SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
Your
reference:

Our
reference:
OzL./
MBTOC­
CUN/
USA/
MS/
gao
Date:
18
March
2005
Dear
Sir,

Re:
Review
of
Critical­
Use
Nominations
for
Methyl
Bromide
­
USA
Please
refer
to
the
on­
going
review
process
of
nominations
for
critical­
use
exemptions
for
methyl
bromide.

I
am
forwarding
for
your
attention
the
second
set
of
questions
from
Methyl
Bromide
Technical
Options
Committee
on
nominations
related
to
soil
applications.

I
would
appreciate
it
if
your
response
and
any
questions
you
may
have
are
directly
sent
to
the
Co­
chairs
of
the
Committee
at
the
addresses
provided
below
with
a
copy
to
the
Secretariat.

Dr.
H.
J.
Banks
Dr.
Nahum
M.
Mendoza
10
Beltana
Road
and
Department
of
Agricultural
Parasites
Pialligo,
ACT
2609
Autonomic
University
of
Chapingo
Australia
P.
O.
Box
56230
Chapingo,
Mexico
Tel:
(+
61­
2)
6248­
9228
Tel:
(+
52­
595)
954­
1646
/
1602
Fax:
(+
61­
2)
6248­
9228
Fax;
(+
52­
595)
954­
1646
/
1602
/
40692
E­
Mail:
apples3@
bigpond.
com
E­
Mail:
nahumm@
correo.
chapingo.
mx
Yours
sincerely,

Marco
González
Executive
Secretary
Ozone
Secretariat
Dr.
John
E.
Thompson,
Ph.
D.
International
Affairs
Officer
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington
DC
20520,
U.
S.
A.

Fax:
(+
1­
202)
647­
5947
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
­
2
­

Copy
to:
Dr.
H.
J.
Banks
Fax:
(+
61­
2)
6248­
9228
Dr.
Nahum
M.
Mendoza
Fax:
(+
52)
5954­
0692
Ms.
Michelle
Marcotte
Tel:
(+
1­
301)
262­
9866
Dr.
Ian
Porter
Fax:
(+
61­
3)
9800
3521
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
UNITED
STATES:

US
CUCURBITS:

1.
In
this
nomination
there
are
differences
(
in
some
cases
important
ones)
between
the
crop
areas
stated
in
the
CUNs
and
those
used
as
a
basis
for
the
requested
amounts­
and
the
official
USDA
statistics
for
these
crops.
For
example
Michigan
does
not
appear
to
be
an
eggplant
producer
according
to
USDA
´
s
statistics;
or
the
"
other
south­
eastern
states",
with
the
only
exception
of
North
Carolina.
Could
the
Party
please
confirm
which
figures
in
the
nomination
are
correct
and
the
official
source
of
this
information.

2.
Could
the
Party
please
confirm
what
data
it
has
used
to
validate
the
areas
cropped
with
cucurbits
that
are
affected
by
Karst
geology
areas.

US
PEPPERS
1.
Please
provide
official
statistics
of
pepper
production
in
the
States
of
Alabama,
Arkansas,
Kentucky,
Louisiana,
South
Carolina,
Tennessee,
and
Virginia
and
MB
use
in
those
States.

2.
Total
area
to
be
treated
with
the
MB
in
Florida
(
Tables
8.1&
12.1)
is
8,417
ha,
while
total
area
in
the
State
is
7,893
ha
(
table
7.1).
Please
explain?

3.
Please
provide
accurate
information,
on
a
county
basis,
about
yellow
and
purple
nutsedge
high
and
moderate
infestations
and
its
coincidence
within
pepper
crop
areas
for
the
Southeast
States,
Georgia
and
Florida.

4.
Please
provide
accurate
information,
on
a
county
basis,
about
occurrence
of
the
karst
geology
phenomena
and
its
coincidence
with
pepper
crop
areas
for
the
States
of
Georgia
and
Florida.

5.
California:
area
treated
in
2002
was
121
ha
(
table
12.1),
while
MB
is
requested
for
759
ha.
Please
explain?

6.
For
the
control
of
Phytophthora
in
Michigan,
1,3
D
+
chloropicrin
is
a
key
alternative
with
efficacy
comparable
to
MB.
According
to
the
CUN,
the
main
problem
for
its
adoption
is
a
potential
delay
in
planting
as
long
as
28
days
low
soil
temperatures.
Fumigation
operations
need
to
be
completed
by
the
first
week
of
May
to
capture
an
early
market
window.
In
Michigan,
Soil
temperatures
in
April
vary
between
10­
15
°
C.
1,3
D+
Pic
can
be
applied
when
soil
temperature
is
higher
than
5
°
C
as
it
is
the
case
in
Michigan
in
April.
Therefore,
can
we
consider
soil
temperature
as
a
limiting
factor
for
the
soil
fumigation
with
1,3D+
Pic
?.

7.
In
Michigan,
it
was
stated
that
the
range
of
yield
loss
varies
between
0%
and
6%
yield
in
plots
fumigated
with
1,3
D+
Pic
compared
to
MB
(
2003).
In
a
trial
undertaken
in
2004,
yields
from
pepper
plots
treated
with
various
alternatives
(
metham
potassium,
alone
or
in
combination
with
chloropicrin,
1,3­
D
+
chloropicrin
)
are
comparable
to
yields
from
plots
treated
with
MB
+
chloropicrin
and
yields
from
control
plots.
These
results
indicate
a
very
low
pest
pressure
in
all
treated
and
control
plots.
Therefore,
if
the
experiments
have
been
conducted
in
plots
with
a
very
low
pathogens
pressure,
has
the
Phytophthora
distribution
in
Michigan
been
established?
If
yes,
what
is
the
%
of
the
areas
with
poor,
moderate
and
high
pathogen
pressure?
Same
question
for
the
other
pests
in
the
US
pepper
production
states.

8.
Important
reductions
may
be
obtained
by
calculating
the
area
with
Karst
geology
where
MB
can
be
replaced
by
Metham
Sodium
and
Pic.
What
percentage
of
US
pepper
production
occurs
in
Karst
geology
?

9.
Why
strip
fumigation
is
not
adopted
in
all
the
US
production
areas?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
10.
Since
2000,
in
Michigan,
about
5%
of
the
acreage
has
been
treated
with
the
50:
50
formulation
of
methyl
bromide
and
chloropicrin.
What
are
the
constraints
to
increase
the
use
of
this
formulation?
Is
it
possible
to
introduce
or
to
increase
the
use
of
the
formulation
in
the
other
states
11.
In
Southern
US
and
other
states,
Pepper
is
generally
double­
cropped
with
a
cucurbit
crop
(
muskmelon,
cucumber,
or
squash).
MB
is
applied
every
year.
The
requested
quantity
can
decrease
if
MB
is
applied
every
two
years,
as
for
Michigan.
Are
there
any
constraints
to
adopt
this
frequency?
The
party
presented
also
a
CUN
for
cucurbits.

12.
The
MB
formulation
adopted
is
67:
33.
Could
the
formulation
50:
50
be
adopted?

13.
One
application
of
methyl
bromide
can
last
more
than
a
year
in
California
and
therefore,
the
frequency
of
application
is
once
every
two
years.
Why
MB
in
not
applied
every
two
years
in
other
states?

14.
Locascio
et
al.
(
1997)
conducted
studies
on
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
Is
there
any
similar
reference
for
peppers?
The
yield
decrease
is
probably
caused
by
Fusarium
and
not
by
nutsedge.

15.
In
California,
has
the
area
fumigated
in
2003
increased
or
decreased?

16.
When
the
uture
plans
to
minimize
MB
use
are
expected
to
be
adopted
(
VIF,
drip
irrigation,
trials
with
new
alternatives
on
pepper,
MB
formulation.)

17.
The
Party
is
requested
to
explain
why
no
large­
plot
studies
have
yet
been
performed
to
show
commercial
feasibility
of
available
alternatives
in
US
peppers
18.
Will
the
farm
demonstration
plots
will
be
implemented
in
2005?
If
yes,
please
give
more
details:
number,
distribution,
alternatives
etc..

19.
The
alternative
implementation
is
scheduled
for
2010.
What
will
be
the
strategies
to
reduce
the
use
and
emission
of
MB
during
the
coming
years?
(
crop
rotation,
raised
crop
beds,
black
plastic,
and
foliar
fungicides.
Use
of
virtually
impermeable
film
(
VIF)
etc..

20.
What
is
the
importance
use
of
HDPE
(
high
density
polyethylene)
to
minimize
use
and
emissions
of
MB.

21.
What
are
the
cultural
practices
used
by
the
farmers
to
minimize
use
and
emissions
of
MB.

US
EGGPLANT
1.
Experimental
results
has
shown
that
for
the
control
of
Phytophthora
on
eggplant
in
Michigan,
1,3
D
+
chloropicrin
is
a
key
alternative
with
efficacy
comparable
to
MB.
According
to
the
CUN,
the
main
problem
for
its
adoption
is
a
potential
delay
in
planting
as
long
as
28
days
low
soil
temperatures.
Fumigation
operations
need
to
be
completed
by
the
first
week
of
May
to
capture
an
early
market
window.
In
Michigan,
Soil
temperatures
in
April
vary
between
10­
15
°
C.
1,3
D+
Pic
can
be
applied
when
soil
temperature
is
higher
than
5
°
C
as
it
is
the
case
in
Michigan
in
April.
Therefore,
can
we
consider
soil
temperature
as
a
limiting
factor
for
the
soil
fumigation
with
1,3D+
Pic
?.

2.
Important
reductions
may
be
obtained
by
calculating
the
area
with
Karst
geology
where
MB
can
be
replaced
by
Metham
Sodium
and
Pic.
What
percentage
of
US
eggplant
production
occurs
in
Karst
geology
?

3.
In
Michigan,
the
formulation
50:
50
has
been
introduced.
What
are
the
constraints
to
increase
the
use
of
this
formulation
in
Michigan
and
also
in
Florida
and
Georgia?

4.
In
some
states,
e.
g.
Georgia,
eggplant
is
generally
double­
cropped
with
a
cucurbit
crop
(
muskmelon,
cucumber,
or
squash).
MB
is
applied
every
year.
The
requested
quantity
can
decrease
if
MB
is
applied
every
two
years,
as
it
is
the
case
in
Michigan.
Are
there
any
constraints
to
adopt
this
frequency
in
Florida
and
Georgia?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
5.
The
MB
formulation
adopted
in
Florida
and
in
Georgia
is
67:
33.
Could
the
formulation
50:
50
be
adopted
in
these
two
eggplant
producing
regions?

6.
The
party
is
requested
to
explain
why
no
large­
plot
studies
have
yet
been
performed
to
show
commercial
feasibility
of
available
alternatives
in
US
eggplants
7.
Will
the
farm
demonstration
plots
will
be
implemented
in
2005?
If
yes,
please
give
more
details:
number,
distribution,
alternatives
etc.

8.
What
are
the
strategies
to
be
adopted
in
the
near
future
to
reduce
the
use
and
emission
of
MB?
etc..

9.
What
is
the
importance
use
of
HDPE
(
high
density
polyethylene)
to
minimize
use
and
emissions
of
MB
in
eggplant
production.

10.
No
reference
about
grafting
on
Solanum
torvum
rootstock
is
provided.
This
alternative
is
widely
used
and
expanding
very
quickly
in
the
Mediterranean
and
the
Netherlands,
as
an
MB
alternative
and
to
increase
production.
Solanum
torvum
is
fully
resistant
to
fusarium
and
nematodes,
with
no
problems
due
to
high
temperatures.
It
is
used
in
Central
America
under
very
hot
conditions.
Please
clarify
the
situation
in
the
US?

Double­
cropping
1.
For
Florida,
Table
11.1
indicates
that
most,
possibly
all,
of
the
CUN
crop
is
double­
cropped
(
page
13).
Please
clarify
what
percentage
of
the
eggplant
CUN
area
practices
doublecropping
in
Florida.
What
are
the
most
common
rotational
crops
in
Florida?
Table
11.1
indicates
peppers,
cucurbits;
whereas
page
7
mentions
several
other
crops
as
well.

Citations
list
(
section
26)
2.
The
citations
list
does
not
include
new
research,
new
communications
or
other
developments
since
2003.
With
only
one
exception,
the
citations
(
including
personal
communications)
in
the
citations
list
are
dated
December
2003
or
earlier.
Have
there
been
any
trials,
activities
or
developments
related
to
eggplant
and
issues
relevant
to
Decision
IX/
6
since
2003?
If
so,
please
provide
information.

Combination
treatments
with
herbicides
3.
In
Questions
sent
to
the
Party
on
eggplant
in
June
2003,
MBTOC
stated
that
"
MBTOC
is
concerned
that
much
of
the
research
conducted
on
uses
of
alternatives
is
conducted
on
peppers
or
tomato
and
extrapolated
to
eggplant
production,
particularly
on
the
impact
of
nutsedge
infestation."
Since
this
is
the
3
rd
year
of
a
CUN
request
for
eggplant
in
the
USA,
it
is
expected
that
very
substantial
progress
will
have
been
made
in
research
in
eggplant
by
now.
Please
clarify?

4.
The
section
on
Florida
(
pages
13­
20)
does
not
give
sufficient
consideration
to
combinations
of
several
fumigants
+
herbicides/
weed
control
methods.
The
only
fumigant
combinations
considered
in
the
section
on
Florida
are
(
a)
1,3­
D+
pic
(
page
13,
17),
and
(
b)
1,3­
D
+
pic
+
Devrinol
+
trifluralin
(
page
15).
Although
Table
C.
1
mentions
metham
with
or
without
pic
(
page
17)
the
citation
Locascio
et
al
1997
in
fact
covers
metham
alone,
therefore
Table
C.
1
relates
to
metham
alone.
Please
provide
information
about
any
other
combination
treatments,
such
as
several
fumigants
+
herbicides/
weed
control
methods
that
have
been
trialled
for
eggplant
in
Florida?

5.
The
CUN
for
Georgia
provides
information
on
several
combinations
of
fumigants
(
page
25)
but
does
not
provide
data/
information
on
combinations
of
fumigants
+
herbicides/
weed
control
methods.
If
such
combinations
have
been
tested
in
eggplant,
please
provide
copies
of
studies
or
citations?

Yield
loss
analysis
6.
The
tables
of
yield
loss
analysis
for
Florida
(
Table
C.
1
page
17)
and
Georgia
(
Table
C.
1
page
27)
do
not
appear
to
be
relevant
or
sufficient.
The
yield
loss
table
considers
only
1,3­
D
+
pic,
and
metham
(
alone).
(
Table
C.
1
is
based
only
on
Locascio
et
al
1997
(
pages
17,
25;
Table
16.1
on
pages
18,
28)
which
carried
out
small­
scale
trials
in
another
crop
(
tomato)
for
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
1,3­
D+
pic,
and
metham.
Although
Table
C.
1
appears
to
cover
metham
sodium
with
or
without
chloropicrin,
the
CUN
text
about
the
study
by
Locascio
et
al
(
1997)
indicates
that
metham
alone
was
tested.)
It
is
very
surprising
that
by
2005
the
CUN
does
not
provide
any
yield
results
for
eggplant,
nor
for
combinations
of
fumigants
+
herbicides/
weed
control
methods,
in
Florida
and
Georgia.

7.
The
sections
on
yield
in
Florida
and
Georgia
in
the
current
CUN
still
rely
strongly
on
other
crops.
Please
provide
more
information
about
yield
(
preferably
copies
of
studies
or
research
reports)
of
MB
alternatives
in
eggplant
in
Florida
and
Georgia,
particularly
focussing
on
the
following:
combinations
of
fumigants
+
weed
control,
using
improved
application
methods
which
became
available
in
recent
years.

8.
The
table
of
yield
loss
analysis
for
Michigan
(
Table
C.
1,
page
36)
appears
to
be
based
entirely
on
Hausbeck
and
Cortwright
[
sic]
(
2003),
a
study
which
is
not
in
the
citations
list.
Table
C.
1
(
on
page
36)
does
not
appear
to
take
account
of
a
more
recent
study
by
Cortright
and
Hausbeck
(
2004),
which
indicates
that
1,3­
D
+
pic
provided
a
higher
yield
of
eggplant
than
MB
(
Table
16.2
on
page
37).
Table
C.
1
also
suggests
that
the
range
of
yield
loss
from
use
of
1,3­
D
+
pic
was
as
high
as
95%
(
page
36).
However,
experience
in
use
of
1,3­
D
+
pic,
in
commercial
practice
and
in
trials,
does
not
support
this
degree
of
loss
when
appropriate
application
methods
are
used,
and
nutsedge
weeds
are
not
key
target
pests.
Please
clarify?
(
The
key
target
pests
in
Michigan
are
listed
as
Phytophthora
capsici
and
Verticillium
spp.
only
(
page
31))

Progress
in
registrations
9.
What
progress
has
been
made
in
registering
products
for
eggplant:
(
a)
iodomethane,
(
b)
herbicides
for
nutsedge,
(
c)
furfural,
(
d)
others?

Copies
of
studies
10.
Please
provide
a
copy
of
the
following
studies:
(
a)
Study
by
Culpepper
and
Langston
performed
in
2004
in
Georgia
(
CUN
pages
19
and
30).
There
is
no
citation
for
this
study
in
the
list
of
citations
in
the
CUN
(
section
26).
(
b)
Study
by
Culpepper
(
2004)
cited
on
page
29.
There
is
no
citation
for
this
study
in
the
list
of
citations
in
the
CUN
(
section
26).
(
c)
Study
by
Hausbeck
and
Cortwright
(
2003)
cited
in
Table
C.
1,
which
forms
the
justification
for
the
yield
loss
data
summary.
There
is
no
citation
for
this
study
in
the
list
of
CUN
citations
in
the
CUN
(
section
26).
(
d)
Study
by
Cortright
[
or
Cortrright]
and
Hausbeck
(
2004,
Evaluation
of
fumigants
for
managing
Phytophthora
crown
and
fruit
rot
of
solanaceous
and
cucurbit
crops)
which
is
summarised
on
page
37.
Since
this
appears
to
be
an
unpublished
study,
it
would
be
useful
for
MBTOC
to
see
the
technical
details.

Area
affected
by
moderate
to
severe
nutsedge
pressure
11.
Please
provide
survey
evidence,
or
similar
supporting
evidence,
on
the
prevalence
of
moderate
to
high
nutsedge
pressure
in
eggplant
production
regions
(
or
eggplant
CUN
areas)
in
Florida,
by
county.

12.
The
section
on
Georgia
says
the
area
affected
by
moderate
to
high
nutsedge
pressure
is
considered
to
be
approximately
58%
and
cites
Culpepper
(
2004)
(
page
29).
MBTOC
has
requested
a
copy
of
this
study
in
the
question
above.
If
Culpepper
(
2004)
does
not
provide
data
or
survey
results,
or
similar
supporting
evidence,
to
substantiate
the
estimated
CUN
areas
subject
to
moderate
to
severe
nutsedge
pressure
in
Georgia,
then
please
provide
additional
data.

Telone
label
relating
to
Karst
geology
or
topography
13.
In
March
2004
DAS
sent
the
following
information
to
MBTOC
(
Executive
Summary
of
Key
Issues
Pertinent
to
Use
of
Telone
Products
as
Alternatives
to
Methyl
Bromide
in
the
US,
DAS,
March
2004.)
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
 
"
A
`
karst
geology'
statement
appears
on
all
Telone
labels.
This
statement
is
intended
to
restrict
the
use
of
Telone
products
in
areas
where
applications
or
seepage
from
applications
may
infiltrate
groundwater.
 
Use
of
Telone
C­
35
(
and
all
other
Telone
products)
is
permitted
in
areas
where
there
is
an
impeding
layer
(
such
as
a
spodic
or
argillic
layer)
that
supports
seepage
irrigation
and
prevents
ground
water
infiltration.
Refer
to
label
wording.
 
The
term
`
karst
geology'
does
not
have
a
clear
definition
nor
can
an
area
of
`
karst
geology'
be
recognized
from
the
growers'
perspective
or
from
an
enforcement
perspective.
 
Dow
AgroSciences
(
DAS)
and
the
Florida
Department
of
Agriculture
and
Consumer
Services
(
FL
DACS)
have
agreed
to
change
this
confusing
wording
from
`
karst
geology'
to
`
karst
topography'
which
is
definable
and
recognizable
from
both
a
growers
perspective
and
enforcement
perspective
(
see
Appendix
2).

"
DAS
has
worked
with
the
Florida
Department
of
Agriculture
and
Consumer
Services
(
DACS)
to
clarify
this
confusion.
The
proposal
is
to
change
the
terminology
to
`
karst
topography.'
This
is
a
definable
term
and
`
karst
topography'
can
be
recognized
by
such
surface
features
as
sink
holes
or
disappearing
streams
which
are
characteristic
of
karst
areas.
Florida
DACS
agrees
with
this
refinement
and
has
written
a
letter
to
the
EPA
in
support
of
the
proposal
to
amend
and
clarify
the
label
in
this
way.
A
copy
of
DACS
letter
to
EPA
and
the
proposed
wording
for
the
label
amendment
are
provided ."

That
was
the
status
as
reported
by
DAS
in
March
2004.
The
Party
is
requested
to
clarify
if
Florida
DACS
and
the
EPA
have
amended
the
labels
for
Telone
products
so
that
its
use
is
restricted
to
areas
of
`
karst
topography'
as
described
above.

14.
The
table
below
indicates
soils
in
7
counties
of
Florida,
based
on
SSURGO
and
row
cropland
use
from
the
Florida
Geographic
Data
Library.
Source:
ABG.
2002.
Analysis
of
Methyl
Bromide
Replacement
with
Telone
in
Strawberries
in
California
and
Florida
and
Tomatoes
in
Florida.
Report
commissioned
by
DAS.
Does
the
Party
agree
with
the
analysis
in
the
table
below?
If
not,
please
send
corrections
or
alternative
data.

15.
What
proportion
of
the
eggplant
CUN
area
in
(
a)
Florida
and
(
b)
Georgia
has
an
underlying
impeding
layer
(
eg.
spodic,
argillic
layers)?

Analysis
of
Florida
soils
in
7
counties,
based
on
SSURGO
and
row
cropland
use
from
the
Florida
Geographic
Data
Library.
ABG,
2002.

Market
windows
13.
The
CUN
section
on
Michigan
states
that
fumigation
practices
must
be
completed
by
first
week
of
May
to
allow
growers
to
"
capture
the
early
market
(
July
 
September)"
(
page
32).
Does
"
first
week"
mean
that
planting
needs
to
take
place
during
the
first
week,
or
during
the
2
nd
week
of
May?
Does
the
entire
period
of
July­
September
comprise
the
"
early"
market?
Please
provide
price
data
for
eggplant
during
the
weeks
of
harvest
in
Michigan.
Since
Total
Acres
County
Acres
%
of
Total
Acres
%
of
Total
Acres
%
of
Total
Acres
Collier
39,748
83.7
7,555
15.9
210
0.4
47,513
Gadsden
41,433
97.3
987
2.3
184
0.4
42,604
Hendry
10,212
75.4
3,320
24.5
3
0.0
13,535
Hillsborough
23,795
83.8
4,361
15.4
228
0.8
28,384
Lee
9,879
90.7
821
7.5
188
1.7
10,888
Manatee
47,159
98.5
553
1.2
145
0.3
47,857
Palmbeach
25,941
77.5
7,357
22.0
172
0.5
33,470
Total
198,167
88.4
24,954
11.1
1,130
0.5
224,251
Spodic/
Argillic
Layer
No
Spodic/
Argillic
Layer
Non­
soil
Area
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
market
window
is
a
major
basis
for
the
eggplant
CUN
it
is
not
appropriate
to
use
price
data
for
peppers
as
stated
in
the
CUN
(
page
45).

14.
Eggplant
growth
is
curtailed
at
temperatures
below
16
°
C
(
page
7),
and
cold
temperatures
injure
this
crop.
In
Michigan
the
outside
temperature
is
reported
to
be
12
°
C
on
average
in
May,
the
month
when
eggplant
is
planted
(
page
32).
When
using
MB
at
present,
what
is
the
date
of
first
harvest,
and
yield
at
first
harvest,
if
eggplant
is
planted
in
(
a)
the
1
st
week
of
May,
(
b)
the
2
nd
week
of
May,
and
(
c)
3
rd
week
of
May?

Clarification
of
BUNI
data
15.
The
BUNI
(
page
51)
lists
metham
+
pic
as
the
marginal
strategy
used
for
Florida
and
Georgia
in
the
yield
loss
analysis.
However,
according
to
the
CUN
text
sections
on
Florida
and
Georgia,
metham
(
alone)
was
used
in
the
analysis
(
as
described
above
in
Q5).
The
BUNI
mentions
frequency
of
MB
treatment
as
1/
year
for
Michigan
(
page
51),
however
the
CUN
states
"
1
time
every
2
years"
(
page
31).
Please
clarify.

FRUIT,
NUT
AND
FLOWER
NURSERIES
Please
respond
to
these
questions
for
the
fruit,
nut,
and
flower
nursery
production
remaining
in
the
nomination
after
subtractions
were
made
for
QPS
and
growth
adjustments.
Please
answer
for
each
of
the
3
categories
"
Raspberries",
"
Fruit
and
Nut
Trees",
and
"
Roses".

Certification
Questions
1.
Is
100%
of
this
nomination
for
certified
propagative
material?

2.
Is
participation
in
the
certification
program
mandatory
or
voluntary?
Please
provide
copy
of
certification
requirements
3.
Are
the
requirements
of
the
certification
program
specified
in
local,
regional,
or
national
regulations?

3.
Is
the
certification
required
to
export
the
propagative
material
within
regional,
State
or
international
countries
(
Please
specify)?

5.
What
are
the
certification
standards?
For
example,
must
be
free
of
specific
pests
or
pathogens,
must
be
free
of
all
pests
and
pathogens,
tolerance
levels,
plant
must
be
of
a
certain
size,
etc.

6.
Is
the
use
of
methyl
bromide
mandated
for
certification?
Is
a
minimum
rate
of
methyl
bromide
specified?

7.
Are
there
soil
disinfestation
measures
other
than
MB
that
are
approved
for
certification
either
for
specific
crops/
growing
conditions
or
broadly
for
many
crops/
growing
conditions?
Why
can't
these
be
used
in
the
circumstances
of
the
nomination?

8.
Please
provide
data
demonstrating
that
MB
results
in
pest/
pathogen­
free
propagative
material.
Some
data
are
presented
in
Section
16
for
nematodes
on
roses
and
trees,
but
no
pest
data
is
presented
for
raspberries.

9.
Please
provide
data
showing
that
MB
alternatives
either
can
or
cannot
meet
pathogen/
pestfree
level
required
for
certification
by
providing
data
comparing
pest/
pathogen
populations
on
propagative
materials
grown
in
1)
soil
treated
with
methyl
bromide,
2)
untreated
soil,
3)
1,3­
D
and
chloropicrin
alone
and
in
combination,
and
4)
other
relevant
alternatives.
While
plant
growth
data
are
useful,
they
do
not
substitute
for
pest/
pathogen
data
if
the
certification
requirement
is
for
pest/
pathogen­
free
propagative
material.
Some
data
are
presented
in
Section
16
for
nematodes
on
roses
and
trees,
but
no
pest
data
is
presented
for
raspberries.
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
10.
What
are
the
consequences
of
not
meeting
the
pest/
pathogen­
free
standards?
For
example,
propagative
material
cannot
be
sold,
material
can
be
sold
as
lower
quality/
lower
price,
propagative
materials
must
be
treated
before
selling
to
kill
pest/
pathogen
(
e.
g.
hot
water
dips,
etc.),
etc.

11.
If
certification
isn't
mandated
by
law
or
regulation,
is
it
used
as
a
quality
standard
demanded
or
expected
in
order
to
market
the
crop?
Why
can't
MB
alternatives
be
used
to
meet
the
quality
standard?

12.
What
are
the
consequences
of
not
meeting
the
quality
standard?
For
example,
inability
to
sell
crop,
lower
price
for
crop,
etc.

General
Questions
13.
90%
of
raspberry,
99%
of
rose,
and
100%
of
Fruit
&
Nut
tree's
original
requests
were
removed
from
the
nomination
as
meeting
the
criteria
of
QPS.
What
is
the
difference
between
QPS
and
non­
QPS
raspberry,
fruit
and
nut
tree,
and
rose
nursery
production?

14.
Party
states
the
proportion
of
the
crop
grown
with
MB
is
not
available.
However
this
information
is
very
important.
Can
the
Party
make
an
"
educated
guess"
at
the
crop
proportion
grown
with
(
or
without)
methyl
bromide?

15.
Iodomethane
might
be
registered
soon
by
the
EPA.
Party
is
requested
to
provide
information
on
the
possibility
of
reducing
methyl
bromide
use
in
2007
if
iodomethane
is
registered.

Raspberry
Questions
16.
In
section
11ii,
Party
states
"
Soil
moisture
is
an
important
determinant
of
capacity
of
1,3­
D
efficacy
(
5)."
(
5)
appears
to
be
a
reference
for
this
statement,
but
no
corresponding
list
of
numbered
references
is
provided.
Please
provide
this
reference.

17.
Section
13
states
that
1,3­
D
could
possibly
be
considered
a
cost
effective
alternative
where
soil
conditions
and
township
caps
allow.
BUNI
does
not
indicate
any
adjustments
for
Regulatory
Issues
or
Soil
conditions
(
unsuitable
terrain?)
for
raspberries.
Does
this
mean
that
there
are
no
regulatory
or
soil
conditions
restricting
use
of
1,3­
D
for
the
raspberry
production
areas
in
this
CUN?
If
there
are
no
restrictions
on
1,3­
D
and
it
is
effective,
why
is
methyl
bromide
needed?
If
there
are
regulatory
or
soil
conditions
restricting
use
of
1,3­
D,
please
state
%
of
nomination
impacted
by
these
restrictions.

18.
Party
states
"
container­
grown
plants
produce
shorter
or
curved
roots.
.
.
.
any
reduction
in
surface
area
would
reduce
the
number
and/
or
quality
of
new
canes."
Please
supply
a
reference
for
this
information.

Fruit
and
Nut
Tree
Questions
19.
Is
"
incompatible
soil
moisture"
include
in
the
"
Unsuitable
Soil
Terrain"
column
of
the
BUNI?

20.
Text
states
that
65%
of
the
area
cannot
be
treated
with
1,3­
D
because
of
incompatible
soil
moisture
or
soil
type,
or
township
caps,
but
BUNI
does
not
show
any
adjustments
for
Regulatory
Issues
or
Unsuitable
Terrain.
Please
provide
information
on
the
%
of
the
nomination
for
Trees
that
is
impacted
by
township
caps
and
soil
moisture/
soil
type
restrictions.

21.
Could
a
67:
33
formulation
of
methyl
bromide:
chloropicrin
be
used
to
reduce
the
amount
of
methyl
bromide
use
in
fruit
and
nut
tree
nursery
production?
If
not,
why?

Rose
questions
22.
Table
13
indicates
that
1,3­
D
could
be
an
alternative
if
no
restrictions
apply.
It
further
states
that
"
US
nomination
is
for
areas
where
1,3­
D
is
not
effective".
Does
the
Party
mean
"
not
available"?
If
1,3­
D
is
considered
not
effective,
state
the
conditions
under
which
it
is
not
effective
and
the
%
of
the
nomination
impacted
by
these
conditions.
No
adjustments
for
Unsuitable
Soils
is
given
in
BUNI.
If
soil
moisture
or
soil
type
is
restricting
uptake
of
alternatives,
please
state
the
percentage
of
the
nomination
impacted
by
these
restrictions.
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
23.
Could
a
67:
33
formulation
of
methyl
bromide:
chloropicrin
be
used
to
reduce
the
amount
of
methyl
bromide
use
in
rose
nursery
production?
If
not,
why?
24.
Although
Party
states
that
1,3­
D
is
a
technically
feasible
alternative
wherever
restrictions
do
not
limit
its
use,
no
economic
analysis
is
included
with
the
nomination.
Such
an
analysis
is
essential
for
MBTOC
to
carry
out
an
economic
feasibility
analysis.
Is
it
the
position
of
the
Party,
that
if
1,3­
D
is
technically
feasible
for
this
CUN,
it
is
also
economically
feasible?

25.
Party
is
requested
to
clarify
what
measures
will
be
taken
to
reduce
and
phase­
out
MB
use
in
the
coming
years.

US
FOREST
SEEDLINGS
Please
respond
to
these
questions
for
the
forest
seedling
production
remaining
in
the
nomination
after
subtractions
were
made
for
QPS,
double­
counting,
growth,
and
rate
adjustments.

Certification
Questions
1.
What
%
of
this
nomination
is
for
certified
forest
seedlings?
If
0%,
please
go
to
question
#
13
below.

2.
Is
participation
in
the
certification
program
mandatory
or
voluntary?

3.
Are
the
requirements
of
the
certification
program
specified
in
local,
regional,
or
national
regulations?

4.
Is
the
certification
required
to
export
the
forest
seedlings?

5.
What
are
the
certification
standards?
For
example,
must
be
free
of
specific
pests
or
pathogens,
must
be
free
of
all
pests
and
pathogens,
plant
must
be
of
a
certain
size,
etc.

6.
Is
the
use
of
methyl
bromide
or
other
alternatives
mandated
for
certification?
Is
a
minimum
rate
of
methyl
bromide
or
other
alternatives
specified?

7.
Are
there
soil
disinfestation
measures
other
than
MB
that
are
approved
for
certification
either
for
specific
crops/
growing
conditions
or
broadly
for
many
crops/
growing
conditions?
Why
can't
these
be
used
in
the
circumstances
of
the
nomination?

8.
Please
provide
data
demonstrating
that
MB
results
in
pest/
pathogen­
free
propagative
material.

9.
Please
provide
data
showing
that
MB
alternatives
either
can
or
cannot
meet
pathogen/
pestfree
level
required
for
certification.

10.
What
are
the
consequences
of
not
meeting
the
pest/
pathogen­
free
standards?
For
example,
propagative
material
cannot
be
sold,
material
can
be
sold
as
lower
quality/
lower
price,
propagative
materials
must
be
treated
before
selling
to
kill
pest/
pathogen
(
e.
g.
hot
water
dips,
etc.),
etc.

11.
If
certification
isn't
mandated
by
law
or
regulation,
is
it
used
as
a
quality
standard
demanded
or
expected
in
order
to
market
the
crop?
Why
can't
MB
alternatives
be
used
to
meet
the
quality
standard?

12.
What
are
the
consequences
of
not
meeting
the
quality
standard?
For
example,
inability
to
sell
crop,
lower
price
for
crop,
etc.

General
Questions
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
13.
Table
16
reports
data
for
numerous
weed
control
trials.
Only
2
trials
report
data
on
disease
control,
both
of
which
show
alternatives
providing
good
control.
Are
there
other
data
that
show
less
disease
control
with
alternatives,
or
is
the
basis
for
this
CUN
primarily
the
need
for
weed
control?

14.
Are
there
published
references
to
the
data
reported
in
Table
16?

15
.
Does
Table
16
report
results
across
all
regions
in
the
CUN?
If
not,
what
regions
are
the
data
from?

16.
Methyl
bromide
use
rates
reported
in
Section
9
of
the
CUN
vary
from
21.0
to
39­
7
g/
m
2
.
The
lower
rates
are
being
used
by
regions
who
are
using
a
higher
%
of
chloropicrin
in
the
formulation.
Why
can't
the
higher
chloropicrin
%
and
lower
methyl
bromide
rates
be
used
in
all
regions?

17.
0­
50%
of
each
applicant's
original
request
was
removed
from
the
nomination
as
meeting
the
criteria
of
QPS.
What
is
the
difference
between
QPS
and
non­
QPS
forest
seedling
production?

18.
Is
halosulfuron
or
trifloxysulfuron
registered
for
weed
control
in
forest
seedling
production?
If
not,
is
future
registration
planned?
If
not,
why?

19.
Several
regions
fumigate
only
once
every
2,
3,
or
4
years,
rather
than
annually
and
point
out
that
use
of
an
alternative
might
require
annual
fumigation
which
could
impact
cost
and
increase
the
amount
of
pesticides
in
the
environment.
Please
present
economic
data
showing
the
projected
impact
of
more
frequent
fumigations
with
alternatives.
Besides
economic
and
environmental
burdens,
are
there
any
other
reasons
that
annual
fumigation
with
a
methyl
bromide
alternative
would
not
be
feasible?

20.
In
section
13,
inconsistent
results
in
weed
control
with
dazomet
and
metham
sodium
are
cited.
Is
the
inconsistent
weed
control
a
problem
in
the
1
st
,
2
nd
,
3
rd
,
and/
or
4
th
crop
following
fumigation?

21.
The
Weyerhauser­
West
region
mentioned
control
of
Phytophthora
ramorum
as
one
reason
methyl
bromide
is
needed.
Isn't
this
pathogen
a
quarantine
pathogen?

22.
The
amounts
of
methyl
bromide
stated
in
tables
8.2,
8.3,
8,5
8.6,
8.7
and
8.8
are
not
consistent
with
the
amounts
stated
in
table
A.
1.
Please
clarify
the
correct
amounts.

23.
Actual
dose
rates
of
region
B
(
Page
22)
and
D
(
Page
27)
increased
in
2003
compared
to
2002.
Please
explain
why
the
dose
rates
increased.

24.
In
region
D,
a
formulation
of
90:
10
methyl
bromide:
chloropicrin
was
used
during
2000­
2002.
Why
did
use
return
to
the
98:
2
formulation
in
2003?

25.
Party
considers
containerized
or
substrate
production
too
expensive
for
tree
seedlings
and
includes
some
economic
considerations.
However,
there
is
no
specific
validation
of
the
economics
for
herbaceous
perennials
(
e.
g.
Delphinium,
Hostas,
Phlox)
also
included
in
this
nomination.
These
species
are
different
from
trees
with
respect
to
cropping
cycle,
use,
etc,
and
are
propagated
in
plug
trays
or
liners
with
different
kinds
of
substrates
in
many
countries
and
even
in
the
United
States
(
e.
g.
see
reference
below).
Please
present
information
on
why
the
containerized
or
substrate
production
cannot
be
used
foe
the
specific
circumstances
of
this
nomination.
Reference:
Styer,
R.
C.
and
D.
S.
Koranski
1997.
Plug
and
Transplant
production
­
a
Grower's
Guide.
Ball
Publishing,
USA,
373
pp.

US
ORCHARD
REPLANTS
1.
Based
on
the
information
in
the
text
and
in
the
BUNI,
it
appears
that
methyl
bromide
is
nominated
for
critical
use
in
3
situations:
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
 
where
the
"
key
pest"
is/
are
the
causal
agent(
s)
of
Replant
Disorder
which
has
an
unknown
etiology
(
35­
50%
of
the
stone
fruit
area,
35%
of
the
grape
area,
85%
of
the
walnut
area,
and
35­
50%
of
the
almond
area);
 
where
the
primary
pests
are
nematodes
and
maximum
allowed
rate
of
1,3­
D
is
not
effective
due
to
fine­
textured
soils
and/
or
inability
to
sufficiently
the
dry
the
soil
at
the
deeper
depths
to
the
level
required
for
effective
use
of
1,3­
D
(
35­
50%
of
area
for
all
4
crops
)
 
where
primary
pests
are
nematodes
and
Township
caps
prevent
the
use
of
1,3­
D,
which
would
otherwise
be
expected
to
be
effective
(
2­
8%
of
area
for
all
4
crops)
Please
confirm
if
this
is
a
correct
understanding
of
the
nomination.
If
it
is
not
correct,
please
clarify.

1.
For
those
areas,
where
the
primary
pests
are
nematodes,
but
1,3­
D
cannot
effectively
be
used
(
situations
#
2
and
#
3
above),
please
clarify
why
metham
sodium,
alone
or
combined
with
chloropicrin,
is
not
an
effective
MB
alternative
and
provide
references.

2.
In
Table
7.1,
Average
Total
Replant
Area
in
2001
and
2002
and
Proportion
of
Total
Replant
Area
Treated
with
Methyl
Bromide
are
given
only
for
almonds
and
are
designated
as
"
Not
Available"
for
stone
fruit,
grape,
and
walnut.
Has
this
information
become
available
in
the
time
since
the
nomination
was
prepared?
If
so,
please
provide
this
info.

3.
In
Table
8.1
(
and
in
the
BUNI),
the
footnotes
indicate
that
some
of
the
stone
fruit
and
almond
area
is
strip
fumigated.
Please
clarify
if
the
application
rate
of
active
ingredient
(
336
and
364
kg/
ha)
in
the
table
is
the
rate
per
treated
unit
of
area
in
the
strips
or
how
this
value
was
calculated.

4.
What
were
the
primary
pests
in
the
trial
in
table
16.1
Stone
fruit
 
specific
nematodes,
specific
fungi,
or
the
unknown
replant
disorder
causal
agent(
s)?

5.
In
table
11.1
Grapes,
the
soil
type
is
given
as
"
light",
but
BUNI
shows
that
35­
50%
of
the
grape
area
is
impacted
by
Unsuitable
Soil.
Since
it
is
not
due
to
fine­
textured
soils,
is
the
Unsuitable
Soil
due
to
inability
to
dry
down
the
deeper
soil
depths?
Please
clarify.

6.
In
Table
11.1
Walnut,
soil
type
is
given
as
40%
medium
and
30%
heavy.
BUNI
states
that
35­
50%
of
the
area
is
impacted
by
unsuitable
soils.
Does
that
mean
that
some
of
the
area
with
medium
soil
types
can
use
alternatives?
Which
alternatives
have
been
successfully
used?

7.
In
Section
11ii
Walnut,
the
nomination
states
that
70%
of
walnut
orchard
situations
are
impacted
by
soil
moisture
restrictions
and
township
cap
restrictions.
BUNI
shows
35­
50%
impacted
by
Unsuitable
Soils
and
2­
8%
impacted
by
Regulatory
Issues.
If
there
was
no
overlap
between
the
two
areas,
the
maximum
in
the
BUNI
for
Unsuitable
Soil
and
Regulatory
restrictions
would
be
58%.
What
alternatives
are
being
used
in
the
remaining
12%
of
the
area?
Please
clarify.

8.
Is
the
soil
moisture
restriction
mentioned
in
section
11ii­
Walnut
due
to
surface
soil
conditions
as
stated
here,
or
due
to
deeper
soil
moisture
conditions
as
described
elsewhere
in
the
CUN,
or
to
some
combination
of
both?
Please
clarify.

9.
Table
16.1
Walnuts
refers
the
reader
to
Table
16
for
stone
fruit,
grapes
and
almonds.
Are
there
no
data
for
Replant
Disorder
or
nematode
control
available
on
walnuts?
If
such
data
are
available,
please
provide.

10.
Table
10.1­
Almonds
states
that
30%
of
the
area
is
impacted
by
Township
caps
and
65%
by
soil
moisture
issues.
BUNI
states
that
only
2­
8%
of
the
requested
area
is
impacted
by
Township
caps
and
35­
50%
impacted
by
Unsuitable
Soil
issues.
What
alternatives
are
being
used
on
the
22­
28%
of
the
area
impacted
by
Township
Caps,
but
not
requesting
critical
use
MB
and
on
the
15­
30%
impacted
by
soil
moisture
issues,
but
not
requesting
MB?
Why
can
these
alternatives
not
be
used
on
the
remaining
area?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
11.
In
Table
16.1
 
Almond,
what
were
the
primary
pests
in
the
trial
 
specific
nematodes,
specific
fungi,
or
the
unknown
replant
disorder
causal
agent(
s)?

12.
In
Section
23,
the
nomination
states
that
orchard
replant
research
will
require
1658
kg
per
year
of
MB
for
2005
and
2006.
This
is
the
2007
nomination,
and
BUNI
shows
a
research
amount
of
1658
kg,
so
is
it
accurate
to
say
that
1658
kg
of
MB
is
also
needed
for
research
in
2007?

US
ORNAMENTALS
1.
MBTOC
is
still
not
clear
as
to
the
proportion
of
the
cropping
area
that
is
presently
treated.
In
the
BUNI
form
at
the
end
of
the
nomination
there
is
a
column
labeled
"
regional
areas"
where
11%
is
indicated
for
California
and
90%
for
Florida.
Party
is
asked
to
clarify
if
this
corresponds
to
the
treated
area.

2.
Acreages
submitted
by
Party
for
the
American
Flower
industry
do
not
seem
to
coincide
with
those
appearing
in
official
publications
such
as
USDA
Floriculture
and
Nursery
Crops
Situation
and
Outlook
Yearbook/
FLO­
2004/
Junie,
2004
www.
ers.
usda.
gov
IN
CALIFORNIA
3.
Party
states
that
regulatory
constraints
such
as
township
caps
restrict
MB
use
in
California.
MBTOC
is
not
clear
as
to
what
percentage
of
the
cropping
area
is
affected
by
this
restriction.
Party
states
that
"
It
is
expected
that
about
30%
of
the
2000
fumigated
area
could
not
have
used
1,3­
D
at
the
current
2x
cap
which
is
expected
to
apply
through
at
least
2004".
MBTOC
requests
Party
to
confirm
that
this
holds
for
2007.
The
BUNI
form
states
that
township
caps
(
regulatory
issues)
affect
between
31
and
44%
of
area.

IN
FLORIDA
4.
Party
states
that
buffer
zones
restrict
use
of
1,3­
D
because
often
flowers
are
produced
on
small
parcels
of
land,
often
near
homes.
1,3­
D
cannot
be
used
in
greenhouses.
Party
is
asked
to
confirm
what
proportion
of
the
cropping
area
is
affected
by
this
issue.
On
p.
55
Party
states
that
buffer
zones
"
will
reduce
cropping
area
by
10%".
The
BUNI
however
allocates
a
0
under
the
buffer
zone
column
for
both
California
and
Florida,
although
it
cites
karst
topography
as
affecting
40%
of
area
in
Florida.

USA
STRAWBERRY
FRUIT
Data
on
MB
usage
1.
On
page
38,
the
dosage
rate
of
MB
active
ingredient
in
kg/
ha
in
2003
is
shown
as
increased
to
24.7kg/
ha
from
18.5kg/
ha
in
the
previous
year.
The
Party
is
requested
to
provide
MBTOC
with
information
on
the
reason
why.

2.
Page
11
stated
that
the
formulation
of
MB/
CP
is
98:
2
in
Florida,
while
Page
76.
stated
is
67:
33
or
50:
50.
Which
formulation
is
correct?

3.
The
CUN
does
not
explain
fully
why
this
sector
cannot
adopt
50:
50
MB/
Pic
in
Florida
and
eastern
states,
and
57:
43
(
or
50:
50
if
registered)
in
California.

4.
What
statistics
are
available
on
the
use
of
1,3­
D,
chloropicrin,
metham,
other
combinations
of
fumigants
or
chemicals,
and
other
types
of
alternatives,
for
strawberry
fruit
in
Florida,
California
and
eastern
states
for
2002,
2003
and
2004?
MBTOC
would
appreciate
information
on
recent
trends.
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
VIF
5.
VIF
has
been
in
commercial
use
in
most
regions
of
the
EC
for
several
years,
because
it
has
been
a
legal
requirement
for
four
years.
Substantial
trials
were
conducted
in
several
countries
and
climates.
At
this
stage,
there
is
little
technical
justification
for
not
adopting
VIF,
since
there
is
substantial
practical
experience
with
this
technology
in
many
different
types
of
cropping
systems.
What
are
the
limiting
impediments
(
if
any)
to
the
widespread
adoption
of
this
proven
emission
reduction
technology?

Economic
issues
6.
Concerning
table
21.1,
table
22.1
and
table
E.
1,
E.
2
andE.
3:
(
1)
Please
check
the
accuracy
of
Table
21.1
(
copied
in
Annex
2
below).
Are
the
operating
costs
the
same
for
methyl
bromide
and
other
alternatives?
Are
the
operating
costs
the
same
over
three
years?
For
example,
in
this
period
it
is
likely
that
the
cost
of
MB
will
increase.
Please
provide
the
actual
costs
in
2004
and
2005
and
estimated
cost
in
2006..
(
2)
Concerning
Table
E.
1
(
Page
50)
for
California,
if
the
figure
of
table
21.1
is
as
it
is,
the
figure
of
table
E.
1
should
be
changed
as
shown
in
red
colour
in
Annex
2
below.
Please
check
it
whether
it
is
appropriate
or
not.
(
3)
Concerning
the
Table
E.
2
(
Page
51)
for
Florida
and
Eastern
United
States,
figures
should
be
changed
to
the
ones
written
in
red
below.

7.
What
prices
and
doses
were
used
for
each
alternative
chemical
product
in
the
economic
tables?
What
are
the
current
commercial
prices
of
these
products
in
2005,
in
each
region?

Efficacy
/
yield
loss
8.
Could
the
Party
please
indicate
the
treated
area
percent
proportion
compared
to
one
hectare
in
Eastern
USA
and
Florida
with
bed/
strip
treatment
system?
Is
MB
bed/
strip
treatment
effective
for
the
control
of
nematodes
and
nutsedge?

9.
In
Table
16.1
on
effectiveness
of
alternatives
for
`
key
pest
1
yellow
nutsedge'
(
page
21­
22)
the
first
study
indicated
that
MB/
CP
(
at
392
kg/
ha)
gave
no
significant
difference
in
native
weed
biomass
compared
with
alternatives
chloropicrin
and
1,3­
D/
CP
(
especially
at
higher
rates,
and/
or
with
VIF),
in
control
of
`
Key
pest
yellow
nutsedge'.
The
second
and
third
study
in
Table
16.1
indicated
that
certain
doses
of
alternatives,
chloropicrin,
1,3­
D/
CP
and
MS
(
35
gal
drip)
provided
higher
yield
than
MB/
CP.
However,
the
estimates
of
yield
loss
in
Table
C.
1
in
California,
eastern
states
and
Florida
(
pages
23,
33
and
43)
appear
to
be
taken
only
from
Shaw
and
Larson
(
1999)
and
Locascio
(
1999).
More
recent
studies,
using
improved
application
methods
and
other
combinations
of
fumigants/
chemicals
have
been
carried
out
since
that
time.
Such
studies,
using
the
better
application
methods
and
know­
how
currently
available,
should
form
the
basis
for
the
yield
analysis.

Steep
slopes
10.
On
steep
slopes,
it
is
feasible
to
use
shank
injection
for
alternative
fumigants.
This
is
the
method
currently
used
for
MB,
according
to
the
CUN
(
page
15).
The
CUN
does
not
adequately
explain
why
shank
injection
could
not
be
used
for
alternatives
on
steep
slopes.

Dates
of
planting,
harvest,
rotational
crops
11.
Please
provide
more
precise
dates
of
planting
and
harvest
(
start
/
finish)
and
key
market
windows
for:
Northern
California,
southern
California,
Florida
and
eastern
states.
Where
rotational
crops
are
common,
please
identify
them
and
provide
planting
and
harvest
dates,
for
each
region.

Nutsedge
12.
Could
the
Party
please
give
more
information
about
the
way
in
which
nutsedge
propagates
or
is
spread?
MB
itself
provides
incomplete
control.
Which
cultural
control
practices
have
been
investigated
for
nutsedge
control
in
strawberry
fruit?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
13.
Why
is
it
not
considered
feasible
to
use
herbicides
to
control
nutsedge
before
transplanting
strawberry?
The
CUN
does
not
provide
a
detailed
update
on
progress
in
examining
and
registering
herbicides
for
the
control
of
nutsedge
in
strawberry
fruit.
Please
provide
an
update.

Nematicides
14.
Fosthiazate,
a
nematicide,
was
registered
by
USEPA
a
couple
of
years
ago.
The
Party
is
requested
to
provide
MBTOC
with
the
information
on
registration
and
deployment
in
the
strawberry
industry,
in
each
relevant
region
(
California,
Florida,
eastern
US).

Supporting
data
on
area
affected
by
moderate
to
severe
pest
pressure
15.
The
previous
CUN
stated
that
the
area
(
hectares)
affected
by
moderate
to
severe
key
pests
(
eg.
nutsedge)
was
derived
from
informal
sources
such
as
websites,
discussions
with
researchers
and
growers
etc.
Is
additional
data
now
available
to
substantiate
these
informal
sources?
Have
any
surveys
been
carried
out
on
the
extent
and
severity
of
key
target
pests
that
form
the
basis
of
the
CUNs
in
(
a)
Florida,
(
b)
eastern
states,
and
(
c)
California?
If
so,
MBTOC
would
be
grateful
to
receive
copies
of
the
detailed
survey
results.

Regulatory
restrictions
on
1,3­
D
16.
MBTOC
recognizes
that
regulatory
restrictions
restrict
the
use
of
1,3­
D
in
certain
regions.
Some
other
fumigants/
chemicals
have
been
found
effective
in
controlling
the
key
nematode
species
affecting
strawberry
fruit
production.
To
what
extent
can
these
techniques
be
adopted
in
the
areas
where
1,3­
D
cannot
be
used
for
regulatory
reasons?
Please
re­
calculate
the
CUN
tonnage
to
take
full
account
of
other
available
treatments/
combinations
in
areas
affected
by
regulatory
restrictions
on
1,3­
D.

17.
Are
there
different
definitions
for
`
karst
geology'
and
`
karst
topography'?
The
CUN
cites
a
Registration
Eligibility
Decision
for
1,3­
D
from
1998
(
page
45).
We
understand
that
some
label
changes
were
proposed
relating
to
karst
topography.
Have
any
changes
been
made
in
the
federal,
state
or
county
restrictions,
labels
or
other
controls
relating
to
karst
geology/
topography
in
the
last
few
years?
If
so,
what
are
the
current
restrictions
relating
to
karst?
If
these
changes
will
mean
that
1,3­
D
can
be
used
on
a
larger
area
than
estimated
in
the
CUN,
please
provide
up­
dated
calculations
of
hectares.

Information
relating
to
potential
adoption
time
(
Annex
I
of
Prague
MOP)
18.
For
each
region
(
California,
Florida
and
eastern
states),
please
estimate:
(
a)
the
number
of
fumigation
companies
that
currently
provide
MB
fumigation
services
to
growers,
(
b)
the
estimated
number
of
growers
in
each
region,
and
(
c)
the
number
and
types
of
government
and
private
training
and
extension
facilities
and
personnel
available
to
the
strawberry
sector.

Other
information
19.
If
you
are
aware
of
any
additional
information
that
would
assist
MBTOC/
TEAP
to
make
a
complete
technical
and
economic
evaluation
of
the
CUN,
as
defined
in
Decision
IX/
6,
we
would
be
very
grateful
to
receive
the
information.

ANNEX
1
AMOUNT
OF
MB
USED/
REQUESTED,
NO
OF
YEARS
REQUESTED
&
HISTORIC
USE:
199
8
199
9
200
0
200
1
200
2
200
3
200
4
200
5
200
6
Formula
tion
Proporti
on
of
Use
Californi
a
1,92
8
2,26
4
1.91
9
1,61
1
1,59
2
1,65
1
108
7
Mostly
67:
33
(
Flat
Fume)
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
MB
Dosage
rate
g/
m2
26
27.5
24.4
19.1
20.1
20.1
20.
1
MB+
CP
Dosage
rate
g/
m2
38.8
41.0
36.4
28.5
30.0
30.0
Eastern
USA
317
239
254
274
283
320
230
67:
33
(
Bed)
Dosage
rate
g/
m2
22
15.1
15.0
15.1
15.1
15.1
15.
1
MB+
CP
Dosage
rate
g/
m2
32.8
22.5
22.4
22.5
22.5
22.5
Florida
551
464
471
486
516
708
296
98:
2
(
strip)
Dosage
rate
g/
m2
22.0
18.5
18.8
18.5
18.5
24.7
18.
5
MB+
CP
Dosage
rate
g/
m2
22.4
18.9
19.2
18.9
18.9
25.2
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
ANNEX
2
21.
OPERATING
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

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

Methyl
Bromide
100%
$
65,888
$
65,888
$
65,888
Chloropicrin
+
Metham
sodium
73%
$
65,683
$
65,683
$
65,683
1,3­
D
+
chloropicrin
86%
$
65,664
$
65,664
$
65,664
California
Metham
Sodium
70%
$
65,684
$
65,684
$
65,684
Methyl
Bromide
100%
$
44,254
$
44,254
$
44,254
1,3­
D
+
chloropicrin
86%
$
43,030
$
43,030
$
43,030
Chloropicrin
+
Metham
Sodium
73%
$
39584
$
39584
$
39584
Florida
Metham
Sodium
70%
$
38,818
$
38,818
$
38,818
Methyl
Bromide
100%
$
29,482
$
29,482
$
29,482
Chloropicrin
+
Metham
sodium
73%
$
30,555
$
30,555
$
30,555
1,3­
D
+
chloropicrin
86%
$
31,658
$
31,658
$
31,658
Eastern
United
States
Metham
Sodium
70%
$
30,270
$
30,270
$
30,270
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.

22.
GROSS
AND
NET
REVENUE
TABLE
22.1:
YEAR
1,
2,
3
GROSS
AND
NET
REVENUE
YEAR
1,
2,
3
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
76,252
$
10,363
Chloropicrin+
Metham
sodium
$
55,664
($
10,020)
1,3­
D
chloropicrin
$
65,548
($
3,840)
California
Metham
Sodium
$
53,376
($
12,307)
Methyl
Bromide
$
55,168
$
10,914
1,3­
D
+
chloropicrin
$
47,224
$
4,194
Chloropicrin
+
Metham
Sodium
$
40,273
$
689
Florida
Metham
Sodium
$
38,728
($
90)
Methyl
Bromide
$
51,892
$
22,410
Chloropicrin+
Metham
sodium
$
37,881
$
7,327
1,3­
D
chloropicrin
$
44,608
$
12,950
Eastern
United
States
Metham
Sodium
$
36,624
$
6,054
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
PIC+
METHA
M
SODIUM
1,3­
D+
PIC
METHAM
SODIUM
YIELD
LOSS
(%)
0%
27%
14%
30%
YIELD
PER
HECTARE
(
FRESH)
48,438
35,359
41,639
33,906
*
PRICE
PER
UNIT
(
US$)
$
1.71
$
1.62
$
1.62
$
1.62
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
76,252
$
55,684
$
65,548
$
53,376
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
65,888
$
65,888
$
65,888
$
65,888
=
NET
REVENUE
PER
HECTARE
(
US$)
$
10,364
$­
10,204
$­
340
$­
12,515
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
17,792
11,817
19,474
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
88.19
58.57
96.52
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
24%
16%
26%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
131%
87%
144%

FLORIDA
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FLORIDA
METHYL
BROMIDE
1,3­
D+
PIC
PIC+
METHAM
SODIUM
METHAM
SODIUM
YIELD
LOSS
(%)
0%
14%
27%
30%
YIELD
PER
HECTARE
5,046
4,319
3,683
3,542
*
PRICE
PER
UNIT
(
US$)
$
10.93
$
10.93
$
10.93
$
10.93
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
55,168
$
47,224
$
40,273
$
38,728
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
44,254
$
43,030
$
39,584
$
38,818
=
NET
REVENUE
PER
HECTARE
(
US$)
$
10,914
$
4,194
$
689
$ 
90
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
6,720
$
10,225
$
11,004
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
33
$
51
$
55
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
14.4%
27.0%
29.8%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
62%
94%
101%

EASTERN
UNITED
STATES
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
EASTERN
UNITED
STATES
METHYL
BROMIDE
PIC+
METHA
M
SODIUM
1,3­
D+
PIC
METHAM
SODIUM
YIELD
LOSS
(%)
0%
27%
14%
30%
YIELD
PER
HECTARE
22,417
16,364
19,270
15,692
*
PRICE
PER
UNIT
(
US$)
2.59
2.59
2.59
2.59
=
GROSS
REVENUE
PER
HECTARE
(
US$)
51,892
37,881
44,608
36,324
­
OPERATING
COSTS
PER
HECTARE
(
US$)
29,482
30,555
31,658
30,270
=
NET
REVENUE
PER
HECTARE
(
US$)
22,410
7,327
12,950
6,054
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
14,942
9,319
16,215
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
99.49
62.05
107.96
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
29%
18%
31%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
67%
42%
73%

US
Strawberry
nurseries
1.
What
are
the
constraints
to
much
wider
use
of
VIF,
combined
with
MB
and
other
fumigants
as
1,3­
D
and
Pic,
where
applicable
combined
with
solarization.

Certification:
2.
Is
100%
of
this
nomination
for
certified
propagative
material?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
3.
Has
part
of
the
nomination
been
exempted
under
QPS?
Specify
amount/
proportion
XXt(
eg
80%)?

4.
Is
participation
in
the
certification
program
mandatory
or
voluntary?
Please
provide
copy
of
certification
requirements
5.
Are
the
requirements
of
the
certification
program
specified
in
local,
regional,
or
national
regulations?

6.
Is
the
certification
required
to
export
the
propagative
material
within
regional,
State
or
international
countries
(
Please
specify)?

7.
What
are
the
certification
standards?
For
example,
must
be
free
of
specific
pests
or
pathogens,
must
be
free
of
all
pests
and
pathogens,
tolerance
levels,
plant
must
be
of
a
certain
size,
etc.

8.
Is
the
use
of
methyl
bromide
mandated
for
certification?
Is
a
minimum
rate
of
methyl
bromide
specified?

9.
Are
there
soil
disinfestation
measures
other
than
MB
that
are
approved
for
certification
either
for
specific
crops/
growing
conditions
or
broadly
for
many
crops/
growing
conditions?
Why
can't
these
be
used
in
the
circumstances
of
the
nomination?

10.
Please
provide
data
demonstrating
that
MB
results
in
pest/
pathogen­
free
propagative
material.

11.
Please
provide
data
showing
that
MB
alternatives
either
can
or
cannot
meet
pathogen/
pest­
free
level
required
for
certification
by
providing
data
comparing
pest/
pathogen
populations
on
propagative
materials
grown
in
1)
soil
treated
with
methyl
bromide,
2)
untreated
soil,
3)
1,3­
D
and
chloropicrin
alone
and
in
combination,
and
4)
other
relevant
alternatives.
While
plant
growth
data
are
useful,
they
do
not
substitute
for
pest/
pathogen
data
if
the
certification
requirement
is
for
pest/
pathogen­
free
propagative
material.

12.
What
are
the
consequences
of
not
meeting
the
pest/
pathogen­
free
standards?
For
example,
propagative
material
cannot
be
sold,
material
can
be
sold
as
lower
quality/
lower
price,
propagative
materials
must
be
treated
before
selling
to
kill
pest/
pathogen
(
e.
g.
hot
water
dips,
etc.),
etc.

13.
If
certification
isn't
mandated
by
law
or
regulation,
is
it
used
as
a
quality
standard
demanded
or
expected
in
order
to
market
the
crop?
Why
can't
MB
alternatives
be
used
to
meet
the
quality
standard?

14.
What
are
the
consequences
of
not
meeting
the
quality
standard?
For
example,
inability
to
sell
crop,
lower
price
for
crop,
etc.

US
Tomatoes
1.
Please
discuss
the
suitability
of
1,3­
D
+
Pic
injected
in
areas
where
field
topography
make
it
difficult
to
use
drip
application
2.
Please
discuss
the
potential
for
using
reduced
dosage
of
1,3­
D
+
Pic
+
VIF
and/
or
solarization
as
an
alternative
to
MB?
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
3.
Combination
of
fumigants
and
herbicides
are
reported
as
a
promising
alternative
but
no
clear
data
(
total
area,
costs,
etc.)
are
given.
Please
specify?

4.
VIF
testing
goes
back
to
2003.
Is
the
final
data
available
yet?
What
are
the
constraints
to
much
wider
use
of
VIF,
combined
with
MB
and
other
fumigants
as
1,3­
D
and
Pic,
where
applicable
combined
with
solarization.

US
TURF
1.
The
CUN
notes
that
primary
MB
alternatives
for
sod
production
are
metham
sodium
and
dazomet,
often
in
combination
with
chloropicrin
and
in
some
cases,
depending
on
pests,
1,3­
D
(
CUN
page
7).
The
CUN
also
states
that
"
dazomet
and
metham
sodium
with
chloropicrin
have
looked
as
good
(
statistically)
and
nearly
as
good
(
numerically)
in
control
of
nutsedge
and
weedy
grasses
as
MB
at
the
high
use
rates
for
turf
(
560
kg/
ha)
(
e.
g.
Unruh
and
Brecke,
2001;
Unruh
et
al.,
2002)"
(
page
9).
It
is
noted
that
barrier
sheets
can
also
increase
the
efficacy
of
metham.
The
CUN
states
in
several
places
it
is
unable
to
determine
yield
or
quality
loss
resulting
from
alternatives
"
since
research
shows
variability
even
among
MB
treatments,
depending
on
location
of
trials
and
pest
type"
(
page
13).
However,
the
BUNI
takes
account
only
of
dazomet
(
alone).
It
would
be
appropriate
to
revise
the
BUNI
to
take
account
of
the
leading
alternatives
for
this
sector.

2.
Q2.
The
use
of
improved
application
methods
for
metham
and
dazomet
are
important,
as
noted
in
the
CUN.
Improved
equipment
for
the
application
of
dazomet
for
turf.
Improved
equipment
for
more
uniform
distribution
of
metham
sodium
is
being
used
in
Europe,
South
America
and
Africa
(
eg.
rotating­
spading
injection
equipment);
and
for
dazomet
in
Europe.
Has
similar
equipment
that
provides
a
uniform
distribution
in
soil,
been
examined
or
used
in
the
USA
for
turfgrass?

3.
Q3.
For
each
state
(
California,
Florida,
Georgia,
Alabama
and
Texas)
please
specify
the
key
target
pest
species
for
which
alternatives
are
considered
not
available,
and
the
precise
reasons
for
the
CUN.

4.
Q4.
Table
14.1:
The
section
pre
or
post
emergent
herbicides
refers
the
reader
to
item
13.
However,
Item
13
does
not
appear
to
provide
any
discussion
on
herbicides.
Please
provide
information
about
pre
and
post
emergent
about
herbicides.

CERTIFIED
SOD
5.
Do
the
sod
certification
standards
in
the
main
CUN
states
(
California,
Florida,
Georgia,
Alabama
and
Texas)
specifically
require
MB
fumigation
as
a
condition
of
certification?
If
the
certification
standards
for
these
states
have
not
been
sent
to
MBTOC
previously,
please
provide
copies.

INDUSTRY
STRUCTURE
6.
How
many
fumigation
companies
provide
MB
as
a
service
to
the
turf
producers
in
the
CUN?
Do
the
current
metham
sodium
users
apply
metham
themselves,
or
do
they
use
a
fumigation
company?
Approximately
how
many
growers/
turf
producers
are
covered
by
this
CUN?

MINIMIZING
MB
USE
AND
EMISSIONS
7.
This
sector
appears
to
have
made
little
or
no
progress
in
minimizing
MB
use
and
emissions,
in
contrast
with
some
other
sectors/
countries.
The
turf
sector
wishes
to
continue
using
MB:
Pic
98:
2
in
2007
(
Table
8.1
page
8).
The
sector
wants
to
use
a
high
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
dose
of
MB
(
480
kg/
ha)
which
is
similar
to
the
rate
used
in
1998
(
488
kg/
ha).
We
note
that
the
EPA
has
reduced
the
nominated
dose
to
300
kg/
ha.
Is
it
technically
feasible
to
make
further
reductions
prior
to
or
during
2007?
If
so,
please
provide
details.
8.
Barrier
films
have
not
been
adopted.
The
CUN
mentions
that
the
requesting
consortia
identified
future
plans
for
examining
high
density
polyethylene
to
reduce
MB
emissions
(
page
15),
however
the
CUN
does
not
provide
any
timelines
for
introduction
of
barrier
films.

ECONOMIC
IMPACT
9.
The
economic
assessment
compares
MB
with
dazomet
only.
This
is
surprising
because
research
information
in
the
CUN
indicates
that
metham
sodium
+
chloropicrin
(+
PV
tarp)
is
a
leading
alternative.
Please
provide
economic
data
for
this
alternative
combination,
and
all
other
leading
combinations.

10.
Please
provide
the
current
cost
of
MB
(
US$/
ha)
in
2005,
and
indicate
expected
price
trends
for
2007.

ACTIONS
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
11.
The
CUN
does
not
provide
information
on
what
actions
will
be
taken
to
rapidly
develop
and
deploy
alternatives.
Please
provide
this
information
and
timeline.

Sod
Production
Please
respond
to
these
questions
for
the
sod
production
remaining
in
the
nomination
after
subtractions
were
made
for
use
rate
and
growth
adjustments.

Certification
Questions
1.
Is
100%
of
this
nomination
is
for
certified
propagative
material?

2.
Is
participation
in
the
certification
program
mandatory
or
voluntary?

3.
Are
the
requirements
of
the
certification
program
specified
in
local,
regional,
or
national
regulations?

4.
Is
the
certification
required
to
export
the
sod?

5.
What
are
the
certification
standards?
For
example,
must
be
free
of
specific
pests
or
pathogens,
must
be
free
of
all
pests
and
pathogens,
plant
must
be
of
a
certain
size,
etc.

6.
Is
the
use
of
methyl
bromide
mandated
for
certification?
Is
a
minimum
rate
of
methyl
bromide
specified?

7.
Are
there
soil
disinfestation
measures
other
than
MB
that
are
approved
for
certification
either
for
specific
growing
conditions
or
broadly
for
many
growing
conditions?
Why
can't
these
be
used
in
the
circumstances
of
the
nomination?

8.
Please
provide
data
demonstrating
that
MB
results
in
pest/
pathogen­
free
sod.

9.
Please
provide
data
showing
that
MB
alternatives
either
can
or
cannot
meet
pathogen/
pestfree
level
required
for
certification
by
providing
data
comparing
pest/
pathogen
populations
on
propagative
materials
grown
in
1)
soil
treated
with
methyl
bromide,
2)
untreated
soil,
3)
1,3­
D
and
chloropicrin
alone
and
in
combination,
4)
metham
sodium/
dazomet,
and
5)
other
relevant
alternatives.
While
plant
growth
data
are
useful,
they
do
not
substitute
for
pest/
pathogen
data
if
the
certification
requirement
is
for
pest/
pathogen­
free
propagative
material.
SECRETARIAT
FOR
THE
VIENNA
CONVENTION
AND
ITS
MONTREAL
PROTOCOL
 
THE
OZONE
SECRETARIAT
P.
O.
Box
30552,
Nairobi,
Kenya
 
Tel:
[+
254
20]
623851 
Fax:
[+
254
20]
624691
/
624692
/
624693
Email:
ozoneinfo@
unep.
org
 
Http://
www.
unep.
org/
ozone
10.
What
are
the
consequences
of
not
meeting
the
pest/
pathogen­
free
standards?
For
example,
sod
cannot
be
sold,
material
can
be
sold
as
lower
quality/
lower
price,
propagative
materials
must
be
treated
before
selling
to
kill
pest/
pathogen
(
e.
g.
hot
water
dips,
etc.),
etc.

11.
If
certification
isn't
mandated
by
law
or
regulation,
is
it
used
as
a
quality
standard
demanded
or
expected
in
order
to
market
the
crop?
Why
can't
MB
alternatives
be
used
to
meet
the
quality
standard?

12.
What
are
the
consequences
of
not
meeting
the
quality
standard?
For
example,
inability
to
sell
crop,
lower
price
for
crop,
etc.

General
Questions
13.
The
Amount
of
Nomination
(
76,112
kg)
shown
in
Table
A1
of
the
Executive
Summary
does
not
appear
to
include
the
1,928
kg
shown
for
research
in
the
BUNI.
Other
U.
S.
CUNs
have
included
the
research
amount
in
the
amount
shown
in
the
Executive
Summary
table.
Is
the
nominated
amount
76,112
kg
or
76,112+
1,928
kg
=
78,040
kg?

14.
Are
halosulfuron
or
trifloxysulfuron
registered
for
use
to
control
nutsedge
or
other
weeds
in
sod
production?
If
not,
will
the
products
be
registered
in
the
future?

15.
The
rate
of
48
g/
m
2
of
methyl
bromide
is
higher
than
that
required
by
several
other
certified
nursery
uses
of
methyl
bromide.
What
circumstances
of
the
sod
production
represented
in
this
CUN
require
the
high
rate
of
methyl
bromide?
Please
present
data
showing
that
lower
rates
are
not
sufficient.

16.
Can
a
formulation
with
a
higher
rate
of
chloropicrin
be
used
for
some
or
all
of
the
circumstances
of
this
nomination,
i.
e.,
instead
of
98:
2,
use
70:
30
methyl
bromide:
chloropicrin?

17.
The
BUNI
includes
some
columns
not
present
in
some
of
the
other
U.
S.
nominations,
and
not
explained
in
the
attached
footnotes.
Please
explain
what
the
"%
adopt"
under
the
heading
"%
Adopt
New
Fumigants"
means.
Please
describe
how
the
value
for
"%
per
year"
under
"%
Adopt
New
Fumigants"
was
reached.
