METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
ORCHARD
REPLANT
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
Orchard
Replant
(
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.
Orchard
Replant
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.
Orchard
Replant
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
....................................................................................................................
8
1.
Nominating
Party
_________________________________________________________
8
2.
Descriptive
Title
of
Nomination______________________________________________
8
3.
Crop
and
Summary
of
Crop
System___________________________________________
8
4.
Methyl
Bromide
Nominated
_________________________________________________
9
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
9
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
11
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
11
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
13
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
13
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.....................................................................
14
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request__________________
14
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
11.
Characteristics
of
Cropping
System
and
Climate_______________________________________________________________
14
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________________
16
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
C:
TECHNICAL
VALIDATION.............................................................................................................................
17
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________________________________________________________________
17
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
______________________________________________
19
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________
20
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
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
_________________________________________
20
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
________________________________________________________________________
21
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
________________
22
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Summary
of
Technical
Feasibility
_
22
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.....................................................................
23
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request____
23
U.
S.
Orchard
Replant
iv
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
11.
Characteristics
of
Cropping
System
and
Climate
________________________________________________
23
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________
25
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
C:
TECHNICAL
VALIDATION.........................................................................................................
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________________________________________
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
______________________________________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
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
___________________________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?_________________________________________________________________
30
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Summary
of
Technical
Feasibility
________________________________________________________________
31
CALIFORNIA
WALNUT
COMMISSION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE...........................................................................................................................
32
California
Walnut
Commission
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
32
California
Walnut
Commission
­
11.
Characteristics
of
Cropping
System
and
Climate
____
32
California
Walnut
Commission
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
34
CALIFORNIA
WALNUT
COMMISSION
­
PART
C:
TECHNICAL
VALIDATION...............................
35
California
Walnut
Commission
­
13.
Reason
for
Alternatives
Not
Being
Feasible
________
35
California
Walnut
Commission
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_________________________________________________________________
37
California
Walnut
Commission
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________________________________________
37
California
Walnut
Commission
­
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
___________________________________________________________
37
California
Walnut
Commission
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
38
California
Walnut
Commission
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
39
California
Walnut
Commission
­
Summary
of
Technical
Feasibility
__________________
39
U.
S.
Orchard
Replant
v
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE............................................................................................................
40
Almond
Hullers
&
Processors
Association
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
________________________
40
Almond
Hullers
&
Processors
Association
­
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
40
Almond
Hullers
&
Processors
Association
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____
43
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
C:
TECHNICAL
VALIDATION
.........
44
Almond
Hullers
&
Processors
Association
­
13.
Reason
for
Alternatives
Not
Being
Feasible
44
Almond
Hullers
&
Processors
Association
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:_________________________________________________________
46
Almond
Hullers
&
Processors
Association
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________
46
Almond
Hullers
&
Processors
Association
­
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
__________________________________________________
46
Almond
Hullers
&
Processors
Association
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
_________
48
Almond
Hullers
&
Processors
Association
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
______________________
48
Almond
Hullers
&
Processors
Association
­
Summary
of
Technical
Feasibility__________
48
PART
D:
EMISSION
CONTROL
..................................................................................................
49
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
50
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
51
PART
E:
ECONOMIC
ASSESSMENT............................................................................................
51
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
51
22.
Gross
and
Net
Revenue___________________________________________________
51
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
52
Summary
of
Economic
Feasibility
_____________________________________________
52
PART
F.
FUTURE
PLANS
...........................................................................................................
53
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
53
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
54
25.
Additional
Comments
on
the
Nomination
____________________________________
54
26.
Citations
______________________________________________________________
54
APPENDIX
A.
2007
METHYL
BROMIDE
USAGE
NUMERICAL
INDEX
(
BUNI)............................
57
APPENDIX
B.
2006
METHYL
BROMIDE
RECONSIDERATION
FOR
ORCHARD
REPLANT.
.............
61
U.
S.
Orchard
Replant
vi
LIST
OF
TABLES
PART
A:
SUMMARY
____________________________________________________________
8
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
9
Table
A.
1:
Executive
Summary
_________________________________________________
11
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
11
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________________
13
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________________________________________________
14
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_________________________________________
14
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________________
15
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule___________________________________________________________
15
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_________________________________________________________
16
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
C:
TECHNICAL
VALIDATION_
17
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible___________________________________________________________
17
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________________________________________
19
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
15.1:
Present
Registration
Status
of
Alternatives___________________________________________________________
20
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
16.1:
Effectiveness
of
Alternatives
 
Replant
Disorder
_______________________________________________________
20
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_______________________________________________________________
21
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________________________
23
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
________________________________
23
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________
24
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
________________________________________________
24
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________________________________________
25
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________________________________
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
_____________________________________________
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
15.1:
Present
Registration
Status
of
Alternatives
___________________________________________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
16.1:
Effectiveness
of
Alternatives
 
Replant
Disorder
(
Nematodes)
__________________________________
29
U.
S.
Orchard
Replant
vii
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
______________________________________________________
30
CALIFORNIA
WALNUT
COMMISSION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
32
California
Walnut
Commission
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
32
California
Walnut
Commission
­
Table
11.1:
Characteristics
of
Cropping
System__________
33
California
Walnut
Commission
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
__
33
California
Walnut
Commission
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
____
34
CALIFORNIA
WALNUT
COMMISSION
­
PART
C:
TECHNICAL
VALIDATION_____________________
35
California
Walnut
Commission
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
___
35
California
Walnut
Commission
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
37
California
Walnut
Commission
 
Table
15.1:
Present
Registration
Status
of
Alternatives
____
37
California
Walnut
Commission
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
____
37
California
Walnut
Commission
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_______
38
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE____________________________________________________________
40
Almond
Hullers
&
Processors
Association
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_______________________________________________
40
Almond
Hullers
&
Processors
Association
­
Table
11.1:
Characteristics
of
Cropping
System_
41
Almond
Hullers
&
Processors
Association
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______________________________________________________________
41
Almond
Hullers
&
Processors
Association
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
43
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
C:
TECHNICAL
VALIDATION
___________
44
Almond
Hullers
&
Processors
Association
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
________________________________________________________________
44
Almond
Hullers
&
Processors
Association
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion______________________________________________________________
46
Almond
Hullers
&
Processors
Association
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________________________________________________
46
Almond
Hullers
&
Processors
Association
 
Table
16.1:
Effectiveness
of
Alternatives
 
Replant
Disorder________________________________________________________________
47
Almond
Hullers
&
Processors
Association
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_______________________________________________________________________
47
PART
D:
EMISSION
CONTROL
____________________________________________________
49
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
50
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
51
PART
F.
FUTURE
PLANS
________________________________________________________
53
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
__________________
57
U.
S.
Orchard
Replant
Page
8
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
Orchard
Replant
(
Prepared
in
2005)

3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
The
Orchard
Replant
sector
represents
stone
fruit,
almond,
and
walnut
orchards,
and
table
grape
and
raisin
vineyards,
in
California.
Growers
of
all
of
these
commodities
face
a
common
threat 
a
poorly
understood
disease
complex
called
"
orchard
replant
problem"
or
"
disorder".
The
disorder
can
be
of
varying
severity
depending
on
orchard
location,
crop,
soil
texture,
soil
moisture,
or
other
factors.
Orchards
with
replant
problem
have
several
visible
effects,
the
first
and
most
apparent
is
poor
tree
growth
during
the
early
years
of
establishment
(
rejection
component)
and
in
some
cases
a
slow
and
detrimental
decline
in
root
health
and
plant
growth
caused
primarily
by
pathogenic
nematodes
and
fungi.
Environmental
interactions
and
damage
by
other
pests
(
e.
g.,
insects,
nutrient
deficiency
or
wind
blow­
down)
are
less
well
documented,
but
anything
that
limits
early
root
growth
can
predispose
the
trees
to
greater
damage
from
subsequent
agents.
The
long
life
of
a
productive
orchard
(
20
to
40
years)
necessitates
a
longterm
approach
to
orchard
management.
Typically,
the
first
step
in
the
establishment
of
an
orchard
on
land
previously
planted
to
orchard
crops,
is
ripping
the
soil
and
then
fumigating.
Fumigation
kills
(
or
reduces)
both
pests
and
remnant
roots,
which
harbor
pests,
of
previous
plantings.
This
pre­
plant
fumigation
occurs
only
once
in
the
life
of
the
orchard
and
is
the
most
biologically
and
economically
effective
treatment
for
establishing
healthy,
long­
producing
orchards.
In
the
past
both
methyl
bromide
(
MB)
and
1,3­
dichloropropene
(
1,3­
D)
have
been
the
standards
for
orchard
replant.
However,
the
use
label
for
1,3­
D
was
revised
in
the
mid­
1990s
with
rate
and
use
restrictions.
Consequently,
1,3­
D
is
not
effective
in
many
orchard
replant
situations,
which
makes
MB
a
critical
tool
to
an
orchard's
long­
term
productivity.
Research
is
being
supported
by
the
requesting
consortia
to
develop
new
strategies
to
address
important
pest
problems.
For
these
types
of
perennial
crops,
however,
efficacy
must
be
tested
before
large
scale
commercial
applications
can
be
attempted.
In
the
interim,
growers
are
requesting
critical
use
of
MB
to
allow
replanting
of
new
orchards.

The
typical
practice
of
replanting
orchards
or
vineyards
is
to
remove
the
old
trees
after
the
final
harvest
and
attempting
to
remove
as
much
of
the
root
system
as
possible.
The
soil
is
fumigated
with
MB
in
the
late
fall
and
the
trees
are
replanted
in
late
winter.
With
MB,
growers
have
usually
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.
In
a
minority
of
orchard
replant
sites,
1,3­
D,
sometimes
in
combination
with
chloropicrin,
can
be
an
alternative
to
MB.
However,
it
is
only
effective
in
orchards
with
sandy
soils
where
moisture
levels
at
over
1
meter
depth
are
reduced
(
and
where
township
restrictions
do
not
apply).
When
it
is
used,
1,3­
D
is
applied
after
removal
of
old
trees,
followed
by
soil
U.
S.
Orchard
Replant
Page
9
ripping
and
deep
soil
drying
and
then
land
leveling
where
needed.
Depending
on
soil
texture,
availability
of
preferred
new
cultivars,
and
finances
of
the
enterprise,
the
land
is
left
fallow
for
one
year
to
accomplish
all
these
activities.

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

2007
405,415
1,219
*
Includes
research
amount
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
Nomination
is
for
orchard
replant
areas
where
alternatives
are
not
suitable,
either
because
of
legal
restrictions
or
physical
features,
such
as
unacceptable
soil
type.
For
many
sites
of
orchard
replant
with
stone
fruit,
grapes,
walnuts,
and
almonds
in
California,
MB
is
a
critical
tool
for
establishing
healthy,
long
lived
orchards,
until
results
of
research
trials
enable
development
of
protocols
for
alternatives
that
can
be
applied
on
a
commercial
scale.
Where
conditions
are
acceptable,
growers
in
California
currently
use
alternative
measures
to
manage
orchard
replant
disorder
(
Browne
et
al.,
2002b;
McKenry,
1999).

In
U.
S.
orchard
replant
situations
there
are
certain
factors
that
make
some
alternatives
to
MB
unsuitable.
These
include:
 
The
efficacy
of
alternatives
may
not
be
sufficient
for
commercial
purposes
in
some
areas,
making
these
alternatives
infeasible
for
use
in
orchard
replant.
 
Some
alternatives
may
be
comparable
to
MB,
especially
when
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
where
the
key
pest
pressure
is
moderate
to
high.
 
Regulatory
constraints,
such
as
1,3­
D
limitations
in
California
due
to
the
township
caps,
make
the
best
alternatives
unavailable
in
some
areas.
 
The
best
alternative
may
not
be
suitable
for
use
in
certain
soil
conditions,
such
as
excessive
moisture
1­
1.5
m
deep.

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

According
to
an
in­
depth
report
on
orchard
replant
(
McKenry,
1999),
in
1999,
at
least
85%
of
U.
S.
Orchard
Replant
Page
10
the
California
walnut
acreage
was
infested
with
one
or
more
problem
nematodes
(
Pratylenchus
vulnus,
Criconemella
xenoplax,
or
Meloidogyne
spp.).
No
rootstocks
are
currently
available
that
have
sufficient
resistance
to
control
these
pests.
About
60%
of
vineyards
are
infested
with
problem
nematodes,
although
tolerant
rootstocks
can
help
ameliorate
the
replant
problem
for
some
nematodes.
However,
vineyards
are
also
susceptible
to
Phylloxera
and
Armillaria
root
rots.
At
least
60%
of
cling
peach
areas
are
infested
with
Criconemella
xenoplax
and
another
35%
of
stone
fruit
plantings
are
infested
with
P.
vulnus
or
C.
xenoplax.
Around
35%
of
almond
plantings
are
infested
with
C.
xenoplax
and/
or
P.
vulnus;
15%
of
almond
orchards
are
infected
with
bacterial
canker,
and
5%
are
infected
with
oak
root
fungus.

Replant
disorder
is
mediated
by
environmental
conditions
or
stress,
such
that
management
can
be
effective
in
some
areas,
but
not
in
others.
Effective
fumigation
prior
to
replanting
orchards
can
reduce
pest
populations
by
99.9%
in
the
top
1.5
meters,
by
effectively
killing
remnant
roots
from
previous
orchard
trees.

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

Prior
to
1990,
1,3­
D
was
considered
at
least
as
good
as
MB
for
treatment
of
replant
problem
(
McKenry,
1999).
However,
due
to
environmental
and
health
concerns
(
it
is
a
B2
carcinogen
and
was
found
off
of
treatment
sites),
1,3­
D
was
banned,
and
MB
became
the
predominant
treatment
for
orchard
replant.
With
the
re­
labeling
of
1,3­
D
in
the
mid­
1990s
there
were
new
restrictions
on
its
use
and
application,
including
township
caps
in
California.
The
reduced
rates
were
considered
ineffective
for
some
severe
replant
situations
(
reduced
to
325
kg/
ha
from
427
kg/
ha).
MB,
therefore,
remains
the
standard
for
the
industry
when
establishing
nearly
all
of
California's
orchards,
except
in
those
with
light
soils
and
with
appropriate
moisture
conditions,
where
lower
rates
of
1,3­
D
can
be
effective
(
McKenry,
1999).
[
Each
township
is
allowed
a
maximum
of
approximately
41,000
kg
per
year,
in
a
township
of
approximately
9300
ha;
at
225
kg/
ha,
180
ha
can
be
treated
with
1,3­
D
per
township.]
U.
S.
Orchard
Replant
Page
11
TABLE
A.
1:
EXECUTIVE
SUMMARY
Region
California
Grape
and
Tree
Fruit
League 
Stone
Fruit
California
Grape
and
Tree
Fruit
League 
Raisin
&
Table
Grapes
California
Walnut
Commission
Almond
Hullers
&
Processors
Association
AMOUNT
OF
APPLICANT
REQUEST
2007
Kilograms
716,449
165,561
226,796
206,384
AMOUNT
OF
NOMINATION*

2007
Kilograms
267,531
26,356
30,205
79,664
*
See
Appendix
A
for
a
complete
description
of
how
the
nominated
amount
was
calculated.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

The
best
alternative
for
the
orchard
replant
sector
is
1,3­
D
or
1,3­
D
with
chloropicrin,
and/
or
metam­
sodium,
especially
in
light
soils
or
under
minimum
disease
pressure.
Under
some
soil
and
moisture
conditions
(
high
moisture
at
surface
and
less
than
12%
at
1­
1.5
meters)
1,3­
D
can
act
as
an
effective
management
tool
for
replant
problems.
However,
there
is
a
critical
need
for
MB
in
some
orchards
in
California,
either
because
of
legally
mandated
township
caps
for
1,3­
D,
or
because
surface
moisture
requirements
can
not
be
met
(
e.
g.,
soils
can
not
be
adequately
dried
prior
to
use
of
1,3­
D).
With
almonds
in
recent
years,
between
2%
and
21%
of
replant
sites
were
fumigated
with
MB,
while
walnuts
in
21,316
hectares
(
only
about
1/
3
of
the
area
is
actually
treated
in
strip
applications)
had
MB
applications
in
2001
(
see
Section
17 
Walnuts,
below).
In
the
same
year,
1,3­
D
was
applied
to
113
hectares
and
metam­
sodium
was
applied
to
28
hectares.

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
AVERAGE
TOTAL
REPLANT
AREA
IN
2001
AND
2002
(
HA)
[
AREA
OF
MB
USE/
TOTAL
AREA
REPLANTED
PER
YEAR]
PROPORTION
OF
TOTAL
REPLANT
AREA
TREATED
WITH
METHYL
BROMIDE
PER
YEAR
(%)

California
Grape
and
Tree
Fruit
League 
Stone
Fruit
Not
available
Not
available
California
Grape
and
Tree
Fruit
League 
Raisin
&
Table
Grapes
Not
available
Not
available
California
Walnut
Commission
Not
available
Not
available
Almond
Hullers
&
Processors
Association
496/
5900
(
2001)
820/
3992
(
2002)
278/
12,502
(
2003)
a
8%
(
2001)
21%
(
2002)
2%
(
2003)
a
NATIONAL
TOTAL:
Not
available
U.
S.
Orchard
Replant
Page
12
a
2003
data
based
on
preliminary
reports
to
California
Department
of
Pesticide
Regulation.

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.

Some
areas
of
California
are
amenable
to
these
crops
and
have
soil
types
and
moisture
characteristics
that
allow
the
use
of
alternative
treatments.
1,3­
D
and
chloropicrin
can
be
an
effective
alternative
to
MB
in
areas
with
soils
that
contain
less
than
12%
moisture
at
1.5
meters
and
can
be
sufficiently
moistened
in
the
top
30
cm.
Areas
considered
in
this
nomination
have
either
regulatory
or
other
reasons
(
e.
g.,
soil
type)
that
prevent
alternatives
from
acting
effectively
in
successfully
managing
replant
disorder.
Until
protocols
are
developed
for
commercial
application
of
effective
alternatives,
MB
is
critical
for
successful
orchard
replant.

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?

Generally,
it
will
be
difficult
to
expand
the
use
of
the
best
alternative,
1,3­
D,
to
a
greater
percent
of
orchard
replant
situations
because
of
physical
and
legal
restrictions.
First,
at
current
label
rates,
1,3­
D
can
be
effective
in
light
soils,
but
not
medium
to
heavy
soils
where
moisture
content
below
1­
1.5
meters
and
on
the
surface
reduces
the
number
of
effective
sites.
Secondly,
only
if
township
cap
limitations
were
reduced
would
there
be
a
likelihood
that
1,3­
D
could
supplant
the
critical
need
for
MB
in
many
orchards.
This
is
not
a
realistic
scenario
given
environmental
and
health
concerns
for
1,3­
D
(
as
well
as
metam­
sodium)
in
California.
Furthermore,
prior
to
label
cancellation
in
1990,
1,3­
D
was
used
at
a
higher
rate
(
427
kg/
ha)
than
the
current
maximum
label
rate
(
375
kg/
ha),
established
after
its
reintroduction
for
perennials
in
1996
(
McKenry,
1999).
The
higher
rate
was
considered
significantly
more
effective
than
the
current
rate
(
where
1,3­
D
is
allowed
under
township
cap
restrictions).
Rates
are
unlikely
to
be
increased
due
to
the
probable
carcinogenic
nature
of
1,3­
D
(
B2
carcinogen).
Aside
from
township
caps,
efficacy
of
1,3­
D
is
highly
dependent
on
soil
type,
requiring
light
soils
to
be
most
effective
at
the
current
label
rates.
Because
research
is
making
significant
gains
in
knowledge
of
alternatives
(
e.
g.,
Browne
et
al.,
2004;
Lampinen
et
al.,
2004;
Schneider
et
al.,
2004),
it
may
be
possible
to
improve
the
efficacy
of
some
alternatives
by
improving
application
technologies
in
conjunction
with
crop
rotation,
fallowing,
rootstock,
or
use
of
VIF
(
use
is
regulated
in
California).
But
these
advances
will
require
further
research
before
commercial
use
in
areas
where
MB
is
currently
critical.
U.
S.
Orchard
Replant
Page
13
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
California
Grape
and
Tree
Fruit
League 
Stone
Fruit
California
Grape
and
Tree
Fruit
League 
Raisin
&
Table
Grapes
California
Walnut
Commission
Almond
Hullers
&
Processors
Association
YEAR
OF
EXEMPTION
REQUEST
2007
2007
2007
2007
KILOGRAMS
OF
METHYL
BROMIDE
716,449
165,561
226,796
206,388
USE:
FLAT
FUMIGATION
a
OR
STRIP/
BED
TREATMENT
Usually
flat
fumigation
Flat
fumigation
Flat
fumigation
Usually
flat
fumigation
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
98:
2
98:
2
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
ha)
2,131
433
809
567
APPLICATION
RATE*
b,
c
(
kg/
ha)
[
ACTIVE
INGREDIENT]
336
382
280
364
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
33.6
38.2
28
36.4
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
a
California
Grape
and
Tree
Fruit
League 
Stone
Fruit
Various
methods
are
used
depending
on
the
particular
location,
fumigation
can
be
flat
fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application 
approximately
0.5
kg/
tree).
Strip
fumigation
would
comprise
approximately
65%
of
the
total
area
that
is
actually
fumigated.
b
California
Grape
and
Tree
Fruit
League 
Stone
Fruit
Requested
rate
of
219
kg/
ha
is
dose
rate
(
21.9
g/
m2)
rather
than
rate
applied
as
if
entire
hectare
were
treated
(
335
kg/
ha).
c
Almond
Hullers
&
Processors
Association
Various
methods
are
used
depending
on
the
particular
location,
fumigation
can
be
Flat
Fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application 
approximately
0.5
kg/
tree).
Strip
fumigation
would
comprise
approximately
65%
of
the
total
area
that
is
actually
fumigated.

9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
MB
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.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
MB
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.
 
Only
the
area
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure,
regulatory
impacts,
and
unsuitable
soils.
U.
S.
Orchard
Replant
Page
14
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Grape
and
Tree
Fruit
League 
Stone
Fruit
Replant
problem
is
a
disease
complex
comprised
of
interactions
between
various
pathogens
and
environmental
factors.
Nematodes
(
Primary
pests):
Meloidogyne
(
root
knot);
Criconemella
(
ring);
Xiphinema
(
dagger);
Pratylenchus
(
root
lesion);
and
Tylenchulus
(
citrus)
Pathogens:
Armellaria,
Phytophthora,
and
various
fungi,
depending
on
orchard
location
and
conditions
that
are
thought
to
contribute
to
orchard
replant
disorder.
Insect:
Pollyphylla
decemlineata
(
Tenlined
June
beetle)
Some
alternatives,
such
as
1,3­
D
and
chloropicrin,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
where
there
is
low
disease
pressure
or
where
there
are
no
legal
restriction
in
light,
sandy
loam
soils,
and
where
there
is
acceptable
soil
moisture.
In
other
situations,
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
is
currently
the
only
single
compound
that
can
effectively
target
root
remnants
from
previous
orchard
trees.
Strategies
that
include
multiple
techniques,
such
as
use
of
herbicides
and
nematicides,
have
the
potential
to
reduce
pest
problems
in
orchard
replant.
However,
these
combination
techniques
must
first
be
tested
and
proven
so
as
not
to
compromise
orchard
productivity.
Short
term
fallow
along
with
nematode
tolerant
rootstock
peach
seedlings
have
looked
promising
in
research
trials
(
e.
g.,
Browne,
2003b).

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
The
typical
practice
of
replanting
orchards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest
(
typically
20­
25
years
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
orchards
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
trees
after
harvest
and
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
trees
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.
Due
to
the
late
harvest
of
the
stone
fruit
crops
there
is
not
generally
a
fallow
period
between
the
removal
of
the
old
trees
and
replanting
with
new
trees.
U.
S.
Orchard
Replant
Page
15
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
California
Grape
and
Tree
Fruit
League 
Stone
Fruit
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Stone
fruit
trees
for
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Perennial
(
20­
25
years)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None;
however,
short
term
fallow
along
with
nematode
tolerant
rootstock
peach
seedlings
have
looked
promising
in
research
trials
(
e.
g.,
Browne,
2003b).

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Varied
(
light,
medium,
heavy)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
in
life
of
orchard
(
20­
25
years),
until
replant
with
new
orchard
OTHER
RELEVANT
FACTORS:
None
identified
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
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
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
20
years)
PLANTING
SCHEDULE
Occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Orchard
replant
into
previously
planted
orchard
land
(
the
typical
situation
in
California)
requires
reducing
pathogen
populations
(
mostly
nematodes
and
fungi)
and
nutrient
sources
of
previous
orchard
tree
roots
and
root
remnants.
This
requires
an
effective
material
that
is
volatile
and
can
penetrate
into
the
soil
to
reach
these
plant
materials.
In
sandy,
loam
soils,
where
restrictions
do
not
apply,
1,3­
D
may
be
an
acceptable
alternative
that
can
penetrate
to
the
target
areas.
In
other
situations,
this
compound
and
other
alternatives
are
not
able
to
move
sufficiently
through
the
soil
to
remove
the
problem
pests.
Thus,
there
is
a
critical
need
for
MB
not
only
for
the
stone
fruit
consortium,
but
for
other
consortia
of
this
sector.
The
infrequent
use
of
MB
(
once
in
25­
40
years)
and
the
positive
benefits
of
vigorous
early
tree
growth
make
MB
a
key
component
of
orchard
fruit
and
nut
production.
U.
S.
Orchard
Replant
Page
16
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
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)
2,815
3,522
1,723
1,063
1,169
Not
available
RATIO
OF
FLAT
FUMIGATION
a
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Usually
flat
fumigation
[
if
strip 
65%
of
area
is
treated]
Usually
flat
fumigation
[
if
strip 
65%
of
area
is
treated]
Usually
flat
fumigation
[
if
strip 
65%
of
area
is
treated]
Usually
flat
fumigation
[
if
strip 
65%
of
area
is
treated]
Usually
flat
fumigation
[
if
strip 
65%
of
area
is
treated]
Not
available
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
946,612
1,184,391
579,254
357,558
392,717
Not
available
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
Not
available
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Not
available
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
336
336
336
336
336
Not
available
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
33.6
33.6
33.6
33.6
33.6
Not
available
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
a
Various
methods
are
used
depending
on
the
particular
location,
fumigation
can
be
Flat
Fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application 
approximately
0.5
kg/
tree).
U.
S.
Orchard
Replant
Page
17
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
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
Has
activity
as
a
fungicide
and
may
be
useful
if
fungi
are
significant
causal
agents
of
replant
disorder
(
Trout
et
al.,
2002);
generally
will
not
reduce
nematodes
significantly
and
they
are
major
cause
of
replant
disorder;
may
have
phytotoxicity
problems
at
rates
that
are
effective
against
pests
(
Browne
et
al.,
2002a)
Alone,
not
effective
for
nematode
problems
1,3­
dichloropropene
(
1,3­
D)
Most
orchards
fall
in
areas
with
township
cap
restrictions
on
use
of
1,3­
D.
May
be
effective
where
township
caps
do
not
apply
and
where
soil
moisture
and
texture
are
such
that
1,3­
D
can
penetrate
to
remnant
tree
roots
of
previous
orchard.
Where
legal
restrictions
are
in
place
and/
or
where
soils
are
medium
to
heavy,
1,3­
D
does
not
effectively
control
nematodes
associated
with
replant
disorder.
Comparative
yield
with
1,3­
D
were
valued
at
5585
kg/
ha
versus
8903
kg/
ha
with
MB
(
Duncan
et
al,
2003).
At
US$
0.30
per
kg
peaches,
this
represents
a
significant
economic
impact.
Only
with
light
soils,
if
no
legal
restrictions
apply
Metam­
sodium
May
be
effective
in
killing
root
tissue
near
soil
surface,
but
will
not
kill
roots
below
75
cm
when
metam­
sodium
is
applied
at
label
rates;
not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
However,
in
the
future,
new
delivery
systems
could
increase
effectiveness
of
this
compound
to
make
it
a
more
acceptable
alternative
to
MB
(
where
soil
conditions
are
amenable
to
its
use).
Reducing
time
in
which
material
can
diffuse
throughout
target
area
will
improve
efficacy
(
McKenry,
1999);
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
Comparative
yield
with
metam­
sodium
were
valued
at
6880
kg/
ha
versus
8903
kg/
ha
with
MB
(
Duncan
et
al,
2003).
At
US$
0.30
per
kg
peaches,
this
represents
a
significant
economic
impact.
No
Dazomet
This
alternative
has
been
examined
by
researchers
and
is
inconsistent
in
field
trials.
This
has
been
deemed
not
feasible
due
to
lack
of
performance
in
field
trials
and
inability
to
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
is
not
feasible
in
a
typical
orchard
situation.
This
product
" 
will
not
be
successful
until
more
is
known
about
the
dissolution
rate
of
the
granules"
(
McKenry,
1999).
No
U.
S.
Orchard
Replant
Page
18
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
Nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
No
NON
CHEMICAL
ALTERNATIVES
Fallow
Not
sufficient
alone;
frequently
done
for
1
year
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
McKenry,
1999)
and
may
not
be
sufficient
even
then;
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
Browne
et
al.,
2002b;
Trout
et
al.,
2002).
However,
short
term
fallow
along
with
nematode
tolerant
rootstock
peach
seedlings
have
looked
promising
in
research
trials
(
e.
g.,
Browne,
2003b,
2004).
No
Rootstock
Genetic
factors
are
known
that
confer
some
tolerance
for
orchard
replant
problems 
for
example,
in
one
study
an
orchard
with
Marianna
2624
Plum
rootstock
was
not
as
sensitive
as
an
orchard
with
Nemaguard
peach
rootstock
(
McKenry,
1999).
This
is
in
spite
of
the
resistance
of
Nemaguard
to
reproduction
of
root
knot
nematodes 
however,
feeding
on
Nemaguard
roots
were
aided
by
reproduction
on
remnant
roots
causing
significant
replant
problem.
Rootstocks
for
all
of
the
commodities
in
this
sector
are
subject
to
differential
effects
from
soil
and
other
environmental
factors,
as
well
as
the
array
of
pests
that
comprise
individual
orchards.
Consequently,
rootstock
can
only
be
considered
a
component
of
an
overall
orchard
management
plan,
and
not
a
solution
to
the
replant
problem.
However,
short
term
fallow
along
with
nematode
tolerant
rootstock
peach
seedlings
have
looked
promising
in
research
trials
(
e.
g.,
Browne,
2003b,
2004).
No
Biofumigation,
solarization,
steam,
biological
control,
cover
crops
and
mulching,
Crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices.
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry.
No
U.
S.
Orchard
Replant
Page
19
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
1,3­
D
+
chloropicrin
+
metam­
sodium
1,3­
D
+
metamsodium
Effective
against
nematodes,
fungi,
and
to
kill
remnant
roots
when
1,3­
D
is
used
in
orchards
with
light
soils;
not
feasible
in
medium
or
heavy
soils;
subject
to
township
caps
and
specific
moisture
requirements.
Promising
results
from
research
trials
indicated
that
efficacy
may
be
improved
by
refining
application
protocols
and
use
rates
(
see
e.
g.,
Browne
et
al.,
2003a,
2004).
Possibly,
after
further
research
that
will
optimize
application
methods,
if
no
legal
restrictions
apply
and
where
soil
type
is
amenable
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Herbicides
(
e.
g.,
triclopyr,
glyphosate)
Not
effective
treatment
alone.
Herbicides
are
used
for
killing
remnant
roots
of
previous
orchard
plants;
research
with
walnuts
(
McKenry,
1999)
suggested
that
herbicide
treatment
followed
by
18
months
fallow
can
result
in
root
knot
nematode
control
of
97%
compared
to
untreated
plots.
However,
this
effect
only
lasted
6
months,
not
long
enough
to
achieve
acceptable
establishment
of
new
orchard;
no
herbicides
were
found
that
kill
grape
roots
(
McKenry,
1999).
In
stone
fruit,
while
remnant
roots
were
killed
after
18
months,
endoparasitic
nematodes
were
not
significantly
reduced
(
McKenry
et
al.,
1995).
The
combination
of
herbicide
costs
plus
additional
18
months
waiting
period
prior
to
planting,
becomes
an
economic
burden,
especially
with
the
limited
effectiveness
of
treatment.
U.
S.
Orchard
Replant
Page
20
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
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:

Sodium
azide
No
registration
package
has
been
submitted
No
Unknown
Propargyl
bromide
No
registration
package
has
been
submitted
No
Unknown
Iodomethane
Not
registered
in
U.
S.
Yes
Unknown
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
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
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
REPLANT
DISORDER
KEY
PEST:
REPLANT
DISORDER
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
[
1]
MB
(
400
kg/
ha)
[
2]
1,3­
D
(
350
kg/
ha)
+
metamsodium
(
125
kg/
ha)
[
3]
1
year
fallow
(
non­
fumigated)
[
4]
non­
fumigated
Peach,
fumigation
Fall,
1997;
Replant,
Spring,
1998;
4
reps,
research
plots
Trunk
diameter
(
mm
for
MB
trt;
and
%
of
MB
value);
Aug.
2002:
[
1]
114a
[
2]
92%
ab
[
3]
86%
bc
[
4]
81%
c
Same
Market
Yield
(
kg/
tree
MB
trt;
and
%
of
MB
value);
Aug.
2002:
[
1]
38a
[
2]
100%
a
[
3]
93%
a
[
4]
86%
a
Trout
et
al.,
2002
[
1]
MB
(
400
kg/
ha)
[
2]
1,3­
D
(
260
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
63
kg/
ha)
[
3]
1
year
fallow
(
non­
fumigated)
[
4]
non­
fumigated
Peach,
fumigation
Fall,
1998;
Replant,
Spring,
1999;
4
reps,
research
plots
Trunk
diameter
(
mm
for
MB
trt;
and
%
of
MB
value);
Aug.
2002:
[
1]
94.1a
[
2]
102%
a
[
3]
89%
b
[
4]
82%
b
Same
Market
Yield
(
kg/
tree
MB
trt;
and
%
of
MB
value);
July,
2002:
[
1]
30ab
[
2]
109%
a
[
3]
87%
bc
[
4]
75%
c
Trout
et
al.,
2002
U.
S.
Orchard
Replant
Page
21
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
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
(
385
kg/
ha)
Nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
350
kg/
ha)
+
metam­
sodium
(
125
kg/
ha)
Nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
below
No
alternatives
are
currently
feasible
in
numerous
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
above
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

In
situations
with
light
soil,
and
water
available
to
moisten
the
top
30
cm
of
soil,
1,3­
D
with
chloropicrin
or
metam­
sodium
can
be
effective
treatments
for
orchard
replant
problems.
In
medium
or
heavy
soils,
high
moisture
content
below
1
to
1.5
meters
usually
reduces
the
efficacy
of
1,3­
D
and
precludes
its
use.
MB
is,
therefore,
critical
since
no
other
treatment
has
been
proven
to
exhibit
such
a
positive
effect
on
achieving
a
healthy
orchard
for
20­
25
years
of
production.
Fallowing
and
crop
rotation
studies
(
Browne
et
al.,
2003b,
2004)
suggest
orchard
replant
disorder
can
be
reduced
with
certain
crop
rotations,
but
further
studies
are
needed
to
test
on
a
commercial
scale.
Nematode
control
has
been
short­
lived
(
only
up
to
6
to
9
months)
in
some
studies
(
McKenry,
1999.
In
a
research
trial,
establishing
peach
and
almond
orchards
on
previous
vineyard
soil
appears
to
improve
orchard
establishment
regardless
of
chemical
fumigant
(
Browne
et
al.,
2004;
Lampinen
et
al.,
2004).
Tolerant
rootstocks
with
resistance
to
the
primary
nematode
pests
are
being
developed,
but
orchard
replant
disorder
is
caused
by
varying
factors
that
are
different
in
different
orchard
locations
and
according
to
the
crop
grown
(
and
crop
grown
prior
to
the
orchard
replant).
U.
S.
Orchard
Replant
Page
22
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

Tests
are
being
conducted
to
develop
new
delivery
systems
to
target
pests
with
alternatives
such
as
metam­
sodium
and
1,3­
D
to
depths
where
these
compounds
can
more
efficiently
kill
roots
and
nematodes
that
feed
on
roots.
McKenry
(
1999)
outlines
several
approaches
through
field
research
studies
that
can
help
address
MB
alternatives
for
stone
fruit,
as
well
as
walnuts,
grapes,
and
almonds.
These
include
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow
or
cover
crops,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required
(
e.
g.,
Browne
et
al.,
2004;
Lampinen,
2004).

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
STONE
FRUIT.
SUMMARY
OF
TECHNICAL
FEASIBILITY
For
replant
situations
where
alternatives
are
not
effective,
MB
is
considered
critical
to
the
healthy
establishment
of
orchards.
In
those
stone
fruit
orchard
replant
sites
with
medium
to
heavy
soils
and/
or
where
township
cap
restrictions
apply
losses
of
trees
could
be
greater
than
20%
(
McKenry,
1999).
Orchard
replant
problems
for
all
orchard
replant
sites
are
a
result
of
biological
and
environmental
causes,
and
interactions
of
these
forces.
Studies
of
individual
pest
populations
tell
only
a
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
Nevertheless,
Criconemella
xenoplax
infests
at
least
60%
of
hectares
planted
in
cling
peaches
(
McKenry,
1999).
An
additional
35%
of
fresh
peach,
plum,
and
nectarine
plantings
are
infested
with
P.
vulnus
and
a
somewhat
smaller
area
is
infested
with
C.
xenoplax.
As
such,
it
is
clear
that
the
long
life
of
orchards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available 
at
orchard
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchard
locations
precludes
some
growers
from
taking
advantage
of
1,3­
D,
since
either
township
caps
or
soil
texture/
moisture
issues
reduce
efficacy
or
legal
availability.
Therefore,
for
2007,
for
stone
fruit
replant
where
alternatives
are
not
effective,
there
is
a
critical
need
for
MB
for
establishment
of
commercial
operations.
Currently,
research
is
being
conducted
examining
non­
fumigant
treatments.
Some
non­
chemical
treatments
have
shown
promise
in
small­
scale
research
trials,
such
as
planting
cover
crops
on
previous
vineyards
(
Browne,
2003b,
2004;
Lampinen
et
al.,
2004).
Long
term
studies
will
have
to
be
conducted
before
these
types
of
treatments
are
developed
for
commercial
applications.
U.
S.
Orchard
Replant
Page
23
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
(
e.
g.
Effective
herbicide
available,
but
not
registered
for
this
crop;
mandatory
requirement
to
meet
certification
for
disease
tolerance)

California
Grape
and
Tree
Fruit
League 
Raisin
&
Table
Grapes
Replant
problem
is
a
disease
complex
comprised
of
interactions
between
various
pathogens
and
environmental
factors.
Nematodes
(
Primary
pests):
Meloidogyne
(
root
knot);
Criconemella
(
ring);
Xiphinema
(
dagger);
Pratylenchus
(
root
lesion);
and
Tylenchulus
(
citrus)
Pathogens:
Armellaria,
Phytophthora,
and
various
fungi,
depending
on
orchard
location
and
conditions,
that
are
thought
to
contribute
to
orchard
replant
disorder.
Insect:
At
some
sites
Pollyphylla
decemlineata
(
tenlined
June
beetle)
Some
alternatives,
such
as
1,3­
D
and
chloropicrin,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
in
vineyards,
especially
where
there
is
low
disease
pressure
or
where
there
are
no
legal
restriction
in
light,
sandy
loam
soils,
and
where
there
is
acceptable
soil
moisture.
For
root
knot
and
citrus
nematode
control,
Inline
and
drip
applied
1,3­
D
have
showed
good
efficacy
in
research
trials
(
Schneider
et
al.,
2004).
Rootstock
"
Harmony"
has
showed
good
efficacy
against
rootknot
nematodes
after
six
seasons,
but
poor
efficacy
against
citrus
nematodes
(
Schneider
et
al.,
2004).
In
situations
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
is
the
only
single
compound
that
effectively
targets
root
remnants
from
previous
orchard
trees.
Strategies
that
include
multiple
techniques,
such
as
use
of
herbicides
and
fallow
and
nematicides,
have
the
potential
to
reduce
pest
problems
in
orchard
replant.
However,
these
combination
techniques
must
first
be
tested
and
proven
so
as
not
to
compromise
orchard
productivity.
Some
research
suggests
that
long
term
fallow
benefits
diminished
after
four
seasons
(
Schneider
et
al.,
2004).

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
As
in
stone
fruit
orchards,
the
typical
practice
of
replanting
vineyards
with
MB
is
to
remove
the
old
plantings
after
the
final
harvest
(
typically
20­
25
years
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
plants
after
harvest
and
as
many
of
the
roots
as
time
and
U.
S.
Orchard
Replant
Page
24
resources
permit.
After
the
removal
of
the
old
plants
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Raisins
and
table
grapes
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Perennial
(
average
of
22
year
vineyard
life)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
in
22
years
OTHER
RELEVANT
FACTORS:
The
applicant
did
not
identify
any
other
relevant
factors.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm):
30­
60
CM/
YR
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
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
22
years)
PLANTING
SCHEDULE
Occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Replanting
vineyards
into
non­
virgin
areas
(
the
typical
situation
in
California)
requires
removing
pathogens
(
nematodes
and
fungi)
and
nutrient
sources
of
previous
orchard
tree
roots
and
root
remnants.
This
requires
an
effective
material
that
is
volatile
and
can
penetrate
into
the
soil
to
reach
these
plant
materials.
In
sandy,
loam
soils,
where
restrictions
do
not
apply,
1,3­
D
may
be
an
acceptable
alternative
that
can
penetrate
to
the
target
areas.
However,
in
vineyard
regions
of
California,
township
caps
may
reduce
use
of
1,3­
D
to
a
fraction
of
planted
vineyard
replant
situations.
U.
S.
Orchard
Replant
Page
25
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
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)
316
251
273
67
96
Not
available
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Not
available
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
124,210
108,035
70,732
18,248
20,193
Not
available
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
Not
available
Not
available
Not
available
Not
available
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Not
available
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
393
430
259
271
210
Not
available
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
39.3
43.0
25.9
27.1
21.0
Not
available
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Orchard
Replant
Page
26
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
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
1,3­
D
Where
soil
moisture
is
acceptable
and
township
caps
are
not
instituted,
1,3­
D
may
provide
sufficient
management
of
replant
disorder
in
vineyards
with
light
soils;
usually
more
effective
with
chloropicrin.
Only
with
light
soils,
if
no
legal
restrictions
apply
Metam­
sodium
Not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils);
nematodes
are
the
primary
pest
in
the
replant
disorder
complex;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
No
Chloropicrin
Where
fungi
are
primary
pest
(
requires
addition
of
1,3­
D
is
nematodes
are
present)
No
Dazomet
This
alternative
has
not
been
examined
by
researchers
for
vineyards,
however,
it
is
likely
that
problems
with
this
chemical
are
similar
to
the
stone
fruit
industry 
i.
e.,
it
is
likely
similar
to
metam­
sodium
in
that
it
would
not
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
likely
would
not
be
feasible
in
a
typical
vineyard
situation.
No
Nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
No
Sodium
tetrathiocarbonate
This
compound
does
not
penetrate
the
old
roots
of
the
previous
vineyard.
Old
roots
then
can
be
a
source
of
inoculum
for
various
fungal
and
nematodes
pests.
Therefore,
the
use
of
this
product
alone
will
not
provide
adequate
control
of
the
pest
complex
in
vineyards.
Generally
this
product
is
used
in
combination
with
other
practices
that
will
allow
for
successful
replanting.
No
U.
S.
Orchard
Replant
Page
27
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

NON
CHEMICAL
ALTERNATIVES
Fallow
Not
sufficient
alone;
frequently
done
for
1
year
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
Browne,
2002b)
and
may
not
be
sufficient
even
then,
especially
if
vineyard
viruses,
such
as
grape
fan
leaf
virus
(
GFLV)
have
occurred;
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
McKenry,
1999;
McKenry
et
al.,
1995).
No
Rootstock
Some
rootstocks
are
available,
such
as
Teleki
5C
or
Harmony,
which
can
significantly
reduce
certain
species
of
nematodes 
but
no
multiple
resistance.
Used
in
combination
with
1,3­
D,
significant
reductions
in
rootknot
and
citrus
nematodes
have
resulted
in
research
tests
(
see
Schneider
et
al.,
2002,
2003;
Ferris
and
Walker,
2002).
No
Biofumigation,
solarization,
steam,
biological
control,
cover
crops
and
mulching,
crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices
(
Schneider
et
al.,
2000).
IPM
approaches
are
being
extensively
investigated
(
Schneider
et
al.,
1999).
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Development
of
durable
resistance
to
nematodes
in
grape
rootstock
is
an
ongoing
and
challenging
area
of
research
(
Ferris
and
Walker,
2002).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
1,3­
D
+
chloropicrin
+
metam­
sodium
1,3­
D
+
metamsodium
Effective
against
nematodes,
fungi,
and
to
kill
remnant
roots
when
1,3­
D
is
used
in
orchards
with
light
soils;
not
feasible
in
medium
or
heavy
soils;
subject
to
township
caps
and
specific
moisture
requirements.
Promising
results
from
research
trials
indicated
that
efficacy
may
be
improved
by
refining
application
protocols
and
use
rates
(
see
e.
g.,
Schneider,
2004).
Possibly,
after
further
research
that
will
optimize
application
methods,
if
no
legal
restrictions
apply
and
where
soil
type
is
amenable
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Orchard
Replant
Page
28
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

MBTOC­
listed
alternatives
were
addressed
in
Section
13.
No
other
alternatives
were
considered
feasible.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
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:

Sodium
azide
Not
registered
in
U.
S.,
no
registration
package
has
been
received
No
Unknown
Propargyl
bromide
Not
registered
in
U.
S.,
no
registration
package
has
been
received
No
Unknown
Iodomethane
Not
registered
in
U.
S.
Yes
Unknown
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
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
U.
S.
Orchard
Replant
Page
29
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
REPLANT
DISORDER
(
NEMATODES).
KEY
PEST:
REPLANT
DISORDER
(
NEMATODES)

METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
CITATION
[
1]
not
fumigated
[
2]
MB
(
455
kg/
ha)
[
shanked,
tarp]
[
3]
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
4]
InLine
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
5]
chloropicrin
(
455
kg/
ha)
[
drip]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
5
reps;
grapes
Meloidogyne
spp.
(#/
100
cc
soil)
(
trial
planted
and
sampled
2001)

[
1]
324a
[
2]
0c
[
3]
290a
[
4]
0c
[
5]
8b
Tylenchulus
semipenetrans
(#/
100
cc
soil)
(
trial
planted
and
sampled
2001)
[
1]
121a
[
2]
0c
[
3]
157a
[
4]
0c
[
5]
2bc
Schneider
et
al.,
2002
Meloidogyne
spp.
per
100
cc
soil
(
trial
planted
1998,
sampled
2001)

Thompson
seedless
rootstock
Teleki
5C
rootstock
Harmony
rootstock
[
1]
not
fumigated
[
2]
1­
year
fallow
[
3]
1­
year
fallow
+
cover
crop
[
4]
MB
(
455
kg/
ha)
[
shanked,
tarp]
[
5]
1,3­
D
(
352
kg/
ha)
[
in
60
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
6]
1,3­
D
(
352
kg/
ha)
[
in
100
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
5
reps;
grapes
[
1]
144ab
[
2]
215a
[
3]
145ab
[
4]
1def
[
5]
0.2ef
[
6]
6cde
[
1]
261a
[
2]
49b
[
3]
190a
[
4]
0.3c
[
5]
0.6c
[
6]
0.2c
[
1]
0.8a
[
2]
0.0a
[
3]
0.1a
[
4]
0.0a
[
5]
0.0a
[
6]
0.0a
Schneider
et
al.,
2002
Tylenchulus
semipenetrans
per
100
cc
soil
(
trial
planted
1998,
sampled
2001)

Thompson
seedless
rootstock
Teleki
5C
rootstock
Harmony
rootstock
[
1]
not
fumigated
[
2]
1­
year
fallow
[
3]
1­
year
fallow
+
cover
crop
[
4]
MB
(
455
kg/
ha)
[
shanked,
tarp]
[
5]
1,3­
D
(
352
kg/
ha)
[
in
60
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
6]
1,3­
D
(
352
kg/
ha)
[
in
100
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
5
reps;
grapes
[
1]
638a
[
2]
352a
[
3]
463a
[
4]
0.4c
[
5]
3c
[
6]
6b
[
1]
301a
[
2]
434a
[
3]
342a
[
4]
4b
[
5]
1b
[
6]
3b
[
1]
913a
[
2]
1123a
[
3]
723a
[
4]
2b
[
5]
6b
[
6]
7b
Schneider
et
al.,
2002
U.
S.
Orchard
Replant
Page
30
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
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
(
385
kg/
ha)
Nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

1,3­
D
(
350
kg/
ha)
+
metamsodium
(
125
kg/
ha)
Nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
below
No
alternatives
are
currently
feasible
in
numerous
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
above
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

In
situations
with
light
soil,
and
water
available
to
moisten
the
top
30
cm
of
soil,
1,3­
D
with
chloropicrin
or
metam­
sodium
can
be
effective
treatments
for
replant
problems.
However,
in
medium
or
heavy
soils,
high
moisture
content
below
1
to
1.5
meters
usually
reduces
the
efficacy
of
1,3­
D
and
precludes
its
use.
MB
is,
therefore,
critical
since
no
other
treatment
has
been
proven
to
exhibit
such
a
positive
effect
on
achieving
a
healthy
vineyard
for
20­
25
years
of
production.
Alternatives
that
are
being
investigated
include
fallowing
studies
(
frequently
with
prior
treatment
with
an
herbicide
to
kill
remnant
roots
from
previous
plantings).
Thus
far,
nematode
control
is
short­
lived
(
only
up
to
6
to
9
months)
(
McKenry,
1999).
Rootstock
with
resistance
to
the
primary
nematode
pests
are
being
developed,
but
orchard
replant
disorder
is
caused
by
varying
factors
that
are
different
in
different
orchard
locations
and
according
to
the
crop
grown
(
and
crop
grown
prior
to
the
orchard
replant).
U.
S.
Orchard
Replant
Page
31
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

Tests
continue
to
be
conducted
to
develop
new
delivery
systems
to
target
pests
with
alternatives
such
as
metam­
sodium
and
1,3­
D
to
depths
where
these
compounds
can
more
effectively
kill
remnant
roots
and
nematodes
that
feed
on
roots
(
e.
g.,
Martin,
2003;
McKenry,
2001).
McKenry
(
1999)
outlined
several
approaches
through
field
studies
that
addressed
MB
alternatives
for
walnuts,
grapes,
stone
fruit,
and
almonds.
These
included
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE 
RAISIN
&
TABLE
GRAPES.
SUMMARY
OF
TECHNICAL
FEASIBILITY
Less
than
1%
of
the
total
area
planted
to
raisin
and
table
grapes
is
subject
to
replanting
(
and,
therefore,
MB)
every
year.
In
these
cases
losses
of
vines
are
likely
to
be
greater
than
20%
(
McKenry,
1999)
without
MB.
As
with
all
replant
sites,
orchard
replant
problems
for
vineyards
are
a
result
of
biological
and
environmental
causes,
and
probably
interactions
of
these
forces.
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
In
situations
with
an
identified
pest,
such
as
rootknot
nematodes,
there
are
promising
resistant
(
or
tolerant)
rootstocks
that
may
help
alleviate
the
problem
(
e.
g.,
Schneider
et
al,
2003,
2004);
long
term
fallow
did
not
appear
to
reduce
nematode
populations
in
field
trials.

It
is
clear
that
the
long
life
of
vineyards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available 
at
time
of
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchard
and
vineyard
locations
precludes
the
majority
of
growers
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduce
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
2007,
for
vineyard
replant
where
alternatives
are
not
effective,
there
is
a
critical
need
for
MB
for
establishment
of
commercial
operations.
U.
S.
Orchard
Replant
Page
32
CALIFORNIA
WALNUT
COMMISSION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
WALNUT
COMMISSION.
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
WALNUT
COMMISSION.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Walnut
Commission
(
Central
Valley
and
coastal
valleys)
Replant
problem
caused
by
interactions
of
pests
and
environment,
primarily
Nematodes:
(
in
~
85%
of
orchards)
Pratylenchus
vulnus,
Mesocriconema
xenoplax,
Meloidogyne
spp.
Township
caps
and
unacceptable
soil
moisture
(>
12%
at
over
1
meter
depths
in
medium
and
heavy
soils)
limit
1,3­
D
use
(
the
best
alternative)
to
approximately
only
30%
of
orchard
land.

Some
alternatives,
such
as
1,3­
D
and
chloropicrin,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
where
there
is
low
disease
pressure
or
where
there
are
no
legal
restriction
in
light,
sandy
loam
soils,
and
where
there
is
acceptable
soil
moisture.
In
other
situations,
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
is
the
only
single
compound
that
can
effectively
target
root
remnants
from
previous
orchard
trees.

Strategies
that
include
multiple
techniques,
such
as
use
of
herbicides
and
fallow
and
nematicides,
have
the
potential
to
reduce
pest
problems
in
orchard
replant.
However,
these
combination
techniques
must
first
be
tested
and
proven
so
as
not
to
compromise
orchard
productivity.

CALIFORNIA
WALNUT
COMMISSION.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
The
typical
practice
of
replanting
orchards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest
(
typically
30­
40
years 
and
sometimes
longer 
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

When
using
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
the
old
trees
are
removed
with
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
trees
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.
U.
S.
Orchard
Replant
Page
33
CALIFORNIA
WALNUT
COMMISSION.
TABLE.
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
REGION
B
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
English
walnuts
on
black/
Paradox
rootstocks
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Perennial
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
(
30%),
medium
(
40%),
heavy
(
30%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
in
orchard
life
(
up
to
40
years)

OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified
by
the
applicant.

CALIFORNIA
WALNUT
COMMISSION.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm):
30­
60
CM/
YR
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
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
40
years)
PLANTING
SCHEDULE
Occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California
CALIFORNIA
WALNUT
COMMISSION.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

In
approximately
70%
of
walnut
orchard
situations
(
Central
Valley
and
coastal
valleys
in
California)
surface
soil
moisture
and
restrictions
due
to
township
caps,
make
the
best
alternative,
1,3­
D,
unlikely
to
replace
MB
for
2007.
U.
S.
Orchard
Replant
Page
34
CALIFORNIA
WALNUT
COMMISSION.
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
WALNUT
COMMISSION.
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)
249
348
89
Not
available
Not
available
Not
available
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
fumigation
Not
available
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
111,518
156,162
39,687
24,308
(?)
59,643
(?)
Not
available
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
98:
2
Not
available
Not
available
Not
available
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
shank
injected
shank
injected
Not
available
Not
available
Not
available
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
448
448
448
Not
available
Not
available
Not
available
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
44.8
44.8
44.8
Not
available
Not
available
Not
available
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Orchard
Replant
Page
35
CALIFORNIA
WALNUT
COMMISSION.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
WALNUT
COMMISSION.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
WALNUT
COMMISSION.
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
1,3­
D
With
appropriate
soil
type
and
moisture
conditions,
an
effective
nematicide,
usually
more
effective
for
orchard
replant
problems
with
chloropicrin
for
added
fungicidal
activity;
also
is
relatively
effective
in
killing
remnant
roots
from
previous
orchard
planting;
however,
subject
to
strict
township
caps
and
specific
moisture
requirements.
Typically
will
be
formulated
with
chloropicrin.
With
conducive
soils,
if
no
legal
restrictions
apply
Chloropicrin
May
perform
acceptably
alone
when
fungi
are
primary
cause
of
orchard
replant
problem;
for
nematode
causation,
presence
of
1,3­
D
is
necessary.
No
Metam­
sodium
Not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils);
however,
can
sometimes
kill
remnant
tree
roots
that
harbor
nematodes,
but
legal
label
rates
(
363
kg/
ha)
generally
can
only
kill
roots
above
the
surface
75
cm
(
McKenry,
1999);
below
this
level,
nematodes
populations
survived.
Generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
No
Dazomet
This
alternative
has
been
examined
by
researchers
and
is
inconsistent
in
field
trials.
This
has
been
deemed
not
feasible
due
to
lack
of
performance
in
field
trials
and
inability
to
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
is
not
feasible
in
a
typical
orchard
situation.
No
Nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
No
U.
S.
Orchard
Replant
Page
36
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

NON
CHEMICAL
ALTERNATIVES
Fallow
Not
sufficient
alone;
frequently
done
for
1
year
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
McKenry,
1999);
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
Browne
et
al.,
2002b;
Trout
et
al.,
2002);
might
be
used
following
herbicide
treatment
but
is
additional
expense
for
reduced
efficacy
compared
to
more
effective
fumigants.
No
Resistant
rootstock
No
commercially
acceptable
rootstocks
are
currently
available
that
have
resistance
to
nematodes
(
McKenry,
1999)
No
Biofumigation,
solarization,
steam,
biological
control,
cover
crops
and
mulching,
crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices.
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
Only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
metamsodium
Only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
chloropicrin
+
metam­
sodium
1,3­
D
mixtures
can
be
effective
in
light
soils
in
areas
with
no
legal
restrictions
[
in
walnuts,
probably
only
30%
of
orchard
replant
situations
(
McKenry,
1999)];
or
situations
where
moisture
levels
are
acceptable
(
requires
less
that
12%
at
depths
of
up
to
1.5
meters,
and
sufficient
moisture
at
surface
to
disperse
compounds,
while
reducing
emissions);
restrictions
reduce
orchard
sites
where
1,3­
D
is
feasible
option;
in
heavy
soils
1,3­
D
is
not
a
feasible
alternative
Only
with
light
soils,
if
no
legal
restrictions
apply
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Orchard
Replant
Page
37
CALIFORNIA
WALNUT
COMMISSION.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
WALNUT
COMMISSION
REGION
C.
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Herbicides
(
e.
g.,
triclopyr,
glyphosate)
Not
effective
treatment
alone.
Herbicides
are
used
for
killing
remnant
roots
of
previous
orchard
plants;
research
with
walnuts
(
McKenry,
1999)
suggested
that
herbicide
treatment
followed
by
18
months
fallow
can
result
in
root
knot
nematode
control
of
97%
compared
to
untreated
plots.
However,
this
effect
only
lasted
6
months,
not
long
enough
to
achieve
acceptable
establishment
of
new
orchard;
no
herbicides
were
found
that
kill
grape
roots
(
McKenry,
1999).
In
stone
fruit,
while
remnant
roots
were
killed
after
18
months,
endoparasitic
nematodes
were
not
significantly
reduced
(
McKenry
et
al.,
1995).
The
combination
of
herbicide
costs
plus
additional
18
months
waiting
period
prior
to
planting
becomes
an
economic
burden,
especially
with
the
limited
effectiveness
of
treatment.

CALIFORNIA
WALNUT
COMMISSION.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
WALNUT
COMMISSION.
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:

Sodium
azide
No
registration
package
has
been
received
No
Unknown
Propargyl
bromide
No
registration
package
has
been
received
No
Unknown
Iodomethane
Not
registered
in
U.
S.
Yes
Unknown
CALIFORNIA
WALNUT
COMMISSION.
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
CALIFORNIA
WALNUT
COMMISSION.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1:
NEMATODES.

KEY
PEST:
REPLANT
DISORDER
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
see
Table
16.1
for
Regions
A
(
Stone
Fruit),
B
(
Grapes),
&
D
(
Almonds)
U.
S.
Orchard
Replant
Page
38
CALIFORNIA
WALNUT
COMMISSION.
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
(
385
kg/
ha)
Nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

1,3­
D
(
350
kg/
ha)
+
metamsodium
(
125
kg/
ha)
Nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
below
No
alternatives
are
currently
feasible
in
numerous
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
above
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

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

According
to
the
consortium,
in
2001,
MB
was
used
on
21,316
hectares
(
only
about
1/
3
of
the
area
is
actually
treated
in
strip
applications).
In
the
same
year,
1,3­
D
was
applied
to
113
hectares
and
metam­
sodium
was
applied
to
28
hectares.
The
limited
(
although
increasing)
use
of
the
best
alternative
1,3­
D,
is
primarily
due
to
township
caps
in
the
concentrated
areas
of
walnut
production
in
California,
and
1,3­
D
use
may
be
limited
by
moisture
factors
when
1,3­
D
is
not
an
effective
nematicide
in
heavy
soils
of
an
orchard
and
soils
with
greater
than
12%
moisture.
In
this
situation
MB
is
critical
and
its
use
is
of
considerable
effectiveness
in
light
of
the
longevity
of
walnut
orchards
and
importance
of
early
tree
health
to
long
producing
orchards.
It
requires
8­
10
years
for
trees
to
produce
a
saleable
crop
and
the
failure
to
start
the
orchard
with
healthy
trees
or
in
a
pathogen
infested
site
will
reduce
production
over
its
40
year
life.
Improper
orchard
replant
can
lead
to
additional
replant
within
10
years
with
no
production
in
the
interim.
U.
S.
Orchard
Replant
Page
39
CALIFORNIA
WALNUT
COMMISSION.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

1,3­
D
has
been
very
effective
in
locations
where
soil,
moisture,
and
legal
restrictions
are
not
problematic.
Where
1,3­
D
is
not
an
acceptable
treatment,
MB
is
critical
to
the
establishment
of
the
walnut
orchard.
This
includes
a
number
of
walnut
orchards.

Some
cultural
practices
can
be
instituted
to
reduce
the
effects
of
replant
problems
(
McKenry,
1999).
It
is
generally
true
that
replant
problems
are
worse
in
sandy
or
alkaline
soils.
It
is
also
known
that
walnuts
grow
better
replanting
after
almond
orchards
(
or
grapes)
rather
than
after
walnuts.
Unfortunately,
many
growers
do
not
have
choices
of
replant
since
land
is
limited
and
choices
must
be
made
for
future
returns
of
a
long
term
crop.
McKenry
(
1999)
outlines
several
approaches
through
field
research
studies
that
can
help
to
address
MB
alternatives
for
walnuts,
as
well
as
grapes,
stone
fruit,
and
almonds.
These
include
use
of
herbicides
to
kill
remnant
roots,
use
of
fallow
or
rotation
crops,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.

CALIFORNIA
WALNUT
COMMISSION.
SUMMARY
OF
TECHNICAL
FEASIBILITY
Where
alternatives,
such
as
1,3­
D
and
chloropicrin
,
are
not
effective
(
e.
g.,
sites
with
medium
to
heavy
soils,
and/
or
where
township
cap
restrictions
apply),
MB
will
be
critical
to
the
healthy
establishment
of
walnut
orchards
in
2007.
In
these
cases
losses
of
trees
may
be
greater
than
20%
(
McKenry,
1999).
McKenry
(
1999)
estimated
that
85%
of
land
used
for
California
walnuts
was
infested
with
one
or
more
of
three
important
nematode
pests
(
Pratylenchus
vulnus,
Criconemella
xenoplax,
or
Meloidogyne
spp.).
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
As
with
the
stone
fruit
orchards,
orchard
replant
problems
for
walnut
orchards
are
a
result
of
biological
and
environmental
causes,
and
probably
interactions
of
these
forces.
Unfortunately,
there
are
no
commercially
available
resistant
rootstocks
that
can
provide
consistent
relief
from
orchard
replant
problem
in
walnuts.
It
is
clear
that
the
long
life
of
orchards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available 
at
orchard
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
chemical
alternative
to
MB.
However,
the
reality
of
California
orchard
locations
precludes
the
majority
of
growers
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduces
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
2007,
for
walnut
replant
where
alternatives
are
not
effective,
there
is
a
critical
need
for
MB
for
establishment
of
commercial
operations.
U.
S.
Orchard
Replant
Page
40
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST:

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Almond
Hullers
and
Processors
Association
(
California)
Replant
problem
(
affects
~
25%
of
total
growing
area)
is
a
disease
complex
comprising
an
interaction
of
pests
(
primarily
nematodes)
and
environmental
factors.
Nematodes
(
affects
35­
50%
of
total
growing
area):
Meloidogyne
incognita
(
root
knot),
Pratylenchus
vulnus
(
root
lesion),
Mesocriconema
xenoplax
(
ring),
Xiphinema
americanum
(
dagger);
Bacteria:
Pseudomonas
syringae
(
canker)
(
affects
15%
of
total
growing
area);
Fungi:
Armillaria
mellea
(
oak
root
fungus)
(
affects
5%
of
total
growing
area)
Many
new
almond
orchards
were
planted
between
1979
and
1982.
These
orchards
will
soon
need
to
be
replanted
as
the
life
of
the
orchard
is
reaching
its
maximum
(
25­
30
years).
Because
little
virgin
land
is
available,
replant
problems
will
occur
in
these
locations.
Because
of
township
caps
(
30%
of
area)
and
water
moisture
issues
(
65%
of
area),
the
best
alternative,
1,3­
D,
is
not
available
or
effective
as
a
replacement
in
many
situations.
Therefore,
MB
is
considered
critical
for
this
industry.
Alternatives,
such
as
1,3­
D
and
chloropicrin,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
where
there
is
low
disease
pressure
or
where
there
are
no
legal
restriction
in
light,
sandy
loam
soils,
and
where
there
is
acceptable
soil
moisture.
In
other
situations,
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
currently
the
product
that
has
been
sufficiently
tested
to
effectively
target
root
remnants
from
previous
orchard
trees.
Strategies
that
include
multiple
techniques,
such
as
use
of
herbicides,
crop
rotations,
and
fallow
have
the
potential
to
reduce
pest
problems
in
orchard
replant.
Research
is
making
progress
in
defining
the
most
effective
alternatives
(
e.
g.,
Lampinen
et
al.,
2004;
Browne
et
al.,
2004).
However,
these
combination
techniques
must
first
be
tested
so
as
not
to
compromise
orchard
productivity.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
The
demand
for
almonds
in
the
future
is
increasing,
thus,
after
2005,
it
is
estimated
that
there
will
be
numerous
orchards
replanted
to
almonds
that
were
originally
planted
from
1979­
1982,
in
addition
to
other
orchards
that
will
be
replanted
to
almonds.
Almonds,
like
other
crops
in
this
sector
are
infrequent
users
of
MB,
since
fumigation
occurs
only
once
in
the
long
life
of
the
orchard.
U.
S.
Orchard
Replant
Page
41
The
typical
practice
of
replanting
orchards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest
(
typically
20­
25
years
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
orchards
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
trees
after
harvest
and
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
trees
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
REGION
D
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
almond
trees
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial
(
25­
30
years)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
none
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light,
medium,
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
25
to
30
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified
by
the
applicant.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm):
30­
60
CM/
YR
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
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
25
to
30
years)
PLANTING
SCHEDULE
Occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California
U.
S.
Orchard
Replant
Page
42
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Orchards
replanted
into
previous
orchard
land
(
the
typical
situation
in
California)
must
reduce
pathogen
populations
(
mostly
nematodes
and
fungi)
and
nutrient
sources
of
old
orchard
tree
roots
and
root
remnants.
This
requires
an
effective
material
that
is
volatile
and
can
penetrate
into
the
soil
to
reach
these
plant
materials.
In
sandy,
loam
soils,
where
restrictions
do
not
apply,
1,3­
D
may
be
an
acceptable
alternative
that
can
penetrate
to
the
target
areas.
In
other
situations,
this
compound
and
other
alternatives
are
not
able
to
move
sufficiently
through
the
soil
to
remove
the
problem
pests.
Thus,
there
is
a
critical
need
for
MB
for
almond
replant
for
2007,
as
well
as
for
other
orchard
replant
crops
of
this
sector.
The
infrequent
use
of
MB
(
once
in
25­
40
years,
or
longer)
and
the
positive
benefits
of
vigorous
early
tree
growth
make
MB
a
key
component
of
orchard
fruit
and
nut
production
until
research
studies
result
in
effective
protocols
for
use
of
alternatives
on
commercial
sites.
U.
S.
Orchard
Replant
Page
43
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003a
AREA
TREATED
(
hectares)
1,613
2,046
1,430
496
820
278
RATIO
OF
FLAT
FUMIGATION
b
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
fumigation
(
broadcast)
Flat
fumigation
(
broadcast)
Flat
fumigation
(
broadcast)
Flat
fumigation
(
broadcast)
Flat
fumigation
(
broadcast)
Flat
fumigation
(
broadcast)

AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
547,622
703,401
497,810
174,502
217,032
85,375
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
shank
injected
shank
injected
shank
injected
shank
injected
Shank
injected
Shank
injected
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
340
344
348
352
265
307
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
34.0
34.4
34.8
35.2
26.5
30.7
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
a
Data
from
preliminary
estimates
by
California
Department
of
Pesticide
Regulation.
b
Various
methods
are
used
depending
on
the
particular
situation;
fumigation
can
be
flat
fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application 
approximately
0.5
kg/
tree).
U.
S.
Orchard
Replant
Page
44
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
PART
C:
TECHNICAL
VALIDATION
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
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
1,3­
D
Can
be
effective
in
orchards
with
light
soils;
currently
not
feasible
in
medium
or
heavy
soils;
usually
more
effective
when
formulated
with
chloropicrin;
subject
to
township
caps
and
specific
moisture
requirements.
(
e.
g.,
Browne
et
al.,
2003a).
Promising
results
have
been
reported
with
1,3­
D/
chloropicrin
for
treatment
of
replant
disorder
(
Browne
et
al.,
2003a,
2004)
Possibly,
after
further
research
that
will
optimize
application
methods
Chloropicrin
May
perform
acceptably
alone
when
fungi
are
primary
cause
of
orchard
replant
problem;
for
nematode
causation,
MB
or
1,3­
D
is
preferred.
Promising
results
have
been
reported
with
some
rates
of
chloropicrin
for
treatment
of
replant
disorder
(
Browne
et
al.,
2003a,
2004)
Possibly,
after
further
research
that
will
optimize
application
methods
Metam­
sodium
Not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
No
Dazomet
This
alternative
has
been
examined
by
researchers
and
is
inconsistent
in
field
trials.
This
has
been
deemed
not
feasible
due
to
lack
of
performance
in
field
trials
and
inability
to
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
is
not
feasible
in
a
typical
orchard
situation.
No
Nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
No
NON
CHEMICAL
ALTERNATIVES
Fallow,
or
crop
rotation
Not
sufficient
alone;
sometimes
done
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
McKenry,
1999)
and
may
not
be
sufficient
even
then;
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
Browne
et
al.,
2002b;
Trout
et
al.,
2002).
Some
research
suggests
that
short
term
rotations
of
some
crops
can
reduce
replant
disorder,
but
large
scale
studies
need
to
be
completed
(
Browne
et
al.,
2004).
No
U.
S.
Orchard
Replant
Page
45
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Rootstock
Similar
situation
to
stone
fruit,
rootstocks
can
help
reduce
some
problem
nematodes,
but
are
not
tolerant
to
an
array
of
pests,
and
do
not
address
overall
replant
"
complex"
(
Browne
et
al.,
2003a).
Initial
results
of
research
examining
cover
crops
suggest
reduction
of
replant
disorder
when
wheat
is
incorporated
into
soil
prior
to
planting
nematode
tolerant
rootstocks
(
Browne,
2003b).
However,
this
research
must
be
continued,
and
results
confirmed,
before
commercial
application
can
be
accepted.
No
Biofumigation,
solarization,
steam,
Biological
Control,
cover
crops
and
mulching,
crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not­
in­
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices.
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
and
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Biological
control
may
have
promise,
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
1,3­
D
+
chloropicrin
+
metam­
sodium
1,3­
D
+
metamsodium
Effective
against
nematodes,
fungi,
and
to
kill
remnant
roots
when
1,3­
D
is
used
in
orchards
with
light
soils;
not
feasible
in
medium
or
heavy
soils;
subject
to
township
caps
and
specific
moisture
requirements.
Promising
results
from
research
trials
indicated
that
efficacy
may
be
improved
by
refining
application
protocols
and
use
rates
(
see
e.
g.,
Browne
et
al.,
2003a,
2004).
Possibly,
after
further
research
that
will
optimize
application
methods,
if
no
legal
restrictions
apply
and
where
soil
type
is
amenable
U.
S.
Orchard
Replant
Page
46
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Herbicides
(
e.
g.,
triclopyr,
glyphosate)
Not
acceptable
treatment
alone.
Herbicides
are
used
for
killing
remnant
roots
of
previous
orchard
plants;
research
with
walnuts
(
McKenry,
1999)
suggested
that
herbicide
treatment
followed
by
18
months
fallow
can
result
in
root
knot
nematode
control
of
97%
compared
to
untreated
plots.
However,
this
effect
only
lasted
6
months,
not
long
enough
to
achieve
acceptable
establishment
of
new
orchard;
no
herbicides
were
found
that
kill
grape
roots
(
McKenry,
1999).
In
stone
fruit,
while
remnant
roots
were
killed
after
18
months,
endoparasitic
nematodes
were
not
significantly
reduced
(
McKenry
et
al.,
1995).
The
combination
of
herbicide
costs
plus
additional
18
months
waiting
period
prior
to
planting,
becomes
an
economic
burden,
especially
with
the
limited
effectiveness
of
treatment.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
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:

Sodium
azide
No
registration
package
has
been
received
No
Unknown
Propargyl
bromide
No
registration
package
has
been
received
No
Unknown
Iodomethane
Not
registered
in
U.
S.
Yes
Unknown
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
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
U.
S.
Orchard
Replant
Page
47
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
REPLANT
DISORDER.
KEY
PEST:
REPLANT
DISORDER
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
fungal
pathogens
[
1]
MB
(
409
kg/
ha)
[
2]
chloropicrin
(
425
kg/
ha)
[
3]
1,3­
D
(
409
kg/
ha)
[
4]
non­
fumigated
Almond
(
Marianna
2624
rootstock),
2001;
4
reps,
research
plots
(
19
m
x
22
m),
no
tarp;
Trunk
diameter
(
mm)
(
increase
after
8
months
postfumigation
[
1]
4b
[
2]
10c
[
3]
2a
[
4]
1a
same
Trees
(%)
w/
growth
>
1.5
m
height
(
in
8
months):
[
1]
21%
a
[
2]
96%
b
[
3]
1%
a
[
4]
2%
a
Browne
et
al.,
2002b
fungal
pathogens
[
1]
MB
(
0.34
kg/
tree)
+
chloropicrin
(
0.11
kg/
tree)
[
2]
chloropicrin
(
0.45
kg/
tree)
[
3]
non­
fumigated
Almond
(
Marianna
2624
rootstock),
2002;
4
reps,
research
plots
(
19
m
x
22
m),
no
tarp;
Trunk
diameter
(
mm)
(
increase
after
8
months
postfumigation
[
1]
15b
[
2]
14b
[
3]
4a
same
Trees
(%)
w/
growth
>
1.5
m
height
(
in
8
months):
[
1]
94%
[
2]
83%
[
3]
6%
Browne
et
al.,
2002b
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
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
(
385
kg/
ha)
Nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
Nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

1,3­
D
(
350
kg/
ha)
+
metam­
sodium
(
125
kg/
ha)
Nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
below
*
1,3­
D
is
not
a
feasible
alternative
where
soil
moisture
is
not
optimal
or
where
township
caps
restrict
its
use.

No
alternatives
are
currently
feasible
in
numerous
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
above
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.
U.
S.
Orchard
Replant
Page
48
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

1,3­
D
with
chloropicrin
is
the
primary
alternative
to
MB
in
areas
where
it
is
effective
(
light
soils,
moisture
less
than
12%
at
1.5
meters,
high
moisture
above
30
cm)
and
allowed.
Previously
discussed
alternatives
are
the
primary
ones
continuing
to
be
examined
(
e.
g.,
Lampinen
et
al.,
2004;
Browne
et
al.,
2004).
Alternatives
that
are
being
investigated
include
fallowing
studies
(
frequently
with
prior
treatment
with
an
herbicide
to
kill
remnant
roots
from
previous
plantings).
Thus
far,
nematode
control
is
short­
lived
(
only
up
to
6
to
9
months)
(
McKenry,
1999).
Rootstock
with
resistance
to
the
primary
nematode
pests
are
being
developed,
but
orchard
replant
disorder
is
caused
by
varying
factors
that
are
different
in
different
orchard
locations
and
according
to
the
crop
grown
(
and
crop
grown
prior
to
the
orchard
replant).
Ongoing
research
(
e.
g.,
Lampinen
et
al.,
2004;
Browne
et
al.,
2004)
suggests
that
alternatives,
including
tolerant
rootstocks,
crop
rotations,
1,3­
D,
chloropicrin,
and
VIF,
have
real
potential
as
replacements
for
MB.
However,
most
researchers
warn
that
further
research
is
necessary
before
protocols
for
commercial
treatments
can
be
devised
and
regulatory
constraints
(
e.
g.,
1,3­
D
and
VIF
in
California)
will
prevent
uses
in
important
areas.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

A
recent
increase
in
demand
for
almonds
has
accelerated
the
rate
of
various
orchards
being
replanted
to
almonds.
To
reduce
MB
use,
however,
growers
have
been
switching
from
the
traditional
broadcast
treatments
to
strip
or
single
hole
treatments.
Use
of
herbicides
can
reduce
remnant
roots
of
previous
plantings
and
reduce
the
nutrients
used
by
problem
nematodes,
but
fumigants
are
still
a
necessary
component.
In
addition,
in
orchards
not
subject
to
restrictions,
1,3­
D
can
be
in
some
situations
an
acceptable
alternative.
However,
as
with
the
other
commodities
of
this
sector,
there
are
numerous
uncertainties
concerning
the
management
of
orchard
replant
problem.
Sound
management
practices
provide
the
trees
with
the
optimal
environment
to
allow
a
productive
and
long­
lived
orchard.
Tests
are
being
conducted
to
develop
new
delivery
systems
to
target
pests
with
alternatives
such
as
metam­
sodium
and
1,3­
D
to
depths
where
these
compounds
can
more
efficiently
kill
roots
and
nematodes
that
feed
on
roots.
McKenry
(
1999)
outlines
several
approaches
through
field
research
studies
that
can
help
address
MB
alternatives
for
almonds,
as
well
as
walnuts,
grapes,
and
stone
fruit.
These
include
use
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
crop
rotations,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.
Early
results,
however,
are
promising
(
e.
g.,
Browne
et
al.,
2003b,
2004;
Lampinen
et
al.,
2004).

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
SUMMARY
OF
TECHNICAL
FEASIBILITY
U.
S.
Orchard
Replant
Page
49
Currently,
no
alternatives
are
feasible
in
the
majority
of
almond
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
As
with
the
other
commodities
of
the
orchard
replant
sector,
replant
problems
for
almonds
are
a
result
of
biological
and
environmental
causes,
and
interactions
of
these
forces.
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
can
cause
only
a
portion
of
the
adverse
growth
effects.
Nevertheless,
approximately
35%
of
hectares
planted
in
almonds
have
infestations
of
Criconemella
xenoplax
and/
or
Pratylenchus
vulnus
(
McKenry,
1999).
Nemaguard,
the
most
commonly
used
almond
rootstock,
has
resistance
only
to
Meloidogyne
spp.
As
such,
it
is
clear
that
the
long
life
of
orchards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available 
at
orchard
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchards
precludes
the
majority
of
growers
from
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduce
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
2007,
for
almond
replant
where
alternatives
are
not
effective,
there
is
a
critical
need
for
MB
for
establishment
of
commercial
operations.
Currently,
research
is
being
conducted
examining
non­
fumigant
treatments.
Some
non­
chemical
treatments
have
shown
promise
in
small­
scale
research
trials,
such
as
use
of
crop
rotation
(
Browne
et
al.,
2003b,
2004).
Continued
studies
will
have
to
be
conducted
before
these
types
of
treatments
are
developed
for
commercial
application.

PART
D:
EMISSION
CONTROL
Research
is
being
conducted
among
all
the
orchard
replant
commodities
to
address
the
orchard
replant
disorder
complex.
Fumigation
is
only
one
means
of
achieving
optimal
orchard
establishment.
Other
practices
can
reduce
long­
term
effects
of
pathogens
and
biotic
and
abiotic
causes
of
this
disorder.
Such
practices
as
fallowing
land,
crop
rotation,
strategic
fertilization,
water
management,
development
of
tolerant
rootstocks,
deep
injection
of
chemicals 
all
will
reduce
the
emissions
of
MB
(
or
other
toxic
chemicals
that
might
be
alternatives).
Current
research
also
includes
studies
with
soil
amendments,
such
as
thiosulfate
fertilizers
that
may
act
as
barriers
or
absorbents
of
MB
and
reduce
emissions.
U.
S.
Orchard
Replant
Page
50
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?
VIF
and
high
density
tarps
being
tested
(
almond)
Testing
reduction
from
98:
2
to
75:
25
(
almond)
When
fungal
pathogens
are
main
concern
chloropicrin
percent
is
increased
Fumigation
is
applied
only
once
in
20­
40
years
for
this
sector
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Testing
Deep
injection;
use
of
additional
herbicides
to
kill
remnant
roots
to
increase
efficacy
of
MB
and
other
fumigants;
reduction
of
MB
in
formulation
Deep
injection,
increased
chloropicrin
in
formulation
to
50:
50
being
examined
Fumigation
is
applied
only
once
in
20­
40
years
for
this
sector
OTHER
MEASURES
(
please
describe)
Unidentified
Combination
of
chemicals
and
cultural
practices
such
as
fallow
+
alternatives
or
reduced
MB
Combination
of
chemicals
and
cultural
practices
such
as
fallow
+
alternatives
or
reduced
MB
Fumigation
is
applied
only
once
in
20­
40
years
for
this
sector
Various
techniques
are
being
studied
to
improve
the
efficacy
of
alternatives.
Primary
is
the
development
of
application
techniques
to
improve
delivery
of
the
best
alternatives,
such
as
1,3­
D
and
metam­
sodium
(
e.
g.,
McKenry,
2001).
In
situations
with
no
township
caps,
and
where
soil
moisture
is
less
than
12%
at
1.5
meters,
1,3­
D
may
be
effective 
this
would
occur
generally
in
orchards
with
light,
sandy
soils.
Although
the
cropping
system
of
these
orchards
makes
the
use
of
MB
cost
effective,
current
research
(
e.
g.,
Browne
et
al.,
2004;
Lampinen
et
al.,
2004;
Schneider
et
al.,
2004)
is
advancing
the
understanding
of
alternatives
in
orchard
replant.
This
research
will
ultimately
result
in
the
development
of
protocols
that
will
be
adapted
for
commercial
use.
U.
S.
Orchard
Replant
Page
51
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS:

Research
is
currently
being
conducted
by
all
commodities
of
this
sector
to
find
increasingly
more
effective
ways
of
managing
orchard
replant
disorder
(
e.
g.,
Browne
et
al.,
2002b;
Ferris
and
Walker,
2002;
Martin,
2003;
McKenry,
1999,
2001;
Schneider
et
al.,
1999,
2000;
Trout
et
al.,
2001).
From
1992
to
2002,
the
expenditures
on
research
have
included
$
430,000
(
California
Walnut
Commission),
$
250,000
(
California
Grape
and
Tree
Fruit
League),
and
$
86,000
(
Almond
Hullers
and
Processors
Association).
Research
by
all
of
these
crop
associations
is
continuing.
This
industry
is
committed
to
reduction
in
MB
use.
Currently
MB
is
used
only
once
in
20
to
40
years,
but
ongoing
tests
to
determine
the
best
approach
to
producing
high
quality
fruit
and
nuts
as
well
as
reducing
MB
emissions
can
help
integrate
new
techniques.
These
include
herbicide
strategies
to
kill
remnant
roots
more
efficiently,
fallowing
regimes
that
will
not
result
in
a
significant
delay
in
replant,
and
deep
injection
to
improve
efficacy.

PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
This
table
is
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
These
tables
are
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.
U.
S.
Orchard
Replant
Page
52
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
AND
TABLE
GRAPES
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
WALNUT
COMMISSION
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
These
tables
are
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

SUMMARY
OF
ECONOMIC
FEASIBILITY
An
economic
analysis
was
not
done
for
this
sector
because
most
of
the
losses
cannot
be
quantified.
The
critical
use
nomination
(
CUN)
for
this
sector
does
not
include
areas
where
soil
conditions
are
ideal
and
township
caps
do
not
restrict
the
use
of
1,3
D.
This
CUN
only
applies
to
areas
where
township
caps
or
certain
soil
types
do
not
permit
the
use
or
effective
use
of
1,3­
D.
In
such
areas
there
are
no
technically
or
economically
feasible
alternatives
and
tree
losses
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
1,3
D
in
combinations
with
chloropicrin
or
metam­
sodium
is
economically
feasible
in
ideal
soil
conditions
when
not
restricted
California
township
caps
on
1,3
D.
Where
soil
conditions
permit
the
effective
use
of
1,3
D
an
estimated
5%
tree
loss
is
expected
from
the
use
of
1,3
D
in
various
combinations
with
chloropicrin
and
metam
sodium.
A
5%
tree
loss
is
considered
a
moderate
loss,
making
the
treatment
economically
feasible,
providing
there
are
no
other
losses.

Where
1,3
D
is
not
permitted
there
are
no
effective
nematicides.
Trees
that
survive
are
not
likely
to
be
as
healthy
and
could
suffer
yield
losses.
If
a
nematode
infestation
causes
the
death
of
trees,
then
replacement
trees
would
also
suffer
the
same
infestation
unless
there
use
of
an
effective
nematicide,
or
possibly
several
years
of
fallow.

An
economic
analysis
was
not
done
because
most
of
the
losses
cannot
be
quantified
since
there
are
no
data
to
substantiate
the
magnitude
of
these
losses.
These
losses
include:
 
Delayed
planting
 
Fallow
 
Additional
use
of
herbicides
 
Tree
loss
 
Replant
costs
to
replace
tree
losses
 
Loss
of
trees
replanted
 
Yield
loss
of
fruit
or
nuts
 
Delayed
achievement
of
full
yield
potential
 
Earlier
loss
of
productivity
of
whole
orchard
U.
S.
Orchard
Replant
Page
53
A
number
of
soil
pathogens
and
nematodes,
many
still
poorly
understood,
occur
over
the
lifespan
of
an
orchard.
It
is
important
that
the
grower
be
able
to
reduce
the
amount
of
inoculum
in
the
soil
to
ensure
that
the
young
trees
have
the
opportunity
to
get
off
to
a
vigorous
start
to
ensure
survival.
1,3
D,
chloropicrin,
and
metam­
sodium
have
shown
promise
on
some
soil
types,
but
long­
term
research
on
tree
survival
and
on
yield
impacts
is
incomplete.
If
the
alternatives
do
not
work
as
effectively
as
MB,
then
it
is
possible
that
other
losses
could
occur,
such
as
additional
replanting,
higher
yield
losses,
and
shorter
lifespan
of
the
whole
orchard
reducing
the
ability
to
amortize
the
initial
investment
costs.

PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

The
development
of
technologies
to
improve
efficacy
of
alternatives,
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
use
of
fallow,
crop
rotation,
tolerant
rootstocks,
and
improved
experience
with
chemical/
non­
chemical
combinations.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.
Considering
that
this
sector
uses
MB
only
once
in
the
life
of
the
orchard,
use
of
alternatives
to
replace
MB
will
have
to
be
well
considered
in
light
of
the
long­
term
impact
on
fruit
and
nut
production.
As
previously
described,
McKenry
(
1999)
has
outlined
several
approaches
through
field
research
studies
that
can
help
address
MB
alternatives
for
almonds,
as
well
as
walnuts,
grapes,
and
stone
fruit.
These
include
use
of
herbicides
to
kill
remnant
roots,
use
of
fallow
and
crop
rotations,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.
The
consortia
requesting
MB
are
currently
developing
timelines
for
transition
from
MB
to
alternatives.
These
timelines
should
be
presented
in
the
very
near
future.

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
estimates
that
orchard
replant
research
will
require
1658
kg
per
year
of
MB
for
2005
and
2006.
This
amount
of
MB
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
U.
S.
Orchard
Replant
Page
54
24.
ARE
THERE
PLANS
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

As
stated
in
Section
23,
minimizing
use
of
MB
can
be
achieved
through
the
development
of
technologies
to
improve
efficacy
of
alternatives,
such
as
deep
injection
methods
or
soil
moisture
management,
and
still
have
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements,
even
though
use
of
MB
is
only
used
once
in
the
long
life
of
these
orchards.
Research
that
is
currently
being
conducted
by
all
of
the
crop
groups
of
this
sector
should
help
identify
strategies
to
most
effectively
manage
replant
disorder.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

The
U.
S.
Nomination
for
MB
is
for
orchard
replant
areas
where
alternatives
are
not
suitable,
either
because
of
legal
restrictions
or
physical
features,
such
as
unacceptable
soil
type.
The
critical
use
exemption
nomination
for
orchard
replant
has
been
reviewed
by
the
U.
S.
government
and
meets
the
guidelines
of
The
Montreal
Protocol
on
Substances
That
Deplete
the
Ozone
Layer.
This
use
is
considered
critical
in
the
designated
areas
because
there
are
no
effective
alternatives
or
substitutes
available.
MB
is
critical
in
the
numerous
orchards
where
1,3­
D
will
not
be
an
effective
treatment
to
orchard
replant
disorder,
such
as
where
orchards
have
medium
to
heavy
soils,
and/
or
township
cap
restrictions
for
1,3­
D.
Under
these
circumstances
MB
is
critical
for
use
in
2007,
and
its
absence
will
result
in
a
significant
burden
for
the
fruit
and
nut
industries
of
California.

26.
CITATIONS
Browne,
G.,
Connell,
J.,
McLaughlin
S.,
Lee,
R.,
Schneider,
S.,
and
Trout,
T.
2004.
Potential
of
chemical
and
non­
chemical
approaches
for
managing
Prunus
replant
disease.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2004).
http://
mbao.
org/

Browne,
G.,
Connell,
J.,
Becherer,
H.,
McLaughlin,
S.,
Schneider,
S.,
Lee,
R.,
and
Hosoda,
E.
2003a.
Evaluation
of
rootstocks
and
fumigants
for
control
of
almond
replant
disease.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2003).
http://
mbao.
org/

Browne,
G.,
Trout,
T.,
Becherer,
H.,
McLaughlin,
S.,
Lee,
R.,
Gartung,
J.,
Gillis,
M.,
Schneider,
S.,
and
Bulluck,
R.
2003b.
Pre­
plant
cropping
and
fallowing
effects
on
severity
of
Prunus
replant
disease.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2003).
http://
mbao.
org/
U.
S.
Orchard
Replant
Page
55
Browne,
G.
T.,
Connell,
J.
H.,
Bulluck,
L.
R.,
Trout,
T.
J.,
and
Schneider,
S.
M.
2002a.
Management
and
etiology
of
replant
disorder
on
almond
and
peach.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/

Browne,
G.,
Trout,
T.
and
Bulluck,
R.
2002b.
Cultural
control
and
etiology
of
replant
disease
of
Prunus
spp.
University
of
California,
Sustainable
Agriculture
Research
and
Education
Program.
http://
www.
sarep.
ucdavis.
edu/
grants/
reports/
mebr/
browne/
browne.
html
Duncan,
R.
A.,
McKenry,
M.,
and
Scow,
K.
2003.
Evaluation
of
pre­
and
post­
plant
treatments
for
replanted
peach
orchards.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2003).
http://
mbao.
org/

Ferris,
H.
and
Walker,
M.
A.
2002.
Development
of
grape
rootstocks
with
broad
and
durable
nematode
resistance.
University
of
California
Sustainable
Agriculture
Research
and
Education
Program.
Final
Report
(
updated
May,
2003).
http://
www.
sarep.
ucdavis.
edu/
Grants/
Reports/
MeBr/
Ferris/
ferris.
html
Gan,
J.,
Becker,
J.
O.,
Ernst,
F.
F.,
Hutchinson,
C.,
Knuteson,
J.
A.,
and
Yates,
S.
R.
2000.
Surface
application
of
ammonium
thiosulfate
to
reduce
1,3­
dichloropropene
volatilization
from
soil.
Pest
Management
Science
56:
264­
270.

Lampinen,
B.,
Browne,
Schneider,
S.,
Shrestha,
A.,
Holtz,
B.,
and
Simon,
L.
2004.
Alternative
pre­
plant
soil
fumigation
treatments
for
deciduous
tree
crops.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2004).
http://
mbao.
org/

Martin,
F.
N.
2003.
Development
of
alternative
strategies
for
management
of
soilborne
pathogens
currently
controlled
with
methyl
bromide.
Annual
Review
of
Phytopathology
41:
325­
350.

McKenry,
M.
2001.
Performance
of
metam
sodium
drenched
to
six
different
replant
sites.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2001).
http://
mbao.
org/

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

McKenry,
M.,
Buzo,
T.,
Kaku,
and
S.
1995.
First­
year
evaluation
of
tree
and
vine
growth
and
nematode
development
following
17
pre­
plant
treatments.
In:
University
of
California
Plant
Protection
Quarterly.
Vol.
5,
No.
4.
http://
www.
uckac.
edu/
ppq/
PDF/
95oct.
pdf
Schneider,
S.,
Trout.
T.,
Browne,
G.,
Ajwa,
H.,
and
Sims,
J.
2004.
Vineyard
replant 
performance
of
methyl
bromide
alternatives
over
time.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2004).
http://
mbao.
org/
U.
S.
Orchard
Replant
Page
56
Schneider,
S.,
Trout.
T.,
Browne,
G.,
Ajwa,
H.,
and
Sims,
J.
2003.
Vineyard
replant
field
trials.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2003).
http://
mbao.
org/

Schneider,
S.,
Trout.
T.,
Browne,
G.,
Ajwa,
H.,
and
Sims,
J.
2002.
Vineyard
replant
disorder 
results
after
1,2,
and
4
growing
seasons.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/

Schneider,
S.,
Ajwa,
H.,
Trout.
T.,
and
Sims,
J.
2000.
Alternatives
for
vineyard
replant
and
grapevine
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2000).
http://
mbao.
org/

Schneider,
Ajwa,
H.
Trout,
T.
and
Sims,
J.
1999.
Grape
replant
disorder 
an
integrated
management
approach.
USDA,
Agricultural
Research
Service,
Methyl
Bromide
Alternatives.
http://
www.
ars.
usda.
gov/
is/
np/
mba/
oct99/
grape.
htm
Trout.
T.,
Ajwa,
H.,
Schneider,
S.,
Gartung,
J.
2002.
Fumigation
and
fallowing
effects
on
replant
problems
in
California
peach.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/
U.
S.
Orchard
Replant
Page
57
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2003
Area
Requested
%

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

267,531
796
336
26,356
77
340
30,205
108
280
79,664
238
334
403,757
1,219
331
69%
69%
1%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
336
336
0
0
0
0
60
35
8
2
0
0
50
35
50%
35%

340
340
0
0
0
0
35
35
8
2
0
0
50
35
50%
35%

280
280
0
0
0
0
85
85
8
2
0
0
50
35
50%
35%

334
334
0
0
0
0
50
35
8
2
0
0
50
35
50%
35%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MB
Use
/

State
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MB
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Y+
N
Yes
Yes
Deep
No
0
Yes
No
Yes
Yes
Deep
No
0
Yes
No
Yes
Yes
Deep
No
0
Yes
Y+
N
Yes
Yes
Deep
No
+
3
Yes
Alternatives
1,3­
D
may
not
be
suitable
due
to
soil
type,
pests
or
township
caps
Notes
1
2
3
Conversion
Units:
1
Pound
=
Kilograms
Hectare
Most
Likely
Impact
Value:
High
24%
Low
76%
Research
Amount
(
kgs)

1658
not
available
not
available
Average
Hectares
in
the
US:

%
of
Average
Hectares
Requested:

Unsuitable
Terrain
(%)
Unsuitable
Soil
(%)
Regional
Hectares**

366,101
1x/
20years
1x/
20years
1x/
40years
Combined
Impacts
(%)

Not
included
as
there
is
no
technically
feasible
alternative.

Quality/
Time/
Market
Window/
Yield
Loss
(%)
Marginal
Strategy
Economic
Analysis
CA
Walnut
Commission
­
Orchard
TOTAL
OR
AVERAGE
2007
Nomination
Options
Frequency
of
Treatment
in
years
CA
Grape
&
Tree
Fruit
League
­
Grapes
(%)
Key
Pest
Distribution
Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)

CA
Walnut
Commission
­
Orchard
Adjustments
to
Requested
Amounts
CA
Grape
&
Tree
Fruit
League
­
Grapes
CA
Walnut
Commission
­
Orchard
REGION
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
CA
Grape
&
Tree
Fruit
League
­
Grapes
CA
Walnut
Commission
­
Orchard
Almond
Hullers
&
Processors
Association
Almond
Hullers
&
Processors
Association
REGION
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
0.453592
1
Acre
=

Other
Considerations
Dichotomous
Variables
(
Y/
N)

CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
Other
Issues
0.404686
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruit
reported
historical
use
rates
that
were
grossly
underestimated
for
normal
fumigation
use.
A
use
rate
of
300
pounds
ai/
acre
was
multiplied
by
the
reported
acreage
to
reflect
a
more
accurate
estimate
of
methyl
bromide
used.

This
applicant
only
replanted
every
20
years,
so
change
from
2002
is
not
necessarily
relevant
since
replant
in
2002
reflects
status
of
market
in
~
1982,
which
was
less
than
planting
in
1970s
that
are
now
being
replanted.

Almond
Hullers
&
Processors
Association
Nomination
Amount
Regulatory
Issues
(%)

Almond
Hullers
&
Processors
Association
(%)
100
ft
Buffer
Zones
REGION
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
CA
Grape
&
Tree
Fruit
League
­
Grapes
1,315,190
%
Reduction
from
Initial
Request
1,315,190
*
Due
to
the
nature
of
these
applications,
the
historical
reported
data
varies
greatly
from
year
to
year.
Therefore
an
average
of
the
usage
from
1997
through
2001
were
used.

CA
Grape
&
Tree
Fruit
League
­
Stone
Fruit
requested
8100
acres
but
only
65%
of
those
acres
are
fumigated
due
to
strip
bed
treatment,
therefore
the
acreage
was
adjusted
downward.

1x/
20years
0%
0%
20%
20%
72%

60%

20%

1,046,003
1,046,003
1,046,003
523,002
­

­
148,544
­
39,126
27,388
206,384
­
­
­
­
103,192
72,235
226,796
­
346,543
242,580
165,561
­
97,281
­
­
34,140
23,898
716,449
­
23,362
­
(­)
QPS
HIGH
LOW
MOST
LIKELY
IMPACT
VALUE
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
338
0%

1,315,190
3,940
334
205
809
280
78,252
1,267,691
3,748
381
0%

206,384
567
364
428,072
1,281
334
0%

226,796
2,061
336
0%

165,561
433
382
68,280
201
340
0%

716,449
2,131
336
693,087
2007
Amount
of
Request
1998~
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:
ORCHARD
REPLANT
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Date:
1/
26/
2005
Methyl
Bromide
Critical
Use
Exemption
Process
U.
S.
Orchard
Replant
Page
58
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.
2007
Amount
of
Request
 
The
2007
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.
2007
Nomination
Options
 
2007
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,
2007
Request
 
Subtractions
from
Requested
Amounts,
2007
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
2007
request
from
an
applicant's
2002
CUE
application
compared
with
the
2007
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
U.
S.
Orchard
Replant
Page
59
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2007
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
2007
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
2007
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.
U.
S.
Orchard
Replant
Page
60
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.
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.
U.
S.
Orchard
Replant
Page
61
APPENDIX
B.
2006
Methyl
Bromide
Reconsideration
for
Orchard
Replant.

Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
827.994
metric
tons
of
methyl
bromide
for
use
in
orchard
replant
for
2006.
The
request
was
distributed
as
follows:
826.336
metric
tons
for
orchard
use
and
1.658
metric
tons
for
research
purposes.

MBTOC
recommended
a
reduced
amount
of
527.6
metric
tons
but
appeared
to
agree
that
for
certain
conditions
there
are
no
feasible
alternatives.
Discussion
with
MBTOC
members
at
the
16th
MOP
(
Prague,
November
2004)
indicated
that
the
basis
for
the
recommended
reduction
was
that
MBTOC
believes
that
alternatives
are
available
for
non­
heavy
(
non­
clay)
soils.
In
addition
during
that
discussion
MBTOC
members
admitted
that
the
amount
of
methyl
bromide
used
in
a
given
year
could
vary
widely
based
on
the
health
of
the
orchards
and
the
economics
of
producing
the
crop.

USG
technical
experts
remain
skeptical
that
technically
and
economically
feasible
alternatives
are
available
but
observe
that
less
methyl
bromide
is
used
in
this
sector.
The
U.
S.
does
not
agree
with
the
technical
basis
of
the
MBTOC's
rationale
for
the
reduction,
but
will
not
contest
it
at
this
time.
The
U.
S.
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
there
are
no
technically
and
economically
feasible
alternatives
in
the
specific
circumstances
of
the
nomination.

U.
S.
2006
nomination
The
U.
S.,
therefore,
accepts
the
MBTOC
recommendation
of
527.6
metric
tons.
