METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
ON
STRAWBERRY
NURSERIES
IN
OPEN
FIELDS
OR
IN
PROTECTED
ENVIRONMENTS
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Strawberry
Nurseries
Grown
in
Open
Fields
or
in
Protected
Environments
(
Prepared
in
2005)

NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
Use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.


Yes

No
Signature
Name
Date
Title:
U.
S.
Strawberry
Nursery
ii
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Steve
Knizner
Title:
Acting
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
305­
6903
Fax:
(
703)
308­
8090
E­
mail:
knizner.
steve@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
U.
S.
Strawberry
Nursery
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY.................................................................................................................................................
6
1.
Nominating
Party
_________________________________________________________
6
2.
Descriptive
Title
of
Nomination______________________________________________
6
3.
Crop
and
Summary
of
Crop
System___________________________________________
6
4.
Methyl
Bromide
Nominated
_________________________________________________
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
6
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
7
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
8
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________
8
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region____________________________________________________________________
9
SOUTHEASTERN
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
......................................
10
Southeastern
States
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
__________________________________________
10
Southeastern
States
­
11.
Characteristics
of
Cropping
System
and
Climate______________
10
Southeastern
States
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
11
SOUTHEASTERN
STATES
­
PART
C:
TECHNICAL
VALIDATION..................................................................................
12
Southeastern
States
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________
12
Southeastern
States
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
__
18
Southeastern
States
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_____________________________________________
18
Southeastern
States
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
________________________________________________________________________
19
Southeastern
States
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide
__________________________
20
Southeastern
States
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide
___________________________________________
20
Southeastern
States
­
Summary
of
Technical
Feasibility
____________________________
21
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
........................................................
22
California
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
22
California
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
22
California
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
24
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
...................................................................................................
25
California
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
25
California
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
25
California
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
25
U.
S.
Strawberry
Nursery
iv
California
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___
25
California
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
32
California
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide____________________________________________________
32
California
­
Summary
of
Technical
Feasibility
___________________________________
33
PART
D:
EMISSION
CONTROL
................................................................................................................................
34
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
34
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
34
PART
E:
ECONOMIC
ASSESSMENT..........................................................................................................................
35
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
35
Southeastern
States­
22.
Gross
and
Net
Revenue
__________________________________
35
California­
22.
Gross
and
Net
Revenue
__________________________________________
36
Summary
of
Economic
Feasibility
_____________________________________________
38
PART
F.
FUTURE
PLANS
........................................................................................................................................
40
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
40
25.
Additional
Comments
on
the
Nomination
____________________________________
41
26.
Citations
______________________________________________________________
41
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
6
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
6
Table
A.
1:
Executive
Summary
__________________________________________________
7
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
__________________________
8
Southeastern
States
and
California­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
______________________________________________________________
8
SOUTHEASTERN
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
________
10
Southeastern
States
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
________________________________________________________________
10
Southeastern
States
­
Table
11.1:
Characteristics
of
Cropping
System
___________________
10
Southeastern
States
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________
10
Southeastern
States
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________
11
SOUTHEASTERN
STATES
­
PART
C:
TECHNICAL
VALIDATION
______________________________
12
Southeastern
States
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________
12
Southeastern
States
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________
18
Southeastern
States
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________
18
Southeastern
States
 
Table
16.1:
Effectiveness
of
Alternatives
 
Certain
Weeds
1
_________
19
Southeastern
States
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________
20
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_________________
22
California
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request__
22
U.
S.
Strawberry
Nursery
v
California
­
Table
11.1:
Characteristics
of
Cropping
System___________________________
22
California
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
23
California
­
Table
11.3
Characteristics
of
Climate
and
Crop
Schedule
___________________
23
California
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____________________
24
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
25
Southeastern
States
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________
25
Southeastern
States
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________
25
California
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
25
California
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
Chemical
Alternatives
to
Methyl
Bromide
Fumigation
 
How
Well
Do
They
Work?
______________________________
27
California
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
Chloropicrin
Effect
on
Weed
Seed
Viability.
_______________________________________________________________
28
California
 
TABLE
16.3:
EFFECTIVENESS
OF
ALTERNATIVES
­
Soil
Fumigation
and
Runner
Plant
Production.
_____________________________________________________________
28
California
 
TABLE
16.4:
EFFECTIVENESS
OF
ALTERNATIVES
­
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries
_____
29
California
 
TABLE
16.5a
AND
16.5b:
EFFECTIVENESS
OF
ALTERNATIVES
­
Evaluation
of
Alternatives
to
Methyl
Bromide
for
the
Control
of
Soil
Pests______________________
30
California
 
TABLE
16.5a:
Fruit
yield
(
grams
per
plant)
of
strawberry
at
Watsonville,
CA
in
2002
_______________________________________________________________________
30
California
 
TABLE
16.5b:
Fruit
yield
(
grams
per
plant)
of
strawberry
at
Watsonville,
CA
in
2003
_______________________________________________________________________
31
California
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
32
PART
D:
EMISSION
CONTROL
____________________________________________________
34
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
34
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
35
Table
21.1:
Operating
Costs
with
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______________________________________________________________________
35
Southeastern
States­
Table
22.1:
Years
1,
2,
and
3
Gross
and
Net
Revenue________________
35
California­
Table
22.1:
Years
1,
2,
and
3
Gross
and
Net
Revenue
_______________________
36
Southeastern
States
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______
37
California
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
37
PART
F.
FUTURE
PLANS
________________________________________________________
40
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
46
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Strawberry
Nurseries
in
Open
Fields
or
in
Protected
Environments
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Southeastern
(
from
Maryland,
North
Carolina,
and
Tennessee)
growers
annually
produce
their
transplants
in
open
fields.
An
individual
field
is
only
planted
to
strawberries
once
every
three
years.
Approximately
85%
of
transplants
produced
are
exported
to
Florida.

California
growers
produce
their
transplants
over
a
five
year
cycle.
Screenhouses
are
used
during
the
first
two
years
and
open
field
plantings
are
used
during
the
last
three
years.
Methyl
bromide
(
MB)
is
only
needed
in
production
years
2
thru
5.
Individual
planting
sites
are
only
planted
to
strawberries
once
every
three
years.
The
fourth
and
fifth
production
years
account
for
22%
and
77%,
respectively,
of
the
current
MB
nursery
usage
in
California.
Transplants
produced
are
distributed
widely
throughout
the
U.
S.
and
other
countries.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)*
NOMINATION
AREA
(
HA)

2007
4,483
13
*
Includes
research
amount
of
454
kgs.

5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
strawberry
nursery
production
there
are
several
factors
that
make
the
potential
alternatives
to
MB
unsuitable.
These
include:
 
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
MB
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
tomato
production.
 
Quarantine
and
Pre­
Shipment
uses
are
not
included
in
this
CUE.

MB
is
needed
in
the
near
future
for
strawberry
nursery
production
to
produce
plants
free
of
all
damaging
diseases
and
nematodes
to
meet
state
and
foreign
certification
standards,
as
well
as
U.
S.
Strawberry
Nursery
7
prospective
buyer
expectations.
In
addition
to
these
certification­
related
pest
control
concerns,
weed
control
is
also
essential
to
insure
maximum
runner
production
and
prevent
the
spread
of
noxious
weeds.
The
available
alternatives,
thus
far,
have
not
been
developed
sufficiently
to
provide
acceptable
levels
of
control
of
the
key
pests
to
depths
of
1
m.
In
addition,
there
are
no
markets
for
plants
that
do
not
meet
the
certification
standards,
which
mean
that
losses
up
to
100%
are
possible
when
less
than
required
levels
of
pest
control
occur.
Failure
to
adequately
control
pests
in
transplants
would
jeopardize
the
viability
of
the
transplant
and
fruit
production
industries
in
the
U.
S.,
as
well
as
the
viability
of
fruit
production
in
countries
purchasing
U.
S.
plants
(
e.
g.,
Canada,
Mexico,
Spain,
countries
in
South
America,
and
some
others).

TABLE
A.
1:
EXECUTIVE
SUMMARY
Region
Southeastern
States
California
AMOUNT
OF
NOMINATION*

2007
Kilograms
2,654
1,375
AMOUNT
OF
APPLICANT
REQUEST
2007
Kilograms
43,292
137,466
*
See
Appendix
A
for
complete
description
on
how
nominated
amount
was
calculated.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE
The
key
alternatives
are
1,3­
dichloropropene
(
1,3­
D)/
chloropicrin,
1,3­
D/
chloropicrin/
metamsodium
and
1,3­
D/
metam­
sodium.
Dazomet
is
also
a
possible
alternative
probably
in
combination
with
chloropicrin
and/
or
1,3­
D.
These
chemicals,
in
addition
to
other
strategies,
such
as
use
of
high
density
tarps,
may
ultimately
reduce
or
replace
MB.
However,
to
maintain
certification
quality
protocols
for
effective
use
of
these
alternatives
have
not
been
sufficiently
developed
to
provide
an
adequate
level
of
disease
and
nematode
control
throughout
the
root
zone
(
up
to
1
m
deep).
Additionally,
these
alternatives
will
require
further
study
before
consistently
providing
control
of
yellow
and
purple
nutsedge
(
Cyperus
esculentus,
C.
rotundus)
(
SE
states
only)
and
a
number
of
other
critical
weed
pests
in
California
(
Table
10.1).
The
state
certification
requirements
associated
with
the
requesting
states
are
strict
(
virtually
zero
tolerance
for
any
damaging
diseases
and
plant­
parasitic
nematodes)
in
order
to
minimize
the
prospect
of
spreading
these
nematode
and
disease
pests
to
other
states
and
countries
where
these
plants
are
shipped.
Research
has
been
cited
(
e.
g.,
Kabir
et
al.,
2003)
in
this
review
that
gives
hope
for
MB
replacement
or
reduction
for
this
sector,
but
the
need
for
MB
for
the
short
term
is
critical
until
protocols
are
developed
sufficiently
for
use
in
commercial
strawberry
nursery
operations.
U.
S.
Strawberry
Nursery
8
7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
All
growers
in
the
affected
states
requesting
methyl
bromide
use
are
dependent
upon
its
wide
pest
spectrum
and
high
level
of
pest
control.

TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TOTAL
CROP
AREA
 
2001­
2002
AVERAGE
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
Southeastern
States
69
100
California
1,386
100
7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE.

Pest­
free
standards
for
nursery
stock
make
the
transition
to
alternatives
difficult.

7.
(
iii)
WOULD
IT
BE
FEASIBLE
TO
EXPAND
THE
USE
OF
THESE
METHODS
TO
COVER
AT
LEAST
PART
OF
THE
CROP
THAT
HAS
REQUESTED
USE
OF
METHYL
BROMIDE?
WHAT
CHANGES
WOULD
BE
NECESSARY
TO
ENABLE
THIS?

Not
applicable
because
the
alternatives
have
not
been
proven
effective
for
the
control
of
the
target
pests
in
nursery
conditions.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
SOUTHEASTERN
STATES
AND
CALIFORNIA­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
SOUTHEASTERN
STATES
CALIFORNIA
YEAR
OF
EXEMPTION
REQUEST
2007
2007
KILOGRAMS
OF
METHYL
BROMIDE
43,292
137,464
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
FLAT
FUMIGATION
FLAT
FUMIGATION
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
ha)
105
522
(
w/
o
QPS)

APPLICATION
RATE
(
kg/
ha)
FOR
THE
FORMULATION
520
395
APPLICATION
RATE
(
kg/
ha)
FOR
METHYL
BROMIDE
350
263
DOSAGE
RATE
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
52.0
39.5
DOSAGE
RATE
(
g/
m2)
OF
METHYL
BROMIDE
35.0
26.3
U.
S.
Strawberry
Nursery
9
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION
The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:

 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
Values
greater
than
100
percent
are
due
to
the
inclusion
of
additional
varieties
in
the
applicant's
request
that
were
not
included
in
the
USDA
National
Agricultural
Statistics
Service
surveys
of
the
crop.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide
were
subtracted.
There
was
no
double
counting
in
this
sector.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
two
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
There
was
a
small
adjustment
for
use
rate
in
one
of
the
applications.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Both
applicants
had
QPS
listed
the
amount
requested
and
reflects
the
subtraction
of
the
QPS
amount.
 
Only
the
area
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure.
U.
S.
Strawberry
Nursery
10
SOUTHEASTERN
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
SOUTHEASTERN
STATES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
SOUTHEASTERN
STATES
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Southeastern
States
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
Purple
nutsedge
(
Cyperus
rotundus)

Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.);
Crown
rot
(
Phytophthora
cactorum);
root­
knot
nematodes
(
Meloidogyne
spp.)
None
of
the
available
alternatives
currently
provides
an
acceptable
or
consistent
level
of
control
of
nutsedge.

SOUTHEASTERN
STATES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
SOUTHEASTERN
STATES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTHEASTERN
STATES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Strawberry
transplants
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
crop,
replanted
in
same
site
once
every
three
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Various
crops
planted
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
93%
medium
and
7%
light
soils,
containing
up
to
2%
organic
matter
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Every
year
OTHER
RELEVANT
FACTORS:
None
identified
SOUTHEASTERN
STATES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
6a,
6b,
7a,
7b,
8a,
8b
RAINFALL
(
mm)
163
124
109
87
78
146
113
202
109
116
54
76
OUTSIDE
TEMP.
(
°
C)
9.4
14.5
17.7
23.4
26
25.9
22.6
14.9
7.7
3.4
2.9
4.2
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
X
HARVEST
SCHEDULE
2X
X
*
Macon,
GA
U.
S.
Strawberry
Nursery
11
SOUTHEASTERN
STATES
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

None
were
identified
as
being
limiting
factors.

SOUTHEASTERN
STATES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
SOUTHEASTERN
STATES
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003
AREA
TREATED
(
hectares)
82
82
55
67
71
75
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Nearly
all
flat
fumigation
Nearly
all
flat
fumigation
Nearly
all
flat
fumigation
Nearly
all
flat
fumigation
Nearly
all
flat
fumigation
Nearly
all
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
49,386
33,764
22,900
27,747
29,251
30,923
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide/
chloropicrin)
98:
2
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
616
619
619
619
619
619
APPLICATION
RATE
OF
METHYL
BROMIDE
IN
kg/
ha*
604
413
413
413
413
413
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
61.6
61.9
61.9
61.9
61.9
61.9
ACTUAL
DOSAGE
RATE
OF
METHYL
BROMIDE
(
g/
m2)*
60.4
41.3
41.3
41.3
41.3
41.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Strawberry
Nursery
12
SOUTHEASTERN
STATES
­
PART
C:
TECHNICAL
VALIDATION
SOUTHEASTERN
STATES
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
SOUTHEASTERN
STATES
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
Chloropicrin
Objectionable
odors
in
residential
areas;
little
or
no
efficacy
on
nutsedge
(
Locascio
1997
&
1999);
in
some
instances
it
caused
increased
emergence
of
nutsedge
(
Motis
and
Gilreath
2002);
Unlikely
that
disease
and
nematode
control
required
by
state
certification
programs
can
be
attained
throughout
the
1
m
root
zone.
Chloropicrin
is
generally
considered
a
good
control
measure
for
certain
pathogens
(
Pythium,
Phytophthora,
Fusarium,
Verticillium),
but
is
not
considered
effective
for
nematode
or
weed
control.
[
See
also
chloropicrin
issues
addressed
in
the
fumigant
combination
entries
in
this
section.]
No
NON
CHEMICAL
ALTERNATIVES
Biofumigation
Lack
of
adequate
data
on
the
activity
of
biofumigation
materials
on
nutsedge
control;
Based
on
studies
with
other
crops,
allelochemicals
may
cause
phytotoxic
effects
(
Norsworthy
2002;
Johnson
et
al.
1993);
unlikely
that
the
level
of
disease
and
nematode
control
required
by
state
certification
programs
can
be
attained
throughout
the
1
m
deep
root
zone.

Biofumigation
is
not
technically
feasible
because
it
does
not
provide
adequate,
or
consistent,
control
of
target
pests
to
produce
a
certifiable
strawberry
nursery
stock.
Research
conducted
in
Florida
showed
some
control
of
plant
pathogens,
but
no
control
of
nematodes
or
weeds
in
the
soil.
In
cases
where
biofumigation
have
been
shown
to
control
weeds,
the
data
are
mostly
for
small­
seeded
weed
species
that
have
small
carbohydrate
energy
sources
compared
to
nutsedge.
The
data
on
biofumigation
are
too
limited
to
consider
it
as
a
practical
alternative
to
methyl
bromide,
and
strategies
to
incorporate
biofumigation
with
other
alternatives
have
not
been
adequately
developed.

It
is
not
clear
that
Brassica
crops
can
be
supplied
in
such
quantity
needed
to
control
target
pests.
Estimates
are
that
the
biofumigant
would
have
to
occupy
approximately
3
hectares
for
every
hectare
of
strawberry
production.
Incorporation
of
Brassica
at
these
levels
would
be
likely
to
have
allelopathic
effects
on
the
target
crop.
No
U.
S.
Strawberry
Nursery
13
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Solarization
Even
in
warmer
climates
(
Georgia)
it
is
difficult
to
attain
temperatures
lethal
to
nutsedge
(
50­
55
°
C)
at
depths
below
10
centimeters
(
Miles
et.
al.
2002).
However,
research
to
enhance
the
efficacy
of
solarization
with
tarps
is
being
conducted
(
e.
g.,
Arbel
et
al.,
2003).

Solarization
is
not
feasible
alternative
by
itself
because
it
does
not
provide
adequate
control
of
target
pests
to
produce
certifiable
strawberry
nursery
stock.
Use
of
solarization
is
not
practical
due
to
the
depth
of
heating
required
to
eliminate
viable
weed
seed,
nematodes,
and
disease
organisms.
The
time
for
solarization
to
raise
soil
temperatures
to
the
level
needed
to
kill
soil
pathogens
in
any
strawberry
nursery
region
is
likely
to
also
be
the
time
when
the
crops
themselves
must
complete
their
growth
cycle.
Unpredictable,
stormy
summer
weather
still
creates
risks
and
may
damage
mulch.
In
one
Southeast
field
trial,
solarization
gave
poor
yields
in
two
years
out
of
three
with
losses
ranging
from
0%
to
40%
(
Miles
et.
al.
2002).
No
General
IPM
IPM,
the
use
of
pest
monitoring
activities
coupled
with
chemical
and
non­
chemical
management
tools,
has
been
adopted
already
for
management
of
weed,
diseases,
and
nematodes
on
most
crops.
General
IPM
is
being
used
in
strawberry
nursery
stock
production,
but
it
is
not
technically
feasible
alone
to
provide
adequate
pest
control.
IPM
practices
include
field
sanitation
to
limit
inoculum
buildup,
crop
rotation
to
provide
non
host
periods,
and
breeding
for
resistance
to
pathogens.
No
Cover
crops
mulching
Cover
crops/
mulching
is
currently
being
used
but
it
is
not
technically
feasible
alone
as
a
complete
replacement
for
MB
to
control
the
target
pest
and
certify
the
nursery
stock;
level
of
disease
and
nematode
control
required
by
state
certification
programs
cannot
be
attained.

Cover
crops/
mulching
is
currently
being
used
but
it
is
not
technically
feasible
as
a
complete
replacement
for
MB
to
control
the
target
pests
and
certify
the
nursery
stock.
The
use
of
cover
crops
is
a
common
practice
to
improve
soil
structure
and
suppress
an
array
of
soilborne
pathogens.
Cover
crops
and
mulches
have
been
integrated
into
strawberry
nursery
crop
production
systems.

Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
et
al.,
1996;
Galloway
et
al.,
1996).
Cowpea
and
sunn
hemp
have
been
shown
to
suppress
nutsedge,
but
the
effect
is
short
lived
due
to
the
weed's
capacity
for
rapid
tuber
production.
Allelochemicals
released
by
some
cover
crops
or
organic
mulches
can
injure
crops
(
Johnson
et
al.,
1993;
Norsworthy,
2002).
No
U.
S.
Strawberry
Nursery
14
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Crop
rotation/
fallow
Growers
typically
use
this
practice
by
growing
other
crops
every
two
out
of
three
years;
this
practice
has
not
resulted
in
a
level
of
disease
and
nematode
control
required
by
state
certification
programs
throughout
the
1
m
deep
root
zone;
no
suitable
nutsedge
controls
are
available
during
production
of
the
rotational
crops
(
Culpepper,
2002).

A
three­
year
crop
rotation/
fallow
is
being
used
in
strawberry
nursery
stock
production,
but
it
is
not
technically
feasible
when
used
alone
to
control
the
key
target
pests.
Strategies
for
use
with
other
alternatives
are
being
studied,
but
are
not
currently
developed
to
use
in
a
commercial
nursery
at
this
time.

Although
such
crop
rotation
and
fallow
procedures
are
generally
considered
useful
pest
management
tools
for
weeds,
diseases
and
nematodes,
they
are
rarely
considered
standalone
control
measures.
Significantly
longer
time
frames
may
produce
higher
levels
of
control
for
most
pests,
but
are
generally
considered
impractical
because
of
limited
land
availability
and
high
costs.

There
are
registered
herbicides
that
are
effective
for
nutsedge
control
in
agronomic
crops.
These
herbicides
are
not
available
for
most
fruit
or
vegetable
crops,
and
many
of
them
have
12­
to
26­
month
carryover
restrictions
for
vegetable
crops.

Crop
rotation
and
fallow
will
not
suppress
nutsedge.
Johnson
&
Mullinix
(
1997)
showed
that
uninterrupted
plantings
of
peanut,
corn,
or
cotton,
with
moderate
levels
of
weed
management
suppressed
yellow
nutsedge
in
Georgia.
Their
data
also
showed
an
increase
in
nutsedge
densities
in
fallow
plots,
likely
due
to
the
longevity
of
nutsedge
tubers
in
soil,
mild
winters
that
prevent
winter­
kill
of
tubers,
and
the
ability
of
tubers
to
regenerate
with
the
long
growing
season
in
the
southeastern
coastal
plain.
There
are
also
reports
of
increasing
populations
of
yellow
nutsedge
in
fallowed
fields,
even
when
weed
control/
management
is
performed.
Since
there
are
no
herbicides
registered
for
use
on
strawberry
plants
that
will
effectively
control
nutsedge,
management
of
these
weeds
during
short­
term
rotations
and
fallow
is
not
effective.
No
Soilless
culture
Soilless
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.
According
to
data
provided
by
The
National
Center
for
Food
and
Agricultural
Policy,
a
greenhouse
typically
costs
between
US$
12.5
million
and
US$
20
million
per
hectare.
Although
yields
obtained
through
greenhouse
production
are
higher
than
yields
of
the
best
growers,
the
issue
of
capitalization
for
this
and
other
sectors
make
the
alternative
not
feasible
as
a
near
term
strategy
to
reduce
reliance
on
MB.
No
U.
S.
Strawberry
Nursery
15
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Substrates/
plug
plants
grown
hydroponically
Substrates/
plug
plants
are
currently
being
produced
and
sold
in
the
southeast
and
to
a
very
limited
extent
in
California,
but
this
method
alone
does
not
provide
pest
control
and
would
fail
to
produce
a
pest
free
product.
Furthermore,
this
method
would
require
extensive
retooling
by
the
nursery
industry,
and
would
be
cost
prohibitive
to
change
to
this
technology.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
Little
or
no
efficacy
on
nutsedge
(
Locascio
1997
&
1999);
level
of
disease
and
nematode
control
required
by
state
certification
programs
cannot
be
attained
throughout
the
1
m
deep
root
zone;
may
be
the
best
alternative
where
nutsedge
is
not
a
problem
(
50%
of
production
area).

The
combination
of
1,3­
D
and
chloropicrin
is
not
technically
feasible
because
it
does
not
adequately
control
nematodes
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3
D
provides
good
nematode
control,
moderate
disease
control,
and
poor
weed
control.
A
30.5
meter
(
100
feet)
1,3­
D
buffer
requirement,
to
mitigate
area
resident
exposure,
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas,
which
is
typical
for
the
Southeastern
U.
S.
growers.
Personal
Protective
Equipment
(
PPE)
requirements
also
limit
operations
that
require
workers
in
the
field,
particularly
given
the
high
temperatures
which
occur
in
the
southeast,
which
are
exacerbated
by
high
humidity.
Workers
wearing
the
required
PPE
become
at
risk
for
possible
heat
exhaustion
or
heat
stroke.
For
example,
PPE
may
require
applicators
to
wear
fully
sealed
suits
with
respirators.
Such
suits
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity,
rapidly
become
unbearable
for
a
typical
applicator.
Growers
believe
that
the
requirements
for
buffers
and
PPE
may
make
it
impractical
to
adopt
1,3­
D.
The
buffer
requirements,
especially
for
the
small
farms
in
the
Southeastern
U.
S.,
eliminate
so
much
area
around
the
perimeter
of
a
field
that
there
is
very
little
left
that
can
be
treated
using
1,3­
D
alone
to
grow
strawberries.
Chloropicrin
provides
good
disease
control,
but
poor
nematode
and
weed
control.
Workers
complain
about
eye
and
lung
irritation
when
applying
chloropicrin,
which
is
used
as
tear
gas.
No
U.
S.
Strawberry
Nursery
16
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3­
D
+
chloropicrin
+
metam­
sodium
Inconsistent
control
of
nutsedges;
unlikely
to
sufficiently
control
disease
and
nematode
problems
as
required
by
state
certification
programs.
The
combination
of
1,3­
D,
chloropicrin
and
metam
sodium
is
not
currently
technically
feasible
because
it
does
not
consistently
control
pests
and
diseases
to
the
level
required
by
various
state
laws.
Research
with
tarps
and
other
combination
strategies
may
improve
efficacy
(
e.
g.,
Ajwa
et
al.,
2003),
but
these
need
to
be
sufficiently
developed
for
commercial
use.
1,3­
D
is
a
good
nematicide
and
chloropicrin
is
a
good
fungicide.
Metam
sodium
provides
moderate,
but
unpredictable
disease,
nematode,
and
weed
control
since
it
suffers
from
erratic
efficacy,
most
likely
due
to
irregular
distribution
of
the
product
through
soil.

Metam
sodium
degrades
in
the
soil
to
form
methylisothiocyanate,
which
has
activity
against
nematodes,
fungi,
insects,
and
weeds.
MB
has
a
higher
vapor
pressure
than
metam
sodium,
therefore
can
penetrate
and
diffuse
throughout
the
soil
more
effectively
than
metam
sodium.
In
addition,
the
effectiveness
of
metam
sodium
is
very
dependent
on
the
organic
matter
and
moisture
content
of
the
soil.
Studies
to
evaluate
best
delivery
systems
for
metam
sodium
are
being
conducted.
Some
studies
have
shown
that
soil
injections
and
drenches
are
more
effective
than
drip
irrigation.
Research
trials
show
that
incorporation
of
metam
sodium
with
a
tractor­
mounted
tillovator
provides
good
results
but
most
growers
do
not
have
this
equipment.

A
3­
week
time
interval
before
planting
is
required
to
avoid
phytotoxic
levels;
causing
delays
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profit
or
actually
causing
a
loss
for
a
grower.

The
combination
of
the
three
chemicals
would
still
require
a
companion
herbicide
or
hand
weeding.
Failure
to
control
the
full
spectrum
of
weeds
could
lead
to
increased
disease
pressure
over
time
because
the
weeds
can
be
reservoirs
for
disease
or
harbors
insect
vectors
of
disease.
Also,
in
strawberry
fruit
production,
there
is
demand
for
pest
free
strawberry
root
stock.
The
nursery
growers
who
do
not
supply
this
type
of
product
will
be
forced
out
of
the
market.
No
U.
S.
Strawberry
Nursery
17
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3­
D
+
metamsodium
1,3­
D
or
metam­
sodium
possess
inconsistent
control
of
nutsedge
(
Webster
et.
al.
2001);
metam­
sodium
component
is
likely
to
provide
inconsistent
nematode,
weed
and
disease
control
due
to
poor
movement
within
soil;
it
is
unlikely
that
the
disease
and
nematode
control
required
by
state
certification
programs
can
be
attained
with
this
combination
throughout
the
1
m.
deep
root
zone.
Research
examining
protocols
for
combination
treatments
have
the
best
chance
for
effective
pest
control,
but
strategies
must
be
developed
so
they
are
ready
for
commercial
applications.

The
combination
of
1,3­
D
and
metam
sodium
is
not
technically
feasible
because
it
does
not
consistently
control
pests
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3­
D
is
a
good
nematicide
and
metam
sodium
provides
moderate,
but
unpredictable
disease,
nematode,
and
weed
control.
As
indicated
above,
metam­
sodium
also
suffers
from
erratic
efficacy,
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
The
combination
of
these
chemicals
would
still
require
a
companion
herbicide
or
hand
weeding.
Failure
to
control
the
weed
seed
in
soil
would
most
likely
lead
to
increased
disease
pressure
over
time.
Also,
in
strawberry
fruit
production,
there
is
demand
for
pest
free
strawberry
root
stock.
The
nursery
growers
who
do
not
supply
this
type
of
product
will
be
forced
out
of
the
market.

As
with
the
other
suggested
combinations
(
above)
there
are
issues
with
the
use
of
Personal
Protective
Equipment
(
PPE)
in
the
hot
or
hot
and
humid
climates
of
California
and
the
southeastern
U.
S.
In
addition,
the
buffer
requirement
of
90
meters
(
300
feet)
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas.
For
small
strawberry
nursery
operations
in
the
southeastern
U.
S.,
the
1,3­
D
buffer
requirements
eliminate
a
large
area
around
the
field
perimeter,
which
impacts
the
total
acreage
available
for
strawberry
nursery
production.

Sequential
application
of
each
one
of
these
chemicals
requires
significantly
more
time
than
using
MB
alone
since
growers
must
wait
longer
after
fumigation
to
put
the
strawberry
root
stock
in
the
ground.
Growers
have
a
greater
planting
delay
for
several
weeks,
which
will
extend
their
production
schedule.
This
delay
directly
impacts
cultivar
options,
Integrated
Pest
Management
practices,
timing
of
planting
and
harvest
for
strawberry
fruit
production,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
Since
growers
will
require
rootstock
at
a
fixed
time
during
the
year,
the
nursery
plants
could
be
of
lower
grade
and
quality
(
smaller)
causing
loss
to
both
the
nursery
grower
and
the
fruit
grower.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Strawberry
Nursery
18
SOUTHEASTERN
STATES
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
SOUTHEASTERN
STATES
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Other
fungicides,
herbicides,
or
nematicides.
There
are
no
other
pesticides
(
with
the
exception
of
iodomethane)
in
the
registration
process
that
can
take
the
place
of
MB.

SOUTHEASTERN
STATES
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS.
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
SOUTHEASTERN
STATES
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Iodomethane
Not
registered
for
any
crop
uses
in
the
US.
Yes
Unknown
Propargyl
bromide
Registration
in
the
U.
S.
has
not
been
requested.
No
Unknown
Sodium
azide
Registration
in
the
U.
S.
has
not
been
requested.
No
Unknown
U.
S.
Strawberry
Nursery
19
SOUTHEASTERN
STATES
­
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
The
following
study
was
conducted
in
the
southeastern
U.
S.
but
with
methyl
iodide
(
MI)
as
the
principal
treatment
comparing
to
1,3­
D
with
35%
chloropicrin
(
Telone
C­
35)
and
an
untreated
control.
Based
on
researchers'
opinions
from
numerous
studies,
MI
when
used
as
a
soil
fumigant
generally
provides
yields
and
levels
of
pest
control
comparable
to
MB.
Accordingly,
we
assumed
that
the
results
of
the
available
study
are
representative
of
previous
studies
and
can
be
relied
upon
for
assessing
the
comparative
value
of
the
best
available
alternative
(
1,3­
D
+
35%
chloropicrin).

Given
the
soil
types
present
in
production
areas
the
root
zone
required
to
be
protected
is
generally
as
deep
as
1
m.
Although
several
of
the
alternatives
provided
adequate
levels
of
pest
control
at
shallower
depths,
none
consistently
provided
suitable
control
levels
at
1
m.
Failure
to
provide
levels
of
pest
control
at
the
required
depth
will
result
in
inadequate
levels
of
control,
which
will
result
in
rejection
of
the
plants
produced
under
these
conditions
(
100%
loss
in
affected
fields).
Accordingly,
the
maximum
loss
estimate
is
listed
as
100%
because
the
various
state
certification
requirements,
which
equate
to
a
zero
tolerance
for
disease
symptoms
and
nematodes.

SOUTHEASTERN
STATES
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
CERTAIN
WEEDS
%
MB
Pest
Control
Treatment
Application
Rate
(
kg/
ha)
Nem.
Dis.
Weeds
%
MB
Yield
Comments
Methyl
Iodide
(
100%)
263
NQ
NQ
Assume
100%
Assume
100%
No
MB
tested
Methyl
Iodide/
Chloropicrin
(
75:
25)
263/
66
NQ
NQ
92%
81%

1,3­
D/
Chloropicrin
(
Telone
C­
35)
254/
139
NQ
NQ
87%
73%

Source:
Gilreath,
J.
P.,
E.
B.
Poling,
J.
W.
Noling,
2001,
unpublished
study
Key
to
Table
Abbreviations:
NQ
=
not
quantified
(
too
low
and
non­
uniform);
Nem.
=
nematodes;
Dis.
=
diseases
MI
alone
yield
was
statistically
higher
than
the
combination
with
chloropicrin
(
CP)
and
the
1,3­
D/
CP
treatments.
There
was
no
statistical
difference
between
these
later
two
treatments,
however,
they
both
provided
statistically
higher
yields
than
the
untreated
controls.
The
prominent
weeds
present
were
hairy
galinsoga
(
Galinsoga
cillata),
carpetweed
(
Mollugo
verticillata),
and
purslane
(
Portulaca
oleracea).
The
most
difficult
weed
to
control
was
hairy
galinsoga,
with
MI
alone
providing
the
highest
levels
of
control
of
this
as
well
as
the
other
weeds.
The
post
treatment
disease
and
nematode
incidence
data
were
too
variable
and
too
low
in
any
of
the
plots
to
formulate
any
conclusions.
The
yield
benefit
exhibited
by
MI
is
likely
to
be
a
combination
of
weed
control
plus
control
of
other
unidentified
microbial
pests.
The
comparative
weed
control
percentages
are
based
solely
on
control
of
hairy
galinsoga.
U.
S.
Strawberry
Nursery
20
SOUTHEASTERN
STATES
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D/
chloropicrin
(
Telone
C­
35)
Certain
Weeds
(
see
above
table)
0­
27%
10%

Metam
Sodium
Certain
Weeds
(
see
above
table)
50%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
10%

SOUTHEASTERN
STATES
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE
Iodomethane
is
in
a
pending
registration
status
and
is
being
evaluated
as
an
alternative.
It
is
generally
considered
to
be
as
effective
as
MB
for
most
preplant
crop
uses
and
nearly
all
pests.
Growers
could
easily
transition
to
this
alternative.

Dazomet
is
also
in
a
pending
registration
status
as
a
nematicide
on
strawberries.
The
efficacy
in
the
southeastern
U.
S.
is
unclear.

SOUTHEASTERN
STATES
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE
There
are
no
replacements
for
MB
currently
because
of
the
strict
requirements
of
producing
pest
free
nursery
stock.
The
technology
changeover
costs
for
adopting
soilless
culture
techniques
are
high.
Although
yields
reportedly
obtained
through
greenhouse
production
are
higher
than
that
of
the
best
conventional
growers,
capitalization
for
this
and
other
sectors
makes
the
alternative
not
feasible
as
a
near
term
strategy
to
reduce
reliance
on
MB.
No
information
was
presented
on
the
long
term
viability
of
this
option.
The
organic
strawberry
fruit
growers
are
dependent
upon
MB
treated
transplants
to
enable
them
to
grow
strawberries
with
limited
pest
problems.
U.
S.
Strawberry
Nursery
21
SOUTHEASTERN
STATES
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Protocols
for
effective
use
of
the
alternatives
have
not
been
sufficiently
developed
at
this
time
to
provide
acceptable
control
of
major
pests
in
commercial
strawberry
nurseries
in
the
southeastern
U.
S.
The
use
of
these
alternatives
will
require
further
study
before
growers
can
be
confident
that
they
are
able
to
effectively
control
such
major
pests
as
yellow
and
purple
nutsedges,
which
are
limiting
factors
in
nursery
production
in
this
area.
The
consortium
is
currently
developing
a
timeline
to
describe
the
transition
from
MB
to
alternatives.
Research
has
been
cited
from
California
(
e.
g.,
Kabir
et
al.,
2003)
that
gives
hope
for
MB
replacement
or
reduction
for
this
sector,
but
the
need
for
MB
for
the
short
term
is
critical
until
protocols
are
developed
sufficiently
for
use
in
commercial
strawberry
nursery
operations
in
both
southeastern
and
California
nursery
sites.

Key
alternatives
are
1,3­
D)/
chloropicrin,
1,3­
D/
chloropicrin/
metam­
sodium,
and
1,3­
D/
metam­
sodium.
Dazomet
is
also
a
possible
alternative
probably
in
combination
with
chloropicrin
and/
or
1,3­
D.
These
chemicals,
in
addition
to
developing
strategies
for
use
of
tarps,
such
as
virtually
impermeable
films,
may
ultimately
reduce
or
replace
MB.
However,
after
long
term
MB
use,
strategies
for
new
treatments
must
be
researched
and
transferred
for
commercial
applications.
U.
S.
Strawberry
Nursery
22
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
California
Diseases:
Phytophthora
Crown
and
Root
Rots
(
Phytophthora
spp.);
Red
Stele
(
Phytophthora
fragariae);
Verticillium
Wilt
(
Verticillium
dahliae);

Nematodes:
Root­
knot
(
Meloidogyne
spp.);
sting
(
Belonolaimus
spp.);
dagger
(
Xiphinema
spp.);
lesion
(
Pratylenchus
spp.);
foliar
(
Aphelenchoides
spp.);
needle
(
Longidorus
spp.);
stem
(
Ditylenchus
spp.)

Weeds:
numerous
weeds
listed
(
e.
g.,
annual
bluegrass,
bur
clover,
carpetweed,
chickweed,
field
bindweed,
goat
grass,
hairy
nightshade,
lambsquarter,
malva,
nutsedge,
pig
weed,
portulaca,
prostate
spurge,
puncture
vine,
purslane,
vetch)
The
state
mandatory
certification
program
has
strict
requirements
for
control
of
diseases
and
nematodes,
which
amount
to
near
complete
control
of
the
key
pests.
Given
the
growing
situations
encountered
over
the
course
of
the
5­
year
transplant
production
cycle
(
a
different
growing
location
is
used
each
year),
none
of
the
alternatives
have
thus
far
been
shown
to
consistently
perform
with
sufficient
efficacyl
at
soil
depths
to
1
m.

There
is
research
being
conducted
that
hints
at
acceptable
alternatives
to
MB
(
e.
g.,
Kabir
et
al.,
2003)
but
currently
there
is
a
critical
need
for
MB
until
commercial
application
of
research
findings
are
instituted.

Methyl
iodide
is
considered
by
most
researchers
to
be
a
potentially
effective
alternative,
but
it
is
currently
not
registered
in
the
US.

CALIFORNIA
 
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
CALIFORNIA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Strawberry
transplants
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
crop,
only
planted
in
the
same
location
once
every
three
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
The
principal
rotational
crops
are
endive,
garlic,
onion,
horseradish,
mint,
alfalfa,
sugarbeets,
and
potatoes.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
80
%
light
soils,
10%
medium
soils
and
10%
heavy
soils;
70%
with
2%
or
less
organic
matter
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Every
year
OTHER
RELEVANT
FACTORS:
No
U.
S.
Strawberry
Nursery
23
CALIFORNIA
(
LOW
ELEVATION
AREAS;
YEARS
3
&
4)
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
6a,
6b,
7a,
9a,
9b
RAINFALL
(
mm)
16
72.1
17.3
0
trace
1.0
trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
X
HARVEST
SCHEDULE
X
*
For
Fresno,
California.

CALIFORNIA
(
HIGH
ELEVATION
AREAS;
YEAR
5)
­
TABLE
11.3
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
6a,
6b,
7a,
9a,
9b
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
HARVEST
SCHEDULE
X
X
X
CALIFORNIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Legal
restrictions
of
some
alternatives
and
certain
soil
moisture
conditions
can
have
an
impact
on
use.
U.
S.
Strawberry
Nursery
24
CALIFORNIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003
AREA
TREATED
(
hectares)
1,153
1,267
1,283
1,295
1,477
1,551
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
All
Flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
313,200
341,230
337,604
341,022
389,069
408,530
FORMULATIONS
OF
METHYL
BROMIDE
(
e.
g.
methyl
bromide
98:
2;
methyl
bromide
/
chloropicrin
70:
30)
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
Flat
fumigation
soil
injection
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
408
404
395
395
395
395
APPLICATION
RATE
OF
METHYL
BROMIDE
IN
kg/
ha*
272
269
263
263
263
263
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
40.8
40.4
39.5
39.5
39.5
39.5
ACTUAL
DOSAGE
RATE
OF
METHYL
BROMIDE
(
g/
m2)*
27.2
26.9
26.3
26.3
26.3
26.3
*
For
Flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Strawberry
Nursery
25
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
Please
see
the
description
above
under
the
Southeastern
U.
S.
(
Southeastern
U.
S.
Table
13.1).

CALIFORNIA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
CALIFORNIA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
Please
see
the
description
in
the
Southeastern
U.
S.
above
(
Southeastern
U.
S.
Table
14.1).

CALIFORNIA
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
CALIFORNIA
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
State
if
registered
for
this
crop,
registered
for
crop
but
use
restricted,
registered
for
other
crops
but
not
target
crop,
or
not
registered
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Iodomethane
Not
registered
for
any
crop
uses
in
the
U.
S.
Yes
Unknown
Sodium
Azide
Not
submitted
for
registration.
No
Unknown
Propargyl
bromide
Not
submitted
for
registration.
No
Unknown
CALIFORNIA
­
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
Numerous
studies
have
been
referenced
(
see
section
26)
in
the
two
applications
(
Southeastern
States
[
Maryland,
North
Carolina,
Tennessee],
and
California).
Several
studies
suggest
that
alternatives
(
most
likely
combination
of
alternatives)
have
potential
as
MB
replacements,
but
not
in
the
immediate
future.
This
is
because
after
so
many
years
of
reliance
on
MB,
protocols
for
alternative
treatments
have
to
go
through
the
long
process
of
research
and
development
before
they
are
commercially
available.
This
is
especially
true
for
managing
pests
subject
to
the
rigorous
requirements
of
California's
nursery
certification
program.
Table
16.4
exemplifies
the
difficulty
in
transtioning
to
alternatives,
given
their
variability.
Even
though
some
studies
have
shortcomings,
in
terms
of
the
procedures
used
or
the
information
reported,
the
overall
conclusion
U.
S.
Strawberry
Nursery
26
is
that
none
of
the
chemical
and/
or
non­
chemical
alternatives
can
immediately
be
substituted
for
MB.
Therefore,
for
the
current
nomination,
MB
is
considered
critical
for
the
strawberry
nursery
sector.
Consortia
are
currently
developing
timelines
to
detail
their
schedules
for
transition
from
MB
to
alternatives.

While
no
immediate
replacements
are
currently
available
to
address
the
most
severe
pest
problems,
research
from
California
(
e.
g.,
Kabir
et
al.,
2003)
(
see
Tables
16.5a
and
16.5b,
below),
suggests
that
strawberry
nurseries
may
have
alternatives
to
MB
that
will
result
in
healthy
nursery
stock
that
will
be
comparable
to
MB
treated
plants,
even
in
terms
of
fruit
yield
after
field
planting.
Small
scale
research
results
suggested
that
the
use
of
chloropicrin
followed
by
dazomet
produced
yields
(
during
some
years
of
the
study)
at
least
as
high
as
MB
treated
soil.
The
issues
of
consistency
and
scale­
up
to
commercial
use
are
still
outstanding,
and
this
study
did
not
evaluate
specific
pests,
use
of
tarps,
or
consider
California
certification
requirements.
Therefore,
there
is
a
critical
need
for
MB
until
the
efficacy
of
alternative
treatments
can
be
confirmed.

When
one
takes
into
account
that
the
five­
year
production
system
involves
new
planting
sites
each
year,
consistency
is
important
in
satisfying
the
needs
of
their
international,
interstate
and
intrastate
customers.
The
inconsistency
in
performance
of
the
alternatives
most
likely
results
from
the
application
methods,
application
rates,
formulations
of
alternatives,
soil
and
weather
conditions,
and
pest
species
and
levels
present
in
tests.
Experience
with
techniques
in
application
of
alternatives,
and
interactions
of
several
alternatives,
should
improve
efficacy.

The
root
zone
to
be
protected
is
as
deep
as
1
m.
Although
several
of
the
alternatives
provide
adequate
levels
of
pest
control
at
shallower
depths,
none
consistently
provide
suitable
control
levels
at
1
m.
Failure
to
provide
levels
of
pest
control
at
the
required
depth
will
result
in
inadequate
levels
of
control,
which
will
result
in
rejection
of
the
plants
produced
under
these
conditions
(
100%
loss
in
affected
fields).
U.
S.
Strawberry
Nursery
27
CALIFORNIA
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
CHEMICAL
ALTERNATIVES
TO
METHYL
BROMIDE
FUMIGATION
 
HOW
WELL
DO
THEY
WORK?
Treatment
Application
Method
&
Rate
(
kg/
ha)
Pest
Control
(%
of
MB)
Yield
(%
of
MB)
Comments
NEM
DIS.
MB/
CP
(
67:
33)
MB:
246kg/
ha;
CP:
121
kg/
ha;
chisel
injection
&
tarped
+
+
100
1,3­
D/
CP
(
70:
30)
1,3­
D:
361
kg/
ha;
CP:
155
kg/
ha;
chisel
injection
&
tarped
+
+
96
Chloropicrin
(
CP)
95­
189;
and
190
and
higher;
chisel
injection
&
tarped
+
+
89
(<
190kg/
ha);

103
(>
190
kg/
ha)
Evaluated
both
low
and
high
dosage
rates
Metam
Sodium
950
kg/
ha;
surface
drench
and
tarped
+
+
92
Dazomet
340
kg/
ha;
broadcast,
tilled
into
soil,
and
tarped
+
+
95
Enzone
(
sodium
tetra
thiocarbonate)
2.85
kg/
ha
tarped
+
+
80
Not
registered
for
use
on
strawberries
UTC
+
+
70
Source:
Gubler,
W.
D.,
J.
M.
Duniway,
and
N.
Welch.
1996.
Chemical
Alternatives
to
Methyl
Bromide
Fumigation
 
How
Well
Do
They
Work?

Key
to
Abbreviations:
1,3­
D
=
1,3­
dichloropropene;
MB
=
methyl
bromide;
CP
=
chloropicrin;
MS
=
metam
sodium;
UTC
=
untreated
control;
Nem.
=
nematodes;
Dis.
=
diseases
Watsonville,
CA
1993
study
using
large­
scale
plots;
low
levels
of
Phytophthora
crown
and
root
rots,
Verticillium
wilt,
and
nematodes;
one­
year
evaluation
only
U.
S.
Strawberry
Nursery
28
CALIFORNIA
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
CHLOROPICRIN
EFFECT
ON
WEED
SEED
VIABILITY.

Control
Measures
Evaluated
Application
Method
&
Rate
(
kg/
ha)
Weed
Control
(%
of
MB)
Comments
MB/
CP
(
67:
33)
MB:
225
kg/
ha
CP:
111
kg/
ha;
soil
injection
100
Very
good
control
of
3
weeds;
no
control
of
2
weeds
(
mallow
&
filaree)

Metam
Sodium
(
MS)
MS:
197
kg/
ha;
drip
irrigation
Comp.
Very
good
control
of
3
weeds;
no
control
of
2
weeds
(
mallow
&
filaree)

MS
plus
CP
MS:
197kg
/
ha
drip
irrigation;
CP:
83
 
220
kg/
ha
soil
injection
Very
Comp.
produced
a
slight
increase
in
weed
control
over
MS
alone
=
best
available
treatment
for
the
weed
species
present
Chloropicrin
(
CP)
CP:
83
 
220
kg/
ha
soil
injection
Comp.
good
control
of
3
weeds
at
the
higher
rates;
no
control
of
2
weeds
(
mallow
&
filaree)

UTC
none
Source:
Haar,
M.
J.,
S.
A.
Fennimore,
H.
A.
Ajwa,
C.
Q.
Winterbottom.
2003.
Chloropicrin
Effect
on
Weed
Seed
Viability.
Key
to
Abbreviations:
CP
=
chloropicrin;
MS
=
metam
sodium;
1,3­
D
=
1,3­
dichloropropene;
UTC
=
untreated
controls;
Comp
=
comparable.

The
study
was
conducted
over
two
years
near
Santa
Maria,
CA.
Primary
weed
pests:
Polygonum
aviculare
(
knot­
grass),
Portulaca
oleracea
(
common
purslane)
and
Malva
parviflora
(
little
mallow)
were
introduced
in
both
years,
whereas,
Stellaria
media
(
chickweed)
and
Erodium
cicutarium
(
red­
stem
filaree)
were
introduced
in
the
second
year;
similar
weed
seed
sensitivity
for
CP
and
MS;
no
yield
data
obtained.

CALIFORNIA
 
TABLE
16.3:
EFFECTIVENESS
OF
ALTERNATIVES
­
SOIL
FUMIGATION
AND
RUNNER
PLANT
PRODUCTION.
Treatment
Application
Method
&
Rate
(
kg/
ha)
Yield
(%
of
MB)
Comments
Methyl
bromide
Chisel
100
(
4
trials)

Chloropicrin
140­
191
kg/
ha
,
chisel
73­
92
(
3
trials)

Chloropicrin
 
300
kg/
ha,
Chisel;
86
 
100
(
4
trials)
Appeared
to
be
the
best
of
the
alternatives
evaluated
1,3­
D/
Chloropicrin
(
70:
30)
Chisel;
84
(
1
trial)
Did
not
rank
very
high
as
an
alternative
due
to
reduced
plant
growth
and
runner
production
1,3­
D/
Chloropicrin
(
30:
70)
Chisel
91
(
1
trial)
Appeared
to
perform
similar
to
the
high
rate
of
chloropicrin
UTC
Not
Applicable
38­
55
(
4
trials)

Source:
Larson,
K.
D.
and
D.
V.
Shaw,
2000,
Soil
Fumigation
and
Runner
Plant
Production:
A
Synthesis
of
Four
Years
of
Strawberry
Nursery
Field
Trials,
Hort
Sci.
35
(
4):
642­
646.
Key
to
Abbreviations:
1,3­
D
=
1,3­
dichloropropene;
UTC
=
untreated
controls.
U.
S.
Strawberry
Nursery
29
This
study
was
conducted
on
former
strawberry
nursery
soils,
however,
other
crops
were
planted
in
these
soils
prior
to
initiating
this
study;
fumigants
chiseled
into
soil
at
a
36
cm
depth
and
covered
with
a
tarp
for
7
days;
pest
types
and
pressures
uncertain,
however,
Verticillium
wilt
(
V.
albo­
atrum)
was
detected
in
some
locations
and
roots
were
examined
for
decay
and
discoloration,
with
the
untreated
plants
(
UTC)
exhibiting
most
of
the
disease
symptoms;
nematodes
were
not
considered
to
be
a
problem
in
any
of
the
test
locations.
It
should
be
noted
that
the
main
focus
of
this
study
was
to
evaluate
yield
responses
and
that
quantification
of
the
various
pest
organisms
was
beyond
the
scope
of
this
study.

CALIFORNIA
 
TABLE
16.4:
EFFECTIVENESS
OF
ALTERNATIVES
­
EVALUATION
OF
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
SOIL
FUMIGATION
AT
COMMERCIAL
FRUIT
AND
NUT
TREE
NURSERIES
Treatment
Application
Method
&
Rate
(
kg/
ha)
Nematode
Control
(%
of
MB)

Methyl
bromide
/
chloropicrin
(
75:
25)
MB:
448
kg/
ha;

CP:
151
kg/
ha
100
1,3­
D/
CP
1,3­
D:
518
kg/
ha;

CP:
283
kg/
ha
83­
100
1,3­
D
+
Metam
Sodium
Sequential
application;
1,3­
D:
518
kg/
ha;

MS:
(?)
kg/
ha.
16­
100
1,3­
D/
dazomet
Sequential
application;
396
kg/
ha;
224
kg/
ha
DZ
28­
100
Source:
McKenry,
M.
V.,
2001.
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries,
California
Department
of
Pesticide
Regulation
(
Contract
#
99­
0218).

Key
to
Abbreviations:
1,3­
D
=
;
CP
=
;
MB
=
;
DZ
=
dazomet;
Prominent
nematode
pests
present:
lesion
(
Pratylenchus
spp.),
spiral
(
Helicotylenchus
dihystera),
dagger
(
Xiphinema
americanum)
and
some
root­
knot
(
Meloidogyne
spp.)
U.
S.
Strawberry
Nursery
30
CALIFORNIA
 
TABLE
16.5a
and
16.5b:
EFFECTIVENESS
OF
ALTERNATIVES
­
EVALUATION
OF
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
THE
CONTROL
OF
SOIL
PESTS:
STRAWBERRY
AS
A
MODEL
SYSTEM
Table
16.5a.
FRUIT
YIELD
(
GRAMS
PER
PLANT)
OF
STRAWBERRY
AT
WATSONVILLE,
CA
IN
2002.
[
The
`
nursery'
column
indicates
the
treatment
of
nursery
plants
grown
in
2001;
the
`
field'
column
indicates
the
fumigation
treatment
in
the
field.]
Nursery
treatment
(
high
elevation,
MacDoel,
CA)
Field
treatment
(
Watsonville)
Marketable
yield
(
g/
plant)
Unmarketable
yield
(
g/
plant)
Total
yield
(
g/
plant)

control
Pic
1301.7
535.6
1837.3
MB/
Pic
Pic
1235.8
550.9
1786.6
MI/
Pic
Pic
1278.2
525.0
1803.3
Pic
followed
by
dazomet
Pic
1388.4
575.1
1963.4
Telone
C35
followed
by
dazomet
Pic
1346.4
553.3
1899.7
control
MB/
Pic
1520.3
600.1
2120.4
MB/
Pic
MB/
Pic
1474.0
596.3
2070.3
MI/
Pic
MB/
Pic
1526.8
625.0
2151.8
Pic
followed
by
dazomet
MB/
Pic
1634.5
640.6
2275.1
Telone
C35
followed
by
dazomet
MB/
Pic
1434.1
634.0
2068.1
ANOVA
­­­­­­­­­­­­­­­­­­­­­­­­­
P
values­­­­­­­­­­­­­­­­­­­­­­

Nursery
0.04*
0.24
0.07
Field
<
0.0001*
<
0.0001*
<
0.0001*

Nursery
(
field)
0.47
0.74
0.73
*
indicates
significance
Source:
Kabir,
Z.,
Fennimore,
S.,
Martin,
F.,
Ajwa,
H.,
Duniway,
J.,
Browne,
G.,
Winterbottom,
C.,
Westerdahl,
B.,
Goodhue,
R.,
Guerrero,
L.,
Haar,
M.
2003.
Alternative[
s]
Fumigants
for
the
Control
of
Soil
Pests:
Strawberry
as
a
Model
System.
Methyl
Bromide
Alternatives
Conference
(
2003).
www.
mbao.
org.

Key
to
Abbreviations:
For
nursery
treatments:
control=
no
fumigation;
methyl
bromide/
chloropicrin
(
MB/
Pic)
=
57:
43,
450
kg/
ha;
methyl
iodide/
chloropicrin
(
MI/
Pic)
=
50:
50,
392
kg/
ha;
1,3­
D/
chloropicrin
(
Telone
C35)
(
300
liters/
ha)
followed
by
dazomet
(
280
kg/
ha);
chloropicrin
(
Pic)
(
336
kg/
ha)
followed
by
dazomet
(
280
kg/
ha).

For
field
treatments:
control=
no
fumigation;
MB/
Pic,
67:
33
(
392
kg/
ha);
Pic
(
224
kg/
ha).
U.
S.
Strawberry
Nursery
31
Table
16.5b.
FRUIT
YIELD
(
GRAMS
PER
PLANT)
OF
STRAWBERRY
AT
WATSONVILLE,
CA
IN
2003.
[
The
`
nursery'
column
indicates
the
treatment
of
nursery
plants
grown
in
2002;
the
`
field'
column
indicates
the
fumigation
treatment
in
the
field.]
Nursery
treatment
(
high
elevation,
MacDoel,
CA)
Field
treatment
(
Watsonville)
Marketable
yield
(
g/
plant)
Unmarketable
yield
(
g/
plant)
Total
yield
(
g/
plant)

control
Pic
1270.2
1092.5
2362.7
MB/
Pic
Pic
1244.2
1070.5
2314.7
MI/
Pic
Pic
1153.7
992.9
2146.6
Pic
followed
by
dazomet
Pic
1324.6
1059.4
2384.0
Telone
C35
followed
by
dazomet
Pic
1220.2
1069.7
2289.9
control
MB/
Pic
1177.2
1216.1
2393.3
MB/
Pic
MB/
Pic
1132.2
1179.8
2311.9
MI/
Pic
MB/
Pic
1050.8
1106.2
2157.0
Pic
followed
by
dazomet
MB/
Pic
1166.9
1249.2
2416.0
Telone
C35
followed
by
dazomet
MB/
Pic
1111.0
1176.9
2287.9
ANOVA
­­­­­­­­­­­­­­­­­­­­­­­­­
P
values­­­­­­­­­­­­­­­­­­­­­­

Nursery
0.001*
0.003*
0.0001*

Field
<
0.0001*
<
0.0001*
0.70
Nursery
(
field)
0.92
0.60
0.99
*
indicates
significance
Source:
Kabir,
Z.,
Fennimore,
S.,
Martin,
F.,
Ajwa,
H.,
Duniway,
J.,
Browne,
G.,
Winterbottom,
C.,
Westerdahl,
B.,
Goodhue,
R.,
Guerrero,
L.,
Haar,
M.
2003.
Alternative[
s]
Fumigants
for
the
Control
of
Soil
Pests:
Strawberry
as
a
Model
System.
Methyl
Bromide
Alternatives
Conference
(
2003).
www.
mbao.
org.

Key
to
Abbreviations:
For
nursery
treatments:
control=
no
fumigation;
methyl
bromide/
chloropicrin
(
MB/
Pic)
=
57:
43,
450
kg/
ha;
methyl
iodide/
chloropicrin
(
MI/
Pic)
=
50:
50,
392
kg/
ha;
1,3­
D/
chloropicrin
(
Telone
C35)
(
300
liters/
ha)
followed
by
dazomet
(
280
kg/
ha);
chloropicrin
(
Pic)
(
336
kg/
ha)
followed
by
dazomet
(
280
kg/
ha).

For
field
treatments:
control=
no
fumigation;
MB/
Pic,
67:
33
(
392
kg/
ha);
Pic
(
224
kg/
ha).

This
strawberry
yield
research
study
was
conducted
at
three
strawberry
runner
nurseries.
Plants
were
grown
for
three
years
at
two
high
elevation
nurseries
(
HEN)
or
for
two
years
at
a
low
elevation
nursery
(
LEN).
Plants
were
then
placed
in
two
different
field
locations
(
Watsonville
and
Oxnard)
for
marketable
yield
assessments.
Plants
received
various
fumigation
treatments
at
both
nursery
and
field
locations
(
results
from
two
trials,
conducted
in
2002
and
2003,
are
presented
in
Tables
16.5a
and
16.5b,
above).

Pests
were
not
identified
and
only
yields
were
evaluated.
In
the
2002
test,
" 
fruit
yield
was
significantly
greater
under
the
on­
site
MBPic
treatment
than
in
Pic
treatment
alone"
(
Table
16.5a).
The
fumigants
used
at
the
nursery
had
" 
positive
carryover
effects
on
marketable
fruit
U.
S.
Strawberry
Nursery
32
yield
when
the
treatment
was
Pic
[
followed
by]
Basamid".

The
results
at
the
Watsonville
location
for
the
2003
test
showed
" 
marketable
fruit
yield
was
increased
(
9%)
in
on­
site
Pic
treatments
compared
to
MBPic
treatments.
In
contrast,
nonmarketable
fruit
yield
was
significantly
greater
(
4%)
under
MBPic
than
under
Pic
(
Table
16.5b).
The
authors
again
noted
that
the
nursery
treatments
had
significant
carryover
effects
on
the
fruit
yield.
They
" 
suggest
that
application
of
Pic
fb
[
followed
by]
Basamid
[
dazomet]
at
the
HEN
increased
runner
plant
production,
which
eventually
improved
fruit
yield
with
Pic
in
the
fruiting
field.
Pic
could
be
a
viable
alternative
to
MBPic".
No
interaction
was
found
between
the
fumigations
at
the
nursery
and
field,
therefore,
the
effects
were
considered
additive.

CALIFORNIA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D/
Chloropicrin
Certain
weeds
0­
27%
10%
1,3­
D
+
Metam
Sodium
Certain
weeds
­­­
13%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
10­
13%

CALIFORNIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

California­
Table
15.1
for
status
of
iodomethane.
This
fumigant
is
unregistered,
but
is
reported
to
be
a
potential
suitable
alternative
for
all
key
pests.

Dazomet
is
also
in
a
pending
registration
status
as
a
nematicide
on
strawberries
and
may
be
an
effective
alternative,
especially
when
combined
with
other
treatments
(
e.
g.,
Kabir
et
al.,
2003).

CALIFORNIA
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE
Because
of
strict
requirements
for
pest
free
nursery
stock,
only
in
limited
areas
can
strawberry
nursery
plants
be
produced
safely
without
MB.
A
shift
to
soilless
cultivation
would
require
a
major
shift
in
production
and
would
result
in
a
significant
market
disruption
for
the
near
term.
U.
S.
Strawberry
Nursery
33
CALIFORNIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Strict
requirements
for
pest
free
nursery
plants
make
MB
a
critical
tool
for
nursery
growers,
at
least
for
the
near
future.
Protocols
for
effective
use
of
the
alternatives
that
were
discussed
above,
have
not
been
sufficiently
developed
at
this
time
to
provide
sufficient
control
of
such
major
pests
as
nematodes
and
root
rot
pathogens
in
commercial
strawberry
nurseries
in
California.
The
use
of
these
alternatives
will
require
further
study
before
growers
can
be
confident
that
they
are
able
to
effectively
control
these
pests,
which
are
limiting
factors
in
nursery
production.
Research
has
been
cited
from
California
(
e.
g.,
Kabir
et
al.,
2003)
that
gives
hope
for
MB
replacement
or
reduction
for
this
sector,
but
the
need
for
MB
for
the
short
term
is
critical
until
protocols
are
developed
sufficiently
for
use
in
commercial
strawberry
nursery
operations
in
both
California
and
southeastern
nursery
sites.
Timelines
are
being
developed
to
outline
the
industry's
transition
to
alternatives.

Key
alternatives
are
1,3­
D/
chloropicrin,
1,3­
D/
chloropicrin/
metam­
sodium,
and
1,3­
D/
metamsodium
Dazomet
is
also
a
possible
alternative
probably
in
combination
with
chloropicrin
and/
or
1,3­
D.
These
chemicals,
in
addition
to
developing
strategies
for
use
of
tarps,
such
as
VIF,
may
ultimately
reduce
or
replace
MB.
Currently,
high
barrier
films
are
in
use
in
California
and
have
helped
to
reduce
the
rates
of
MB.
VIF
are
restricted
in
California
and
there
are
concerns
about
acceptable
off­
gassing
rates.
Strategies
for
new
treatments
must
be
researched
and
transferred
for
commercial
applications.
U.
S.
Strawberry
Nursery
34
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
Currently,
most
growers
use
HDPE
tarps;
VIF
is
restricted
in
California.
Between
1997
and
2002
the
dosage
rate
of
methyl
bromide
has
dropped
by
one
eighth.
All
use
67:
33
For
certification
of
nursery
stock,
fumigation
must
occur
prior
to
every
planting
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Research
is
underway
to
develop
use
in
commercial
production
systems
Possible
changeover
from
broadcast
to
raised
bed
band
treatments,
Unidentified
For
certification
of
nursery
stock,
fumigation
must
occur
prior
to
every
planting
OTHER
MEASURES
(
please
describe)
Examination
of
promising
but
presently
unregistered
alternative
fumigants
with
non­
chemical
methods.
Unidentified
Unidentified
For
certification
of
nursery
stock,
fumigation
must
occur
prior
to
every
planting
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
Tarpaulins
(
high
density
polyethylene,
mostly
experimental
use
of
virtually
impermeable
film)
are
used
to
minimize
use
and
emissions
of
MB.
In
addition,
practices
such
as
deep
injection
are
used
by
strawberry
nursery
growers
to
reduce
the
MB
rates
required
for
growing
nursery
stock.
U.
S.
Strawberry
Nursery
35
PART
E:
ECONOMIC
ASSESSMENT
The
following
economic
analysis
is
organized
by
MeBr
critical
use
application.
Cost
of
MeBr
and
alternatives
are
given
first
in
table
21.1.
This
is
followed
in
table
22.1
by
a
listing
of
net
and
gross
revenues
by
applicant.
Expected
losses
when
using
MeBr
alternatives
are
then
decomposed
in
tables
E1
and
E2.

Reader
please
note
that
in
this
study
net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
of
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
should
be
smaller
than
the
net
revenue
measured
in
this
study.
We
did
not
include
fixed
costs
because
it
is
often
difficult
to
measure
and
verify.

21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
OPERATING
COSTS
WITH
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
REGION
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)

Methyl
Bromide
100
$
30,245
$
30,245
$
30,245
Metam
Sodium
50
$
29,927
$
29,927
$
29,927
SOUTHEASTERN
STATES
1,3­
P+
Pic
90
$
31,513
$
31,513
$
31,513
Methyl
Bromide
100
$
37,831
$
37,831
$
37,831
1,3­
D+
Metam
Sodium
87
$
40,157
$
40,157
$
40,157
CALIFORNIA
1,3­
D+
Pic
90
$
37,664
$
37,664
$
37,664
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
SOUTHEASTERN
STATES­
22.
GROSS
AND
NET
REVENUE
SOUTHEASTERN
STATES­
TABLE
22.1:
YEARS
1,
2,
AND
3
GROSS
AND
NET
REVENUE
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
42,008
$
11,763
Metam
Sodium
$
21,004
$
(
8,923)
1,3­
d+
pic
$
37,807
$
6,294
U.
S.
Strawberry
Nursery
36
CALIFORNIA­
22.
GROSS
AND
NET
REVENUE
CALIFORNIA­
TABLE
22.1:
YEARS
1,
2,
AND
3
GROSS
AND
NET
REVENUE
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
47,741
$
9,909
1,3­
D+
Metam
Sodium
$
41,773
$
1,616
1,3­
D+
Pic
$
42,967
$
5,303
U.
S.
Strawberry
Nursery
37
SOUTHEASTERN
STATES
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
STATES
METHYL
BROMIDE
ALTERNATIVE
METAM
ALTERNATIV
E
1,3­
D+
PIC
YIELD
LOSS
(%)
0%
50%
10%

YIELD
PER
HECTARE
(
PLANTS)
211,715
105,857
190,543
*
PRICE
PER
UNIT
(
US$)
$
0.20
$
0.20
$
0.20
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
42,008
$
21,004
$
37,807
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
30,245
$
29,927
$
31,513
=
NET
REVENUE
PER
HECTARE
(
US$)
$
11,763
$
(
8,923)
$
6,294
LOSS
MEASURE
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
20,686
$
5,469
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
50.15
$
13.26
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
49%
13%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
176%
46%

CALIFORNIA
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
ALTERNATIVE
1,3­
D
METAM
ALTERNATIVE
1,3­
D+
PIC
YIELD
LOSS
(%)
0%
13%
10%

YIELD
PER
HECTARE
(
BOXES)
796
696
716
*
PRICE
PER
UNIT
(
US$)
$
60.00
$
60.00
$
60.00
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
47,741
$
41,773
$
42,967
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
37,831
$
40,157
$
37,664
=
NET
REVENUE
PER
HECTARE
(
US$)
$
9,909
$
1,616
$
5,303
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
8,293
$
4,606
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
31.49
$
17.49
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
17%
10%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
84%
46%
U.
S.
Strawberry
Nursery
38
SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
MB
included
an
evaluation
of
economic
losses
from
three
basic
sources:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
quality
losses,
which
generally
affect
the
price
received
for
the
goods,
and
(
3)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices.

The
economic
reviewers
then
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

(
1)
Losses
as
a
percent
of
gross
revenues.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
2)
Absolute
losses
per
hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.

(
3)
Losses
per
kilogram
of
MB
requested.
This
measure
indicates
the
value
of
MB
to
crop
production
but
is
also
useful
for
structural
and
post­
harvest
uses.

(
4)
Losses
as
a
percent
of
net
revenues.
We
define
net
revenues
as
gross
revenues
minus
operating
costs.
This
is
a
very
good
indicator
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
owners
or
operators
of
an
enterprise.
However,
operating
costs
can
often
be
difficult
to
measure
and
verify.

These
measures
represent
differ
MB
users,
who
are
forest
seedling
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
MB.
The
economic
measures
provide
the
basis
for
making
that
determination.

The
economic
analysis
compared
the
costs
of
MB
alternative
control
scenarios
for
the
Southeastern
Strawberry
Consortium
and
the
California
Strawberry
Growers
Association
to
the
baseline
costs
for
MB.
The
economic
estimates
were
first
calculated
in
pounds
and
acres
and
then
converted
to
kilograms
and
hectares.
The
costs
for
the
alternatives
are
based
on
market
price
for
the
control
products
multiplied
by
the
number
of
pounds
of
active
ingredient
that
would
be
applied.
The
baseline
costs
were
based
on
the
average
number
of
applications
to
treat
strawberry
plants
(
boxes)
with
MB
per
year.
The
loss
per
hectare
measures
the
value
of
MB
based
on
changes
in
operating
costs
and
changes
in
yield.
The
loss
expressed
as
a
percentage
of
the
gross
revenue
is
based
on
the
ratio
of
the
loss
to
the
gross
revenue
using
MB.
Likewise
for
the
loss
as
a
percentage
of
net
revenue.
These
losses
are
shown
in
Tables
E.
1
and
U.
S.
Strawberry
Nursery
39
E.
2.

The
values
to
derive
gross
revenue
and
the
operating
costs
for
each
alternative
were
derived
from
the
baseline
MB
costs
compared
to
the
costs
of
changes
under
two
fumigation
scenarios
in
the
Southeastern
States:
1)
metam
sodium;
and
2)
1,3­
d
+
chloropicrin.

For
California,
the
baseline
MB
costs
were
compared
to
two
scenarios:
1)
1,3­
d
+
metam
sodium;
and
2)
1,3­
d
+
chloropicrin.
The
differences
in
the
cost
of
production
were
primarily
attributable
to
changes
in
fumigation
costs.

One
of
the
issues
facing
nursery
growers
is
that
pest
infestation
can
wipe
out
production
for
the
season.
If
there
are
quality
concerns
such
as
disease,
weeds,
or
insect
infestation,
nursery
growers
will
not
be
able
to
market
their
seedlings.
Fruit
producers
are
not
willing
to
purchase
plants
that
have
any
visual
symptoms
of
disease
and
may
hold
the
nursery
responsible
for
any
disease
that
shows
up
during
fruiting
in
the
field
in
the
first
weeks
after
planting.
A
small
amount
of
contamination
in
nursery
stock
could
be
multiplied
many
times
in
strawberry
fruit
production.
Nearly
a
billion
plants
are
produced
by
the
California
strawberry
nursery
system
alone
each
year
and
this
production
is
distributed
world­
wide.
There
are
approximately
13
seedling/
runner
producers
in
California
that
must
manage
disease
incidence
over
the
4
year
production
cycle
of
the
strawberry
stock.
U.
S.
Strawberry
Nursery
40
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Results
of
ongoing
research
suggest
that
there
are
treatments
for
strawberry
nurseries
that
have
the
potential
to
replace
MB
in
the
future.
However,
because
nursery
stock
is
so
important
to
the
strawberry
fruit
industry,
effective
alternatives
will
be
difficult
to
identify.
The
industry
supports
research
to
identify
the
most
effective
methods
to
treat
soil,
and
as
noted,
some
are
promising
(
e.
g.,
Kabir
et
al.,
2003).
After
possibly
five
years
of
research
trials,
scale­
up
trials
on
a
commercial
level
will
be
done
to
confirm
the
most
effective
treatments
found
in
research
trials.
Combinations
of
several
chemical
and
non­
chemical
controls
are
likely
to
be
the
most
effective
alternative
to
MB.

The
amount
of
MB
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
MB
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimated
that
strawberry
nurseries
research
will
require
454
kg
per
year
of
MB
for
2005
and
2006.
This
figure
will
be
revised
for
use
after
that
time.
That
amount
of
MB
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
One
example
of
the
research
is
a
three
year
study
testing
the
comparative
performance
of
MB,
alternative
fumigants,
preplant
fungicide
dips,
post
plant
fungicides,
germplasm,
microbial
inoculants,
and
cultural
practices.

24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

As
described
in
Section
23.
U.
S.
Strawberry
Nursery
41
25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

The
MB
critical
use
exemption
nomination
for
Strawberry
Nurseries
has
been
reviewed
by
the
U.
S.
Environmental
Protection
Agency
and
the
U.
S.
Department
of
Agriculture
and
meets
the
guidelines
of
The
Montreal
Protocol
on
Substances
That
Deplete
the
Ozone
Layer.
This
use
is
considered
critical
because
there
are
conditions
in
some
nurseries
within
this
sector
with
high
pest
pressure
where
no
feasible
alternatives
or
substitutes
are
currently
effective.
While
some
alternatives
appear
to
offer
an
alternative
to
MB
for
some
pests
in
some
research
trials,
the
high
production
nursery
industry
demands
a
consistent
and
reliable
pre­
plant
fumigation
treatment
that
can
allow
production
goals
to
be
met.
Currently
MB
is
the
only
consistent
provider
of
this
requirement.
The
loss
of
MB,
therefore,
would
result
in
a
significant
market
disruption.
The
effort
to
avoid
market
disruption
provides
the
basis
for
nomination
of
this
sector
for
critical
use
exemption
of
MB.

26.
CITATIONS
REFERENCED
IN
THIS
REPORT
Ajwa,
H.
A.,
Fennimore,
S.,
Kabir,
Z.,
Martin,
F.,
Duniway,
J.,
Browne,
G.,
Trout,
T.,
Goodhue,
R.,
and
Guerrero,
L.
2003.
Strawberry
yield
under
reduced
application
rates
of
chloropicrin
and
Inline
in
combination
with
metam
sodium
and
VIF.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions
(
2003).
www.
mbao.
org.

Ajwa,
H.
A.,
T.
Trout,
J.
Mueller,
S.
Wilhelm,
S.
Nelson,
R.
Soppe,
D.
Shatley.
2002.
Application
of
Alternative
Fumigants
Through
Drip
Irrigation
Systems.
Phytopath
92(
12):
1349­
1355.

Ajwa,
H.,
T.
Trout.
2000.
Distribution
of
Drip
Applied
Fumigants
Under
Various
Conditions.
2000
Annual
International
Research
Conference
on
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APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2001
&
2002
Average
Requested
%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

1,375
5
263
2,654
8
350
4,029
13
315
98%
98%
­
9%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
263
263
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

413
350
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

Strip
Bed
Treatm
ent
Currently
Use
Alternatives?
Research
/

Transition
Plans
T
arps
/

Deep
Injection
Used
Pest­

free
Cert.

Requirement
Change
from
Prior
CU
E
Request
(+/­)
Verified
Historic
M
eBr
Use
/

State
Frequency
of
Treatm
ent
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
M
eBr
(

US$/

kg)
Loss
as
a
%

of
G
ross
Revenue
Loss
as
a
%

of
Net
R
evenue
No
Yes
Yes
Tarp
Yes
+
Yes
2~
5
years
4,606
$
17
$
10%
46%

No
Yes
Yes
Tarp
Yes
+
Yes
2~
5
years
5,469
$
13
$
13%
46%

*
Growth
calculated
after
subtracting
QPS
Conversion
Units:
1
Pound
=
Kilograms
Hectare
High
24%
Low
77%
Not
Available
Regional
Hectares**

Not
Available
Research
Amount
(
kgs)

454
Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)
Unsuitable
Terrain
(%)

(%)
Key
Pest
Distribution
Regulatory
Issues
(%)

(%)
100
ft
Buffer
Zones
CALIFORNIA
SOUTHEASTERN
US
Economic
Analysis
Dichotomous
Variables
(
Y/
N)
Other
Issues
REGION
SOUTHEASTERN
US
CALIFORNIA
SOUTHEASTERN
US
Other
Considerations
Nomination
Amount
Adjustments
to
Requested
Amounts
%
Reduction
from
Initial
Request
0%
0%

REGION
CALIFORNIA
SOUTHEASTERN
US
CALIFORNIA
2007
Nomination
Options
REGION
180,756
180,756
8%
4,029
4,029
Cold
Soil
Temp
(%)

98%
98%

11%
98%

165,963
161,593
1,375
43,292
­
14,793
4,370
21,475
2,654
2,654
136,089
­
(­)
Growth*
4,029
1,375
­
­

Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

393,544
1,455
270
94%

TOTAL
OR
AVERAGE
180,756
627
288
1,386
263
99%

43,292
105
413
28,499
69
413
89%

137,464
522
263
365,045
2007
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

REGION
Sector:
STRAWBERRY
NURSERY
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
%
of
Average
Hectares
Requested:

Date:
1/
28/
2005
Methyl
Bromide
Critical
Use
Exemption
Process
Average
Hectares
in
the
US:

Most
Likely
Impact
Value:
Quality/
Time/
Market
Window/

Yield
Loss
(%)
Marginal
Strategy
10%
10%
1,3­
D
+
Pic
1,3­
D
+
Pic
1
Acre
=
0.404686
137,464
2007
Request
0.453592
MOST
LIKELY
IMPACT
VALUE
Combined
Impacts
(%)

(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
(­)
Double
Counting
U.
S.
Strawberry
Nursery
47
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
U.
S.
Strawberry
Nursery
48
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
topography
 
Percent
karst
topography
is
the
proportion
of
the
land
area
in
a
nomination
that
is
characterized
by
karst
formations.
In
these
areas,
the
groundwater
can
easily
become
contaminated
by
pesticides
or
their
residues.
Regulations
are
often
in
place
to
control
the
use
of
pesticide
of
concern.
Dade
County,
Florida,
has
a
ban
on
the
use
of
1,3D
due
to
its
karst
topography.
17.
(%)
100
ft
Buffer
Zones
 
Percentage
of
the
acreage
of
a
field
where
certain
alternatives
to
methyl
bromide
cannot
be
used
due
the
requirement
that
a
100
foot
buffer
be
maintained
between
the
application
site
and
any
inhabited
structure.
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
example,
the
key
pest
in
Michigan
peppers,
Phytophthora
spp.
infests
approximately
30%
of
the
vegetable
growing
area.
In
southern
states
the
key
pest
in
peppers
is
nutsedge.
19.
Regulatory
Issues
(%)
­
Regulatory
issues
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
their
use.
20.
Unsuitable
Terrain
(%)
 
Unsuitable
terrain
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance)
or
terrain
configuration,
such
as
hilly
terrain.
Where
the
use
of
alternatives
poses
application
and
coverage
problems.
21.
Cold
Soil
Temperatures
 
Cold
soil
temperatures
is
the
proportion
of
the
requested
acreage
where
soil
temperatures
remain
too
low
to
enable
the
use
of
methyl
bromide
alternatives
and
still
have
sufficient
time
to
produce
the
normal
(
one
or
two)
number
of
crops
per
season
or
to
allow
harvest
sufficiently
early
to
obtain
the
high
prices
prevailing
in
the
local
market
at
the
beginning
of
the
season.
22.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
soil
impacts,
temperature,
etc.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
For
example,
if
50%
of
the
requested
area
had
moderate
to
severe
key
pest
pressure
and
50%
of
the
requested
area
had
karst
topography,
then
75%
of
the
area
was
assumed
to
require
methyl
bromide
rather
than
the
alternative.
This
was
calculated
as
follows:
50%
affected
by
key
pests
and
an
additional
25%
(
50%
of
50%)
affected
by
karst
topography.
23.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
24.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2006
or
the
historic
average
use
rate.
25.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
26.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
27.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
28.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
29.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
30.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
31.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
U.
S.
Strawberry
Nursery
49
32.
Research/
Transition
Plans
 
Research/
Transition
Plans
is
`
yes'
when
the
applicant
has
indicated
that
there
is
research
underway
to
test
alternatives
or
if
applicant
has
a
plan
to
transition
to
alternatives.
33.
Tarps/
Deep
Injection
Used
 
Because
all
pre­
plant
methyl
bromide
use
in
the
US
is
either
with
tarps
or
by
deep
injection,
this
variable
takes
on
the
value
`
tarp'
when
tarps
are
used
and
`
deep'
when
deep
injection
is
used.
34.
Pest­
free
cert.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
certified
as
`
pest­
free'
in
order
to
be
sold
35.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
36.
Change
from
Prior
CUE
Request­
This
variable
takes
a
`+'
if
the
current
request
is
larger
than
the
previous
request,
a
`
0'
if
the
current
request
is
equal
to
the
previous
request,
and
a
`­`
if
the
current
request
is
smaller
that
the
previous
request.
37.
Verified
Historic
Use/
State­
This
item
indicates
whether
the
amounts
requested
by
administrative
area
have
been
compared
to
records
of
historic
use
in
that
area.
38.
Frequency
of
Treatment
 
This
indicates
how
often
methyl
bromide
is
applied
in
the
sector.
Frequency
varies
from
multiple
times
per
year
to
once
in
several
decades.
39.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
40.
Loss
per
Hectare
 
This
measures
the
total
loss
per
hectare
when
a
specific
alternative
is
used
in
place
of
methyl
bromide.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
41.
Loss
per
Kilogram
of
Methyl
Bromide
 
This
measures
the
total
loss
per
kilogram
of
methyl
bromide
when
it
is
replaced
with
an
alternative.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
42.
Loss
as
a
%
of
Gross
revenue
 
This
measures
the
loss
as
a
proportion
of
gross
(
total)
revenue.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
43.
Loss
as
a
%
of
Net
Operating
Revenue
­
This
measures
loss
as
a
proportion
of
total
revenue
minus
operating
costs.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
This
item
is
also
called
net
cash
returns.
44.
Quality/
Time/
Market
Window/
Yield
Loss
(%)
 
When
this
measure
is
available
it
measures
the
sum
of
losses
including
quality
losses,
non­
productive
time,
missed
market
windows
and
other
yield
losses
when
using
the
marginal
strategy.
45.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
