest
and
disease
free
planting
stock
is
a
universally
demonstrated
fact.
The
necessity
of
utilizing
methyl
bromide
to
produce
this
clean
planting
stock
has
been
recognized
by
the
Methyl
Bromide
Technical
Options
Committee
of
the
United
Nations
Environment
Program
(
1998).

More
time
and
research
are
required
to
find
a
technology
that
can
be
used
to
provide
the
same
level
of
cleanliness
from
nematodes,
pathogens,
and
weeds
currently
realized
with
the
use
of
Methyl
Bromide
as
a
fumigant
in
California
strawberry
nurseries.

References:
The
following
references
are
from
the
EPA
website:
3,
4,
9,
13,
14,
19,
20,
21,
22,
24,
25,
28,
29,
and
34.
1)
California
Management
Plan:
1,3­
Dichloropropene.
Department
of
Pesticide
Regulation.
January
30,
2002.
2)
California
Department
of
Food
and
Agriculture.
Summary
of
California
Laws
and
Regulations
Pertaining
to
Nursery
Stock.
3)
Replacing
Methyl
Bromide
for
Preplant
Soil
Fumigation
with
Telone,
Chloropicrin
and
Tillam
Combination
Treatments.
U.
S.
Environmental
Protection
Agency.
From
EPA
Website.
4)
Distribution
of
Drip
Applied
Fumigants
Under
Various
Conditions.
H.
Ajwa
and
T.
Trout.
From
EPA
Website.
5)
Strawberry
Growth
and
Yield
with
Three
Years
of
Drip
Fumigation.
H
Ajwa
and
T.
Trout.
Report
to
the
California
strawberry
commission
Feb.
13,
2001
and
presented
at
the
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
6)
Options
to
Methyl
Bromide
for
the
Control
of
Soil­
Borne
Disease
and
Pests
in
California.
A.
Braun
and
D.
Supkoff.
July
1994.
Pest
Management
Analysis
and
Planning
Program.
California
Department
of
Pesticide
Regulation.
7)
Outlook
for
Managing
Phytophthora
Diseases
on
California
Strawberries
without
methyl
Bromide.
G.
Browne,
et
at.
8)
Strategies
for
Management
of
Phytophthora
on
California
Strawberries.
G.
Browne
et
al.
California
Strawberry
Commission
Pink
Sheet
#
02­
09.
March
19,
2002.
9)
Impact
of
1,3­
D
Restrictions
in
California
after
a
Ban
on
Methyl
Bromide.
J.
Carpenter
and
L.
Lynch.
From
EPA
Website.
10)
Chemical
and
Cultural
Alternatives
to
Methyl
Bromide
Fumigation
of
Soil
for
Strawberry:
Research
Progress
Report,
Spring
2002.
J.
Duniway
et
al.
Report
to
the
California
Strawberry
Commission.
11)
Chemical
and
Cultural
alternatives
to
Methyl
Bromide
Fumigation
of
Soil
for
Strawberry.
J
Duniway
et
al.
12)
Microbial
Mechanisms
of
Growth
and
Yield
Responses
to
Soil
Fumigation
in
Strawberry.
Duniway
et
al.
Report
to
California
Strawberry
Commission.
13)
Some
Chemical,
Cultural,
and
Biological
Alternatives
to
Methyl
Bromide
Fumigation
of
Soil
for
Strawberry.
Duniway
et
al.
From
EPA
Website,
2000
2001
Annual
International
Research
Conference
of
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
13a)
Cultural
Practices
for
Managing
Verticillium
Wilt.
J.
M.
Duniway
et
al.
Report
to
California
Strawberry
Commission.
14)
Alternative
fumigants
for
control
of
soil
pests:
strawberry
as
a
model
system.
S.
Fennimore,
J.
Duniway
et
al.
2001
Annual
International
Research
Conference
of
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
15)
Weed
Control
Options
in
California
Strawberry
without
methyl
Bromide.
S.
Fennimore
et
al.
16)
Summary
of
Recent
Research
on
Verticillium
wilt
in
High
Elevation
Strawberry
Nurseries.
T.
Gordon
et
al.
Report
to
California
Strawberry
Commission.
March
10,
1999.
17)
Management
of
Verticillium
Wilt
in
High
Elevation
Strawberry
Nurseries.
T.
Gordon
et
al.
Report
to
California
Strawberry
Commission.
June
27,
2000
18)
Chemical
Alternatives
to
Methyl
Bromide
Fumigation
 
How
Well
do
They
Work?
W.
Gubler
et
al.
19)
Metam
Sodium
and
Metam
Combinations
as
a
Viable
Replacement
for
Methyl
Bromide.
W.
Haglund.
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
20)
Results
of
Alternative
Applications
on
Weed
Control
in
a
Strawberry
Nursery.
C.
Keddy
et
at.
1997
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
21)
1,3
D,
A
Valid
Alternative
to
Methyl
Bromide
for
Control
of
Plant
Parasitic
Nematodes.
F.
Lamberti
et
al.
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
22)
Nursery
Soil
Fumigation
Regime
Affects
Strawberry
Transplant
Production,
Transplant
Size,
and
Subsequent
Fruit
Yield.
K.
Larsen.
1997
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
23)
Soil
Fumigation
and
Runner
Plant
Production:
A
Synthesis
of
four
Years
of
Strawberry
Nursery
Field
Trials.
K.
Larsen
et
al.
HortScience,
July
2000,
35(
4):
642­
646.
24)
Management
of
Root
disease
of
Strawberry.
F.
Martin.
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
25)
Strawberry
Production
with
Methyl
Bromide
Alternatives:
A
Farmer's
Perspective.
C.
Martinez
et
al.
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
26)
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries.
M.
McKenry
et
al.
Report
to
California
Department
of
Pesticide
Regulation,
March
31,
2001.
27)
The
Replant
Problem
and
Its
Management.
M.
McKenry.
July
1999.
Catalina
Publishing.
124
pgs.
28)
Application
of
Chloropicrin
+
1,3
Dichloropropene
through
Soil
Injection
in
North
Italy.
A.
Minuto
et
al.
.
2000
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
29)
Methyl
Bromide
for
Preplant
Soil
Disinfestation
in
Temperate
Horticultural
Crops
in
Australia
in
Perspective.
I.
Porter
et
al.
1997
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emission
Reductions.
From
EPA
Website.
30)
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation.
A.
Paulus
et
al.
California
Strawberry
Commission
Pink
sheet.
January
8,
1998.
31)
A
Meta­
analysis
of
Strawberry
Yield
Response
to
Preplant
Soil
Fumigation
wit
combinations
of
Methyl
Bromide­
chloropicrin
and
Four
Alternative
Systems.
D.
Shaw
et
al.
HortScience,
August
1999
34(
5):
839­
845.
32)
Impact
of
Township
Caps
on
Telone
Use
in
California.
T.
Trout.
California
Strawberry
Commission
Pink
Sheet,
June
11,
2001.
33)
Township
Limits
on
1,3­
D
Will
Impact
Adjustment
to
Methyl
Bromide
Phase­
out.
T.
Trout
et
al.
California
Agriculture.
2001.
55(
3):
1218.
34)
Strawberry
Response
to
Fumigants
Applied
by
Drip
Irrigation
Systems.
T.
Trout
et
al.
1999
Annual
International
Research
Conference
on
methyl
Bromide
Alternatives
and
Emissions
Reductions.
From
EPA
Website.
35)
Soil
Fumigation
with
Telone.
N.
Welch
et
al.
California
Strawberry
Commission
Pink
Sheet.
December
16,
1991.
36)
Unpublished
data
from
on
going
research
trial
at
Shasta
Nursery.
Dr.
Becky
Westerdahl,
Dr.
Bill
Haglund,
Dr.
Mike
McKenry.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
X
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.

BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
alternative
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
rates,
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
of
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.

The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websites
for
studies
that
pertain
to
your
crop
and
geographic
area.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.

Telone
+
Chloropicrin
Soil
Fumigation
and
Runner
Plant
Production:
A
Synthesis
of
Four
Years
of
Strawberry
Nursery
Field
Trials
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
x
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
x
No
7.

8.

OMB
Control
#
2060­
0482
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.

For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Kirk
D.
Larsen
and
Douglas
V.
Shaw
HortScience,
Vol.
35(
4),
July
2000
Multiple
Nursery
Locations
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Telone
+
Chloropicrin
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Methyl
bromide
+
Chloropicrin
produced
more
runner
plants
per
mother
plant
(
higher
yield)
then
did
the
Telone
+
Chloropicrin
combination.

It
appears
that
the
decrease
in
yield
is
cummulative
and
will
follow
the
plant
from
the
low
elevation
fields
to
the
high
elevation
fields
causing
a
larger
overall
decline
in
the
number
of
runner
plants
produced
per
mother
plant.

It
is
unclear
how
the
continued
use
of
this
product
on
the
same
piece
of
ground
will
further
impact
yield.
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?

In
order
for
nurseries
to
remain
economically
viable,
it
is
important
for
the
nursery
to
maintain
adequate
yields.
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:

Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
DEFGHIJKL
MNO
P
Pest
1
Pest
2
Inte
rval
Rati
ng
Inte
rval
Rati
ng
Inte
rval
Rati
ng
Inte
rval
Rati
ng
Inte
rval
Rati
ng
Inte
rval
Rati
ng
1
Methyl
Bromide/
Chloropicrin
67/
33
392
kg/
ha
39.2
a
2
Telone/
Chloropicrin
30/
70
448
kg/
ha
35.8
ab
3
Telone/
Chloropicrin
70/
30
516
kg/
ha
33.0
bc
Comments:

Visual
observations
of
weed
control
in
this
study
indicate
that
all
alternative
treatments
had
higher
levels
of
weeds
then
the
Methyl
Bromide/
Pic
standard.

OMB
Control
#
2060­
0482
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
List
what
type
of
pest
control
method
was
used.

Effects
of
the
fumigation
treatment
from
one
growing
cycle
to
another
(
low
plants
moving
to
high
elevation),
appear
to
be
additive
so
that
the
loss
of
yield
is
cummulative
between
cycles.

Use
of
Telone+
Pic
(
with
the
high
rate
of
Pic)
resulted
in
8.6%
fewer
runners.
The
effect
with
higher
Telone
vs.
Pic
was
even
more
pronounced.

Treatment
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
runners
per
mother
plant)

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Research
Summary
Table
Telone
+
Chloropicrin
Soil
Fumigation
and
Runner
Plant
Production:
A
Synthesis
of
Four
Years
of
Strawberry
Nursery
Field
Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
over
the
words
"
Rating
Interval
1"
with
"
pre­
treatment",
type
over
"
Rating
Interval
2"
with
"
3
weeks",
and
type
over
"
Rating
Interval
3"
with
"
6
weeks."
If
you
are
completing
the
printed
version,
please
define
Rating
Interval
in
the
Provide
one
summary
table
for
each
study
being
described.

Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.
Ideally,
a
research
study
should
directly
compare
methyl
bromide
and
the
alternative
regimen.

List
the
treatment
number
from
the
research
study
you
are
citing.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
X
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Brom
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
re
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agenc
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Pleas
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
a
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).

BACKGROUND
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
a
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
fo
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
releva
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Su
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.

This
study
is
not
yet
published
as
i
research
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.

The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progr
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websi
studies
that
pertain
to
your
crop
and
geographic
area.
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
use
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
1996.

Telone,
Telone+
Metam
Sodium
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
x
No
Yield
results
not
yet
available,
plants
will
be
dug
in
October
2002.

7.

8.

OMB
Control
#
2060­
0482
approved
alternative
for
certified
nursery
use,
but
that
the
alternative
does
not
increase
the
nursery
operating
For
EPA
Use
Only
ID#

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Weed
control
and
deep
nematode
control
are
important
issues
for
strawberry
nursery
growers.
It
is
important
that
the
alternative
choosen
is
not
only
approved
by
the
California
Department
of
Food
and
Agriculture
as
a
viable,
on
going
research,
not
yet
published
Malin,
Oregon
in
cooperation
with
Shasta
Nursery
Telone,
with
and
without
tarps
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Brom
costs
or
reduce
the
overall
nursery
yield.
The
effect
of
Telone,
with
or
with
out
Metam
Sodium
and
with
or
without
tarps
was
studied.
Preliminary
results
on
the
numbe
nematodes
in
50
grams
of
soil
at
various
depths
as
well
as
weed
germination
results
are
presented.

Methyl
bromide
is
more
effective
in
controlling
the
pests
in
this
study
although
Telone
did
a
fair
job
on
controlling
nematodes
While
tarping
increased
the
effectiveness
of
metam
sodium
(
in
combinatin
with
Telone)
for
weed
control,
Methyl
bromide
was
effective.
Dr.
Becky
Westerdahl,
Dr.
Bill
Haglund,
Dr.
Mike
McKenry
Telone
+
Metam
Sodium,
with
and
without
tarps
romide
research
has
ncy
and
ase
number
me
el
the
d
alternative,

5,
and
8.
)
is
or
is
not
for
each
vant
Summary
s
it
is
ongoing
n
a
ion
rates,
ss
of
gress.
EPA
bsites
for
sed
ible
alternative
romide
ber
of
as
still
more
Alternative:
Study:
Dr.
Bill
Haglund,
Dr.
Becky
Westerdahl,
Dr.
Mike
McKenry
Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:

Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
DE
FGH
I
J
K
L
MNO
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Please
See
Attached
Page
Comments:

OMB
Control
#
2060­
0482
Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,
etc.).

Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
should
directly
compare
methyl
bromide
and
the
alternative
regimen.

List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
over
the
words
"
Rating
Interval
1"
with
"
pre­
treatment",
type
over
"
Rating
Interval
2"
with
"
3
weeks",
and
type
over
"
Rating
Interval
3"
with
"
6
weeks."
If
you
are
completing
the
printed
version,
please
define
Rating
Interval
in
the
comments
below.

unpublished,
on­
going
research
from
2001­
2002
study
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

Telone,
Telone
+
Metam
Sodium
Provide
one
summary
table
for
each
study
being
described.
Alternative:
Telone,
Telone/
Metam
Sodium
Study:
Unpublished,
Ongoing
Research
from
2001­
2002
Dr.
Becky
Westerdahl,
Dr.
Bill
Haglund,
Dr.
Mike
McKenry
Telone
gallons
per
acre
Metam
Injected
gallons
per
acre
Metam
rototilled
gallons
per
acre
Tarped
0­
3
inche
s
3­
6
inche
s
6­
12
inche
s
12­
18
inche
s
Weeds
from
weed
seed
tapes
placed
at
different
depths
Surface
Weed
Treatment
Weeds/
Acr
0
30
30
No
112
54
86
52
162
0
30
30
Yes
56
256
84
10
0
0
30
40
No
0
0
0
4
0
0
30
40
Yes
0
62
0
0
0
0
40
30
No
0
0
0
60
G
erm
at
0­
8"
and
16­
3
27
0
40
30
No
28
0
0
0
Germ
at
4­
8"
and
18­
3
36
0
40
30
No
42
0
0
0
Germ
at
22­
32"
144
0
40
30
No
2
0
0
0
Germ
at
21­
32"
63
0
40
30
Yes
6
0
0
0
Germ
at
22­
32"
0
0
40
30
Yes
6
0
64
14
Germ
at
20­
32"
0
0
40
30
Yes
16
156
210
18
Germ
at
22­
32"
0
0
40
30
Yes
0
0
80
18
No
Germ
0
20
0
0
No
28
0
0
0
No
Germ
1215
20
0
0
Yes
10
0
4
0
No
Germ
0
20
0
30
No
0
0
0
0
No
Germ
72
20
0
30
Yes
1
0
0
0
No
Germ
0
20
0
40
No
36
0
0
0
198
20
0
40
Yes
1
0
0
0
0
20
30
30
No
0
0
0
0
No
Germ
90
20
30
30
Yes
0
0
0
0
No
Germ
0
20
30
40
No
20
0
0
0
Germ
at
0­
20"
­
20
30
40
Yes
0
0
0
0
No
Germ
0
20
40
30
No
2
0
0
0
No
Germ
117
20
40
30
Yes
0
0
0
0
No
Germ
0
35
0
0
No
86
0
0
0
No
Germ
2244
35
0
0
Yes
8
0
0
0
No
Germ
0
35
0
30
No
0
0
0
0
9
35
0
30
Yes
0
0
0
0
No
Germ
0
35
0
40
No
0
0
0
0
81
35
0
40
Yes
0
0
0
0
0
35
30
30
No
10
0
0
0
No
Germ
9
35
30
30
Yes
12
4
0
0
No
Germ
0
35
30
40
No
4
0
0
0
No
Germ
153
35
30
40
Yes
0
0
0
0
No
Germ
0
35
40
30
No
0
0
0
0
90
35
40
30
Yes
0
0
0
0
0
Fall
MB
No
0
0
0
0
No
Germ
0
Fall
MB
No
0
0
0
0
No
Germ
0
Fall
MB
No
2
0
0
0
No
Germ
0
Fall
MB
No
0
0
0
0
No
Germ
0
Fall
MB
Yes
0
0
0
0
No
Germ
0
Fall
MB
Yes
0
0
0
0
No
Germ
0
Fall
MB
Yes
0
0
0
0
No
Germ
0
Fall
MB
Yes
0
0
0
0
No
Germ
0
Non­
Fume
No
1212
710
664
550
24000
Non­
Fume
No
1220
716
542
194
24000
Non­
Fume
No
840
686
462
132
24000
Non­
Fume
No
1184
684
536
468
24000
Non­
Fume
No
446
442
624
380
24000
Non­
Fume
No
264
308
534
116
24000
Non­
Fume
No
1430
1456
632
244
24000
Non­
Fume
No
1136
1184
648
464
24000
Non­
Fume
Yes
98
548
422
240
2700
Non­
Fume
Yes
336
284
240
184
2700
Non­
Fume
Yes
52
292
394
100
2700
Non­
Fume
Yes
62
302
332
338
2700
Non­
Fume
Yes
82
464
472
270
2700
Non­
Fume
Yes
20
200
312
112
2700
Non­
Fume
Yes
244
508
548
166
2700
Non­
Fume
Yes
88
338
362
312
2700
Number
of
Nematodes
in
50
grams
of
soil
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:

Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­

O):
Col.
J:
Yield
A
B
C
DE
F
GH
I
J
K
L
M
NO
P
Sting
nematode
Stunt
nematode
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
Interval
3
1
Untreated
­
pre­
trt
700
3
wks
700
6
wks
707
pre­
trt
100
3
wks
111
6
wks
109
5,000
2
Methyl
Bromide
300
gal.
pre­
trt
669
3
wks
221
6
wks
120
pre­
trt
98
3
wks
77
6
wks
36
8,000
3
Iodo
methane
150
gal.
pre­
trt
675
3
wks
250
6
wks
125
pre­
trt
111
3
wks
35
6
wks
32
7,580
Comments:

Ratings
are
for
nematodes
per
gram
of
soil
OMB
Control
#
2060­
0482
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Treatment
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)
Yield
(
lbs/
acre)

Enter
the
intervals
(
days,
weeks
or
months)
that
the
rating
was
taken
for
each
treatment
in
Columns
D,
F,
H,
J,
L,
and
N.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
For
this
example,
insert
"
pre­
treatment"
in
the
"
Interval
1"
column
,
insert
"
3
weeks"
in
the
"
Interval
2"

column,
and
insert
"
6
weeks"
in
the
"
Interval
3"
column."

In
columns
E,
G,
I,
K,
M,
and
O
insert
the
rating
(
the
level
of
control
provided
for
a
specific
pest)
for
each
interval
for
each
treatment
described.
In
this
example,
for
the
methyl
bromide
treatment
for
sting
nematode
enter
669
for
the
"
Rating
for
Interval
1",
221
for
the
"
Rating
for
Interval
2",
and
120
for
the
"
Rating
for
Interval
3."
In
the
comments
section
below
describe
the
rating
scale
(
e.
g.,

nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,
etc.).

For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,

etc.)
Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
should
directly
compare
methyl
bromide
and
the
alternative
regimen.

List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Example
Research
Summary
Table
Example
Provide
one
summary
table
for
each
study
being
described.
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Acre
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)

Telone
C35
Nematodes
1,3
D
dichloropropene
250­
350
lbs/
acre
$
2,722.00
Chloropicrin
Pathogens
Chloropicrin
200­
400
lbs/
acre
Metam
Sodium
Weeds
MITC
37­
50
gals
Telone
C35
Nematode
1,3
D
dichlorop
97.5
331.6
33.7
gals
$
1,645.00
Chloropicrin
Pathogen
Chloropicrin
100
100
100
lbs
Telone
C35
Nematodes
1,3
D
dichloropropene
250­
350
lbs/
acre
$
2,152.00
Metam
Weeds
MITC
37­
50
gals/
acre
Average
Costs
of
Alternative:
$
2,173.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
2,173.00
Comments:

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.
B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regarding
the
same
product.

Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Applicatio
n
In
the
crop
rotation
used
by
strawberry
nurseries
the
following
crops
are
grown:
registered
grain
seed,
onion
seed,
garlic
seed,
endive,
horseradish,
mint,
rye,
triticale,
oats,
barley,
wheat.
All
of
these
crops
benefit
in
terms
of
weed
and
pathogen
control.
The
nursery
may
lease
out
the
land
to
another
grower
during
the
crop
rotation
period,
or
may
actually
grow
the
cover
crop
themselves.

Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Telone
C35
with
Metam
Sodium
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
pesticides
that
replace
methyl
bromide
for
the
entire
interval.
Do
not
include
pesticides
that
are
used
along
with
methyl
bromide­­
enter
only
the
additional
pest
control
if
methyl
bromide
were
not
available.

Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Col.
I.
Enter
any
other
costs
associated
with
applying
this
product
in
Col.
J,
specifying
what
they
are
in
the
comments
section
at
the
bottom
of
this
sheet.

Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied.
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Application
s
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)

Product
X
Pest
Y,
Pest
Z
Chemical
D,

Chemical
F
90%
Chemical
D,

10%
Chemical
F
250
278
lbs
$
10.00
$
20.00
0
25
1
$
2,800.00
Product
U
Pest
V,
Pest
Y
Chemical
C
100%
150
200
gal
$
5.00
$
20.00
10
25
2
$
2,060.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Control
P
Pest
J,
Pest
K
$
500.00
Total
$
5,360.00
Comments:

If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

OMB
Control
#
2060­
0482
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Product
X
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Col.
I.
Enter
any
other
costs
associated
with
applying
this
product
in
Col.
J,
specifying
what
they
are
in
the
comments
section
at
the
bottom
of
this
sheet.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
per
area
For
EPA
Use
Only
ID#

Control
P
is
done
2
times
per
year
according
to
____
methods.

Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.

B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regardin
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)

Low
Elevation
Plants
market
boxes
of
1,000
plants
357
$
50.00
$
17,850.00
High
Elevation
Plants
market
boxes
of
1,000
plants
279
$
62.00
$
17,298.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
$
17,574.00
Comments:

None
of
the
strawberry
nurseries
had
commerical
acreage
in
any
alternative
fumigant.
These
numbers
are
generated
by
using
yield
reductions
predicted
in
the
article
written
by
K.
Larsen
and
D.
Shaw,
Soil
Fumigation
and
Runner
Plant
Production:
A
Synthesis
of
Four
Years
of
Strawberry
Nursery
Field
Trials.
2000.
HortScience
35(
4):
642­
46.

OMB
Control
#
2060­
0482
Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternative:
Telone
C35
with
Metam
Sodium
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,

you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
the
comment
section
below.

Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,

grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
row.
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
in
making
the
case
that
the
use
of
alternatives
affects
these
price
factors.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.
Post­
harvest
and
structural
users
may
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Increased
weeding
costs
140
325
$
465.00
hand
weeding
and
removal
$
0.00
of
a
noxious
weed
that
$
0.00
survived
fumigation
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Custom
per
Area
$
0.00
User
Total
per
acre
$
465.00
Comments:

No
growers
are
using
alternatives
on
a
commercial
basis.
Number
for
this
sheet
are
generated
from
information
provided
by
a
grower
who
conducted
a
trial
on
his
property
(
see
enclosed
letter).

OMB
Control
#
2060­
0482
Telone
with
Metam
Sodium
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,

not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operation
costs,
or
in
Col.
C
and
D
for
operations
done
by
user.

Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Typical
Equipment
Used
Operation
Done
by
User
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:
See
attached
sheet
6.
Yes
X
No
7.

OMB
Control
#
2060­
0482
There
are
a
series
of
studies
currently
being
conducted
at
the
strawberry
nurseries
(
See
attached
sheet)

See
attached
sheet
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
(
All
available
methyl
bromide
alternatives
from
the
alternatives
list
should
have
been
tested
or
have
future
tests
planned.)
There
is
no
need
to
complete
a
separate
worksheet
for
future
research
plans
for
each
alternative
­
you
may
use
this
worksheet
to
describe
all
future
research
plans.

If
additional
testing
is
not
planned,
please
explain
why.
(
For
example,
the
available
alternatives
have
been
tested
and
found
unsuitable,
an
alternative
has
been
identified
but
is
not
yet
registered
for
this
crop,
available
alternatives
are
too
expensive
for
this
crop,
etc.)
See
attached
sheet
See
attached
sheet
Will
crop
yield
be
measured
in
the
study?
For
EPA
Use
Only
ID#

See
attached
sheet.
Worksheet
4.
Alternatives
­
Future
Research
Plans
Alternatives
to
Methyl
Bromide
Fumigation
Research
for
California
Strawberry
Nurseries
The
California
strawberry
commission
has
funded
many
nursery
based
projects
from
1992­
2002.
They
estimate
that
10­
15%
of
their
overall
research
budget
from
that
period
of
time
was
spent
either
directly
on
nursery
projects
or
on
projects
that
had
a
large
nursery
component.
This
research
included
nusery
stock
performance
under
alternative
fumigant
regimes,
tracing
nursery
stock
under
alternative
fumigant
regimes
from
low
elevation
to
high
elevation
to
grower
production
fields
to
see
the
effect
of
alternative
fumigants
through
the
entire
nursery
cycle.
Research
on
root
pathogens
and
control
of
root
pathogens
by
chemical
and
non­
chemical
means
was
also
studied.
The
CSC
also
funds
an
on­
going
strawberry
breeding
program
to
develop
superior
cultivars
for
California
production
systems
including
evaluation
and
breeding
for
disease
resistance.
Some
of
the
research
studies
evaluated
the
root
health
and
development,
as
well
as
weed
and
pathogen
control
in
the
nurseries.
The
California
Strawberry
Commission
projects
that
they
have
spent
between
$
800,000
to
$
1,200,000
on
strawberry
nursery
research
during
this
time
period.

The
USDA
has
funded
projects
at
the
California
strawberry
nurseries
to
look
for
alternatives
to
Methyl
Bromide.
An
estimated
$
400,000
has
been
spent
on
these
projects
during
the
period
from
1992
through
2001.
These
projects
are
ongoing.
This
season
projects
on
alternatives
to
Methyl
Bromide
include
evaluating
chemical
and
non­
chemical
alternatives
with
researchers
evaluating
yield,
pathogen
populations,
nematode
populations
and
weed
levels
in
the
alternative
plots.
Further
studies
evaluating
rates
of
fumigants,
methods
of
application
and
different
tarps
are
planned
for
the
future.

The
University
of
California
Davis
campus
in
cooperation
with
the
UC
Kearney
Ag
Research
Center
has
ongoing
nursery
reasearch.
This
project
includes
evaluating
vertical
and
horizontal
migration
of
Vapam
in
the
soil,
multi
layer
Vapam
test,
C35
fumigation
test,
low
elevation
Vapam
and
Telone/
Vapam
test,
High
elevation
Vapam,
Telone
and
Methyl
Bromide
test.
This
is
the
research
that
generated
the
numbers
of
nematodes
and
weeds
throughout
the
soil
profile
at
the
Shasta
Nursery
site.
This
is
on­
going
research,
about
$
100,000
has
been
spent
on
this
project
up
to
this
time.
Further
research
evaluating
chemical
and
non­
chemical
alternativesis
planned
for
the
future.

Individual
nurseries
have
also
been
evaluating
alternatives
to
Methyl
Bromide.
Projects
have
included
cultural
changes
(
I.
e.
looking
at
raised
beds
and
drip
irrigation,
looking
a
non
leaking
irrigation
pipes,
evaluating
alternative
planting
densities
with
and
without
tractor
rows),
chemical
alternatives
(
small
plots
of
Telone
and
Telone
combinations
for
research
purposes),
non­
chemical
alternatives
(
Steam
soil
sterilization).
The
estimates
from
the
nurseries
for
the
money
they
have
spent
to
date
is
$
250,000.
All
of
the
nurseries
plan
to
continue
to
evaluate
alternatives
as
they
become
available
and
continue
to
evaluate
currently
registered
materials
to
attempt
to
improve
the
efficacy
of
the
alternatives.
1.

1a.
Check
all
methods
you
will
use
Nothing
X
Tarpaulin
(
high
density
polyethylene)

X
Virtually
impermeable
film
(
VIF)

Cultural
practices
(
please
specify)

1b.
Will
you
use
other
pesticides
to
reduce
use
of
methyl
bromide?
Yes
x
No
If
yes
please
specify.

1c.
Other
non­
chemical
methods:
(
please
specify):

2.
Yes
No
X
If
yes,
how
many
pounds?
lbs.

3.

Yes
No
X
If
yes,
how
many
pounds?
lbs.

4.

$

5.

6.

Telone
(
and
Telone
combinations)
as
well
as
Chloropicrin
(
and
Chloropicrin
combinations)
on
the
soil
pest
complex.

When
do
you
expect
these
to
occur?
Worksheet
5.
Additional
Information
For
EPA
Use
Only
ID#

Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
on
January
1,
2005?

If
an
alternative
can
be
found
that
1)
has
equal
effectiveness
on
soil
pathogens,
nematodes
and
weeds
2)
is
growers
as
well
as
the
USDA,
IR4,
University
of
California
have
all
made
significant
investments
to
reduce
the
Identify
what
factors
would
allow
you
to
stop
or
reduce
your
use
of
methyl
bromide
(
e.
g.
registration
of
particular
pesticide;
completion
of
research
plan;
capital
outlay).
What
is
the
cumulative
amount
spent
to
date
by
the
user
or
consortium
on
research
to
develop
alternatives
to
methyl
bromide
(
beginning
in
1992)?

reliance
on
methyl
bromide.
None
of
the
alternatives
have
proved
to
be
as
effective
as
methyl
bromide
in
controlling
the
soil
nematodes,
soil
pathogens
and
weeds.
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Do
you
have
access
to
recycled
methyl
bromide?
Methyl
bromide
is
used
in
combination
with
chloropicrin
normally
at
67/
33
or
75/
25
VIF
will
be
used
as
the
technology
to
apply
this
material
improves.
Currently
th
problems
with
the
glue
used
to
hold
the
sheets
of
VIF
together,
the
material
do
bend
well,
there
is
only
one
source
of
the
material
so
availability
can
be
an
issu
$
1,550,000
Other
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide.
Describe
each
investment
and
its
associated
cost.

The
California
Strawberry
Nursery
Assoication,
California
Strawberry
Commission,
individual
strawberry
nursery
This
is
on­
going,
long
term
research.
We
hope
to
have
more
information
on
feasibility
of
alternatives
in
the
next
5
to
years.
Further
research
is
needed
to
find
a
viable
alternative
that
can
maintain
current
plant
cleanliness
levels.
as
economical
to
apply
and
3)
is
accepted
as
an
alternative
by
the
California
Department
of
Food
and
Agriculture
certification
regulations,
then
California
Strawberry
Nurseries
will
use
the
alternative.

Research
into
alternatives
is
on­
going.
Further
research
needs
to
be
done
on
the
long
term
effects
of
the
Aother
alternatives
(
Midas)
are
also
being
tested
although
they
are
not
yet
registered
in
California
or
the
U.
S.
7.

0­
10
acres
10­
25
acres
25­
50
acres
50­
100
acres
100­
200
acres
200­
400
acres
over
400
acres
0
1
0
1
2
6
2
Range
of
acres
farmed
by
growers
included
in
this
application?
(
insert
number
of
users
in
each
category)
Worksheet
5.
Additional
Information
(
continued)

8.

0
0
­
5,000
sq.
ft.

0
5,001
­
10,000
sq.
ft.

0
10,001
­
20,000
sq.
ft.

0
20,001
­
40,000
sq.
ft.

0
40,001
­
80,000
sq.
ft.

7
80,001
­
160,000
sq.
ft.
This
is
for
the
low
elevation,
foundation
fields.

12
over
160,000
sq.
ft.
This
is
for
the
low
elevation
registered
fields
and
the
high
elevation
certified
fields.

I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.

Signature
Date
Print
Name
Title
Signature
Date
Print
Name
Title
OMB
Control
#
2060­
0482
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintainin
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
resp
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
colle
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
brom
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
Range
of
square
feet
of
the
area
to
which
applicants
included
in
this
application
will
apply
methyl
bromide?
(
insert
number
of
users
in
each
category)

Information
in
this
application
may
be
aggregated
with
information
from
other
applications
and
used
by
the
United
States
government
to
justify
claims
in
the
national
nomination
package
that
a
particular
use
of
methyl
bromide
be
considered
"
critical"
and
authorized
for
an
exemption
beyond
the
2005
phaseout.
Use
of
aggregate
data
will
be
crucial
to
making
compelling
arguments
in
favor
of
critical
use
exemptions.
By
signing
below,
you
agree
not
to
assert
any
claim
of
confidentiality
that
would
affect
the
disclosure
by
EPA
of
aggregate
information
based
in
part
on
information
contained
in
this
application.
For
EPA
Use
Only
ID#
/
25.
there
are
does
not
sue.

to
10
.

es
the
time
ining
spond
to
a
ollection
of
omide.
An
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
790,000
5.
Area
Treated
with
Methyl
Bromide
2005
3,360
acres
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

are
not
controlled,
will
be
international
control
and
quarantine
issues.

2006
790,000
lbs.
Area
Treated
3,360
acres
units
2007
790,000
lbs.
Area
Treated
3,360
acres
units
Not
Technically
Feasible
Not
Economically
Feasible
x
x
x
x
x
x
For
EPA
Use
Only
ID#

Worksheet
6.
Application
Summary
This
worksheet
will
be
posted
on
the
web
to
notify
the
public
of
requests
for
critical
use
exemptions
beyond
the
2005
phase
out
for
methyl
bromide.
Therefore,
this
worksheet
cannot
be
claimed
as
CBI.

Name
of
Applicant:

Location:

Crop:
California
Strawberry
Nursery
Association
Many
nursery
systems
worldwide,
as
well
as
fruit
producers
worldwide,
depend
on
California
as
a
source
of
pesth
and
pathogen
free
stock.
Deep,
uniform
fumigation
is
essential
to
produce
plants
with
the
necessary
level
of
cleanliness.
Currently,
no
alternative
has
been
identified
that
can
achieve
the
same
level
of
pathogen
and
pest
control.
Because
plants
are
so
widely
distributed,
any
disease
and
insect
problems
tha
Northern
California,
Southern
Oregon,
Sacramento
Valley,
Northern
San
Joaquin
Valley
strawberry
nursery
plants
Reduces
yield,
does
not
have
the
same
pathogen,
nematode
and
weed
control
as
MeBr/
Pic.
Cannot
control
pathogens
and
pests
deeply
enough
in
the
soil
profile.
Reasons
Reduces
yield,
does
not
have
the
same
pathogen,
nematode
and
weed
control
as
MeBr/
Pic.
Cannot
control
pathogens
and
pests
deeply
enough
in
the
soil
profile.

Reduces
yield,
does
not
have
the
same
pathogen,
nematode
and
weed
control
as
MeBr/
Pic.
Cannot
control
pathogens
and
pests
deeply
enough
in
the
soil
profile.

1,3­
D,
Chloropicrin,
Metam
Sodium
1,3­
D,
Metam
Sodium
Potential
Alternatives
1,3­
D,
Chloropicrin
Place
an
"
X"
in
the
column(
s)
labeled
"
Not
Technically
Feasible"
and/
or
"
Not
Economically
Feasible"
where
appropriate.
Use
the
"
Reasons"
column
to
describe
why
the
potential
alternative
is
not
feasible.
Fumigation
cycle:

Year:
Comparable
data:

2­
year
example:

Other
beneficiary
example
Crop
cycle
change
example:
If
a
methyl
bromide
fumigation
is
made
every
2
years,
then
the
2001
fumigation
cycle
began
in
2001
and
would
end
in
2003.
The
data
should
cover
the
methyl
bromide
costs
and
usage
for
the
methyl
bromide
fumigation
made
in
2001,
and
all
yields
and
revenues
received
and
other
costs
incurred
during
the
2
year
period.
To
be
comparable,
the
data
on
alternatives
should
cover
a
similar
2
year
period
beginning
in
2005
beginning
at
the
same
time
of
year
when
a
methyl
bromide
fumigation
would
be
made.
The
data
should
cover
all
methyl
bromide
alternatives
used,

and
all
yields
and
revenues
received
during
that
2­
year
interval.
Other
pest
control
and
other
costs
would
only
need
to
be
provided
for
that
interval
if
they
would
change
from
what
they
were
with
methyl
bromide.

If
someone
other
than
the
applicant
benefits
from
a
methyl
bromide
fumigation,
you
should
comment
on
these
benefits
if
you
do
not
have
quantitative
data
for
the
entire
fumigation
cycle.

For
example,
if
a
rotational
crop
in
the
second
year
benefits
from
a
methyl
bromide
fumigation
a
year
earlier,
but
there
is
quantitative
data
only
on
the
first
crop,
then
the
data
on
the
alternatives
should
cover
only
the
first
crop,
and
the
benefits
of
methyl
bromide
and
the
additional
pesticides
that
would
have
to
be
used
on
the
rotational
crop
should
be
discussed
in
the
comments
sections.

If
in
a
one
year
interval,
methyl
bromide
is
applied,
tomatoes
are
grown
and
harvested
followed
by
peppers,
then
the
fumigation
cycle
would
be
one
year
including
the
tomatoes
and
peppers.
If,

however,
without
methyl
bromide,
it
is
not
possible
to
follow
tomatoes
with
peppers
in
the
same
one
year
interval,
then
the
alternative
data
on
pesticides,
costs,
yields,
and
revenues
should
just
cover
tomatoes.
The
loss
of
profit
from
not
being
able
to
grow
peppers
with
the
alternatives
would
be
part
of
the
loss
from
not
having
methyl
bromide.

Fumigation
Cycle
Definitions:

In
order
to
compare
revenues
and
costs
with
and
without
methyl
bromide,
data
on
alternatives
for
pest
control,
yields,
revenues,
and
costs
must
be
for
the
same
time
interval
as
the
methyl
bromide
fumigation
cycle.
If,
however,
quantitative
data,
is
not
available
for
the
entire
fumigation
cycle,

then
to
be
comparable,
the
quantitative
data
for
the
alternatives
should
cover
the
same
portion
of
the
fumigation
cycle
as
the
quantitative
data
for
methyl
bromide,
and
the
rest
of
the
cycle
should
be
discussed
in
the
comments
sections.

If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
"
year"
refers
to
the
calendar
year
when
methyl
bromide
is
applied
(
or
the
beginning
of
the
cycle).

The
period
of
time
between
methyl
bromide
fumigations.
