Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Strawberries Grown for Fruit in Open Fields

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 Strawberries Grown for Fruit in
Open Fields (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:	  HYPERLINK "mailto:ThompsonJE2@state.gov" 
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:







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

Paper Documents:

Title of Paper Documents and Appendices	Number of Pages	Date Sent to
Ozone Secretariat



















electronic copies of all paper documents: 

Title of Electronic Files	Size of File (kb)	Date Sent to Ozone
Secretariat



















Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc94707780"  Part A: Summary	  PAGEREF
_Toc94707780 \h  7  

  HYPERLINK \l "_Toc94707781"  1. Nominating Party	  PAGEREF
_Toc94707781 \h  7  

  HYPERLINK \l "_Toc94707782"  2. Descriptive Title of Nomination	 
PAGEREF _Toc94707782 \h  7  

  HYPERLINK \l "_Toc94707783"  3. Crop and Summary of Crop System	 
PAGEREF _Toc94707783 \h  7  

  HYPERLINK \l "_Toc94707784"  4. Methyl Bromide Nominated	  PAGEREF
_Toc94707784 \h  8  

  HYPERLINK \l "_Toc94707785"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc94707785 \h  8  

  HYPERLINK \l "_Toc94707786"  6. Summarize Why Key Alternatives Are Not
Feasible	  PAGEREF _Toc94707786 \h  9  

  HYPERLINK \l "_Toc94707787"  7. Proportion of Crops Grown Using Methyl
Bromide	  PAGEREF _Toc94707787 \h  9  

  HYPERLINK \l "_Toc94707788"  8. Amount of Methyl Bromide Requested for
Critical Use	  PAGEREF _Toc94707788 \h  11  

  HYPERLINK \l "_Toc94707789"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc94707789 \h  12  

  HYPERLINK \l "_Toc94707790"  California - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc94707790 \h  13  

  HYPERLINK \l "_Toc94707791"  California - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc94707791 \h  13  

  HYPERLINK \l "_Toc94707792"  California - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc94707792 \h  13  

  HYPERLINK \l "_Toc94707793"  California - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc94707793 \h  15  

  HYPERLINK \l "_Toc94707794"  California - Part C: Technical Validation
  PAGEREF _Toc94707794 \h  16  

  HYPERLINK \l "_Toc94707795"  California - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc94707795 \h  16  

  HYPERLINK \l "_Toc94707796"  California - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide	  PAGEREF
_Toc94707796 \h  19  

  HYPERLINK \l "_Toc94707797"  California - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc94707797 \h  20  

  HYPERLINK \l "_Toc94707798"  California - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested	
 PAGEREF _Toc94707798 \h  21  

  HYPERLINK \l "_Toc94707799"  California - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc94707799 \h  24  

  HYPERLINK \l "_Toc94707800"  California - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc94707800 \h  25  

  HYPERLINK \l "_Toc94707801"  California - Summary of Technical
Feasibility	  PAGEREF _Toc94707801 \h  25  

  HYPERLINK \l "_Toc94707802"  Eastern US - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc94707802 \h  26  

  HYPERLINK \l "_Toc94707803"  Eastern US - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc94707803 \h  26  

  HYPERLINK \l "_Toc94707804"  Eastern US - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc94707804 \h  26  

  HYPERLINK \l "_Toc94707805"  Eastern US - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc94707805 \h  28  

  HYPERLINK \l "_Toc94707806"  Eastern US - Part C: Technical Validation
  PAGEREF _Toc94707806 \h  29  

  HYPERLINK \l "_Toc94707807"  Eastern US - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc94707807 \h  29  

  HYPERLINK \l "_Toc94707808"  Eastern US - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc94707808 \h  32  

  HYPERLINK \l "_Toc94707809"  Eastern US - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc94707809 \h  32  

  HYPERLINK \l "_Toc94707810"  Eastern US - 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	
 PAGEREF _Toc94707810 \h  33  

  HYPERLINK \l "_Toc94707811"  Eastern US - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc94707811 \h  34  

  HYPERLINK \l "_Toc94707812"  Eastern US - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc94707812 \h  34  

  HYPERLINK \l "_Toc94707813"  Eastern US - Summary of Technical
Feasibility	  PAGEREF _Toc94707813 \h  35  

  HYPERLINK \l "_Toc94707814"  Florida - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc94707814 \h  36  

  HYPERLINK \l "_Toc94707815"  Florida - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request	
 PAGEREF _Toc94707815 \h  36  

  HYPERLINK \l "_Toc94707816"  Florida - 11. Characteristics of Cropping
System and Climate	  PAGEREF _Toc94707816 \h  37  

  HYPERLINK \l "_Toc94707817"  Florida - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc94707817 \h  38  

  HYPERLINK \l "_Toc94707818"  Florida - Part C: Technical Validation	 
PAGEREF _Toc94707818 \h  39  

  HYPERLINK \l "_Toc94707819"  Florida - 13. Reason for Alternatives Not
Being Feasible	  PAGEREF _Toc94707819 \h  39  

  HYPERLINK \l "_Toc94707820"  Florida - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc94707820 \h  42  

  HYPERLINK \l "_Toc94707821"  Florida - 15. List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc94707821 \h  42  

  HYPERLINK \l "_Toc94707822"  Florida - 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	
 PAGEREF _Toc94707822 \h  43  

  HYPERLINK \l "_Toc94707823"  Florida - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc94707823 \h  44  

  HYPERLINK \l "_Toc94707824"  Florida - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc94707824 \h  45  

  HYPERLINK \l "_Toc94707825"  Florida - Summary of Technical
Feasibility	  PAGEREF _Toc94707825 \h  45  

  HYPERLINK \l "_Toc94707826"  Part D: Emission Control	  PAGEREF
_Toc94707826 \h  46  

  HYPERLINK \l "_Toc94707827"  19. Techniques That Have and Will Be Used
to Minimize Methyl Bromide Use and Emissions in the Particular Use	 
PAGEREF _Toc94707827 \h  46  

  HYPERLINK \l "_Toc94707828"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc94707828 \h  48  

  HYPERLINK \l "_Toc94707829"  Part E: Economic Assessment	  PAGEREF
_Toc94707829 \h  49  

  HYPERLINK \l "_Toc94707830"  21. Operating Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc94707830 \h 
49  

  HYPERLINK \l "_Toc94707831"  22. Gross and Net Revenue	  PAGEREF
_Toc94707831 \h  50  

  HYPERLINK \l "_Toc94707832"  Summary of Economic Feasibility	  PAGEREF
_Toc94707832 \h  51  

  HYPERLINK \l "_Toc94707833"  Part F. Future Plans	  PAGEREF
_Toc94707833 \h  55  

  HYPERLINK \l "_Toc94707834"  23. What Actions Will Be Taken to Rapidly
Develop and Deploy Alternatives for This Crop?	  PAGEREF _Toc94707834 \h
 55  

  HYPERLINK \l "_Toc94707835"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc94707835 \h  57  

  HYPERLINK \l "_Toc94707836"  25. Additional Comments on the Nomination
  PAGEREF _Toc94707836 \h  59  

  HYPERLINK \l "_Toc94707837"  26. Citations	  PAGEREF _Toc94707837 \h 
59  

  HYPERLINK \l "_Toc94707838"  APPENDIX A.  2007 Methyl Bromide Usage
Numerical Index (BUNI).	  PAGEREF _Toc94707838 \h  65  

  HYPERLINK \l "_Toc94707839"  APPENDIX B.  Transitional Issues for
Strawberry growers in Northern California	  PAGEREF _Toc94707839 \h  69 


  HYPERLINK \l "_Toc94707840"  APPENDIX C.  2006 Methyl Bromide
Reconsideration for Strawberry Fruit.	  PAGEREF _Toc94707840 \h  71  

  HYPERLINK \l "_Toc94707841"  Citations Reviewed but Not Applicable	 
PAGEREF _Toc94707841 \h  87  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc94343707"  Part A:
Summary	  PAGEREF _Toc94343707 \h  7  

  HYPERLINK \l "_Toc94343708"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc94343708 \h  8  

  HYPERLINK \l "_Toc94343709"  Table A.1: Executive Summary	  PAGEREF
_Toc94343709 \h  9  

  HYPERLINK \l "_Toc94343710"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc94343710 \h  9  

  HYPERLINK \l "_Toc94343711"  California - Table 8.1: Amount of Methyl
Bromide Requested for Critical Use	  PAGEREF _Toc94343711 \h  11  

  HYPERLINK \l "_Toc94343712"  Eastern US - Table 8.2: Amount of Methyl
Bromide Requested for Critical Use	  PAGEREF _Toc94343712 \h  11  

  HYPERLINK \l "_Toc94343713"  Florida - Table 8.3: Amount of Methyl
Bromide Requested for Critical Use	  PAGEREF _Toc94343713 \h  11  

  HYPERLINK \l "_Toc94343714"  California - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc94343714 \h  13  

  HYPERLINK \l "_Toc94343715"  California - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc94343715 \h 
13  

  HYPERLINK \l "_Toc94343716"  California - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc94343716 \h  13  

  HYPERLINK \l "_Toc94343717"  California - Table 11.2 Characteristics
of Climate and Crop Schedule	  PAGEREF _Toc94343717 \h  14  

  HYPERLINK \l "_Toc94343718"  California - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc94343718 \h  15  

  HYPERLINK \l "_Toc94343719"  California - Part C: Technical Validation
  PAGEREF _Toc94343719 \h  16  

  HYPERLINK \l "_Toc94343720"  California – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc94343720 \h  16  

  HYPERLINK \l "_Toc94343721"  California – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc94343721 \h  19  

  HYPERLINK \l "_Toc94343722"  California – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc94343722 \h  20  

  HYPERLINK \l "_Toc94343723"  California – Table 16.1: Effectiveness
of Alternatives – Key Pest 1	  PAGEREF _Toc94343723 \h  21  

  HYPERLINK \l "_Toc94343724"  Table 16.2.  Effects of Soil Fumigation
with Methyl Bromide/Chloropicrin (MB/CP) vs.
Dichloropropene/Chloropicrin (DP/CP) on Yields (grams/plant) of
Strawberry in 10 Studies	  PAGEREF _Toc94343724 \h  23  

  HYPERLINK \l "_Toc94343725"  California – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc94343725 \h  23  

  HYPERLINK \l "_Toc94343726"  Eastern US - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc94343726 \h  26  

  HYPERLINK \l "_Toc94343727"  Eastern US - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc94343727 \h 
26  

  HYPERLINK \l "_Toc94343728"  Eastern US - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc94343728 \h  26  

  HYPERLINK \l "_Toc94343729"  Eastern US - Table 11.2 Characteristics
of Climate and Crop Schedule	  PAGEREF _Toc94343729 \h  27  

  HYPERLINK \l "_Toc94343730"  Eastern US - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc94343730 \h  28  

  HYPERLINK \l "_Toc94343731"  Eastern US - Part C: Technical Validation
  PAGEREF _Toc94343731 \h  29  

  HYPERLINK \l "_Toc94343732"  Eastern US – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc94343732 \h  32  

  HYPERLINK \l "_Toc94343733"  Eastern US – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc94343733 \h  32  

  HYPERLINK \l "_Toc94343734"  Eastern US – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc94343734 \h  33  

  HYPERLINK \l "_Toc94343735"  Florida - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc94343735 \h  36  

  HYPERLINK \l "_Toc94343736"  Florida - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc94343736 \h 
36  

  HYPERLINK \l "_Toc94343737"  Florida - Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc94343737 \h  37  

  HYPERLINK \l "_Toc94343738"  Florida - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc94343738 \h  37  

  HYPERLINK \l "_Toc94343739"  Florida - Table 12.1 Historic Pattern of
Use of Methyl Bromide	  PAGEREF _Toc94343739 \h  38  

  HYPERLINK \l "_Toc94343740"  Florida - Part C: Technical Validation	 
PAGEREF _Toc94343740 \h  39  

  HYPERLINK \l "_Toc94343741"  Florida – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc94343741 \h  42  

  HYPERLINK \l "_Toc94343742"  Florida – Table C.1: Alternatives Yield
Loss Data Summary	  PAGEREF _Toc94343742 \h  43  

  HYPERLINK \l "_Toc94343743"  Part D: Emission Control	  PAGEREF
_Toc94343743 \h  46  

  HYPERLINK \l "_Toc94343744"  Table 19.1: Techniques to Minimize Methyl
Bromide Use and Emissions	  PAGEREF _Toc94343744 \h  46  

  HYPERLINK \l "_Toc94343745"  Part E: Economic Assessment	  PAGEREF
_Toc94343745 \h  49  

  HYPERLINK \l "_Toc94343746"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc94343746 \h 
49  

  HYPERLINK \l "_Toc94343747"  Table 22.1: Year 1 Gross and Net Revenue	
 PAGEREF _Toc94343747 \h  49  

  HYPERLINK \l "_Toc94343748"  Table 22.2: Year 2 Gross and Net Revenue	
 PAGEREF _Toc94343748 \h  49  

  HYPERLINK \l "_Toc94343749"  Table 22.3: Year 3 Gross and Net Revenue	
 PAGEREF _Toc94343749 \h  50  

  HYPERLINK \l "_Toc94343750"  California - Table E.1: Economic Impacts
of Methyl Bromide Alternatives	  PAGEREF _Toc94343750 \h  51  

  HYPERLINK \l "_Toc94343751"  Eastern US - Table E.2: Economic Impacts
of Methyl Bromide Alternatives	  PAGEREF _Toc94343751 \h  51  

  HYPERLINK \l "_Toc94343752"  Florida - Table E.3: Economic Impacts of
Methyl Bromide Alternatives	  PAGEREF _Toc94343752 \h  52  

  HYPERLINK \l "_Toc94343753"  Part F. Future Plans	  PAGEREF
_Toc94343753 \h  56  

  HYPERLINK \l "_Toc94343754"  APPENDIX A.  2007 Methyl Bromide Usage
Numerical Index (BUNI).	  PAGEREF _Toc94343754 \h  66  

 

Part A: Summary  TC "Part A: Summary" \f F \l "1"    TC "Part A:
Summary" \f C \l "1"  



1. Nominating Party  TC "1. Nominating Party" \f C \l "2"  



The United States of America (U.S.)



2. Descriptive Title of Nomination  TC "2. Descriptive Title of
Nomination" \f C \l "2"  



Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Strawberries Grown for Fruit in Open Fields (Prepared in 2005)



3. Crop and Summary of Crop System  TC "3. Crop and Summary of Crop
System" \f C \l "2"  



This nomination covers methyl bromide (MB) use in three major strawberry
production areas—California, Florida, and states in the eastern U.S.
(Alabama, Arkansas, Georgia, Illinois, Kentucky, Louisiana, Maryland,
New Jersey, North Carolina, Ohio, South Carolina, Tennessee, West
Virginia and Virginia).  

California.  California produces more than 85% of the fresh market and
processed strawberries grown in the U.S.  California produces about 20%
of the world’s strawberries.  Most strawberries exported from
California go to Canada, Japan, and Mexico.  

California has two distinct strawberry production areas.  The southern
region produces both fresh (63%) and processed (37%) strawberries.  The
northern region includes both rotated and non-rotated strawberry
production regimes, with each producing fresh (84%) and processed (16%)
strawberries.  The majority of growers are farming between four and 20
hectares of land with strawberry fields in rotation.  Because strawberry
production in California is concentrated in a small geographic location
due to optimal growing conditions, factors that affect this small area
can be significant.  An example of this, which is discussed later in
this chapter, is the regulatory limit on the amount of
1,3-dichloropropene (1,3-D) that can be used in each township (i.e., 36
square mile area, approximately 95 square km) in California.

Depending on the region, California strawberries are planted in the
summer (southern California) or fall (northern and southern California).
 Prior to planting, fumigation is typically performed on flat ground
over the entire surface of the field.  Immediately after fumigation the
field is covered with plastic.  At the end of the fumigation period, the
plastic is removed and planting beds are formed and covered with fresh
plastic.  Strawberry plants are transplanted about two to six weeks
after fumigation to ensure that there are no phytotoxic levels of
fumigant remaining.  Harvest begins about two to four months later.  At
the end of the first harvest, the strawberry plants are removed and the
field is readied for the next crop.  Rotational crops that are planted
after strawberries, and that benefit from the previous fumigation,
include broccoli, celery, lettuce, radish, leeks, and artichokes. 

Florida.  Florida is the second largest strawberry producing state with
12% of the total U.S. production.  All of Florida’s production is for
fresh market.  Nearly all of the domestically produced strawberries
harvested in the winter are grown in Florida.  Strawberries are grown as
an annual crop in Florida using a raised-bed system.  Typically, MB in
combination with chloropicrin is applied to the soil during construction
of raised-beds, approximately two weeks prior to planting transplants. 
Immediately after application, beds are covered with plastic mulch. 
Drip and overhead irrigation are used to help establish plants, irrigate
plants, and protect plants from frost.  Many strawberry growers use the
existing beds and drip tubes to grow a second crop, such as cucurbits or
solanaceous crops.

Eastern U.S.  The eastern U.S. strawberry industry is highly
de-centralized and primarily consists of small family farms that
directly market strawberries through “U-pick”, “ready-pick”,
roadside stands, and farmers markets.

Strawberry production in the eastern states differs from that in Florida
because of soils type (Florida typically has sandy soils; eastern soils
are heavier); topography (Florida has much karst geology; much less
common in other states), climate (very mild winters in Florida), farm
size (farms are larger in Florida), and marketing practices (Florida is
typically commercial compared to small U-pick operations).  In the
eastern U.S. the majority of the strawberry farms use an annual cropping
plasticulture production system where the berries are grown on raised
beds similar to Florida strawberry production.  Planting time is similar
to Florida but the production peak occurs later in the season, between
April and May.  About 50% of the soils have textures finer than sandy
loam.  Nutsedge is a primary pest on about 40% of the land that
typically has coarse-textured soils.  Some double cropping of beds
occurs.

4. Methyl Bromide Nominated  TC "4. Methyl Bromide Nominated" \f C \l
"2"  



Table 4.1: Methyl Bromide Nominated  TC "Table 4.1: Methyl Bromide
Nominated" \f F \l "1"  

Year	Nomination Amount (kg)*	Nomination Area (ha)

2007	1,733,901	9,780

* Includes research amount of 2,377 kgs.

5. Brief Summary of the Need for Methyl Bromide as a Critical Use  TC
"5. Brief Summary of the Need for Methyl Bromide as a Critical Use" \f C
\l "2"  



The U.S. nomination for critical use of MB, for 2007, is only for those
areas where the alternatives are not suitable, such as constraints due
to regulatory, topographical, geological, or soil conditions.  U.S.
strawberry fruit production will still require MB for 2007, and most
likely until protocols are developed from research conducted over
several seasons that will provide commercial producers with reliable and
economically feasible alternatives.  However, the nomination notes
significant progress in adopting emission reduction technologies and
changing formulations and application rates to reduce MB dosage rates. 
Research is ongoing to evaluate new alternatives, and to test
impermeable films.  Constraints on use of alternatives, for 2007,
include:

In areas with heavy pest pressure, the protocols for use of alternatives
may not be sufficiently developed, based on research studies, to risk
current crop.

Alternative treatments may be comparable to MB when there is little
pressure from key pests.  However, the U.S. is only nominating a CUE for
strawberry fruit where the key pest pressure is moderate to high, such
as nutsedge in the eastern U.S.

Regulatory constraints: e.g., 1,3-D and virtually impermeable film use
is limited in California due to regulations, and in Florida, 1,3-D use
is not allowed in areas with karst geology.

Delay in planting and harvesting: e.g., the plant-back interval for
1,3-D + chloropicrin may be two weeks longer than MB + chloropicrin.  In
these cases, delays in planting and harvesting will result in users
missing key market windows resulting in reduction in revenues due to
lower prices.

Unsuitable topography: e.g., alternatives that must be applied with drip
irrigation may not be suitable in areas with rolling or sloped
topography due to uneven distribution of the fumigant; broadcast
fumigation can be impacted by restrictions on 1,3-D.

Table A.1: Executive Summary  TC "Table A.1: Executive Summary" \f F \l
"1"  

Region	California	Eastern U.S.	Florida

Amount of Applicant Request 

	2007	Kilograms	1,451,494	359,841	579,691

Amount of Nomination*

	2007	Kilograms	1,267,880	165,735	297,909

*See Appendix A for a complete description of how the nominated amount
was calculated.

6. Summarize Why Key Alternatives Are Not Feasible  TC "6. Summarize Why
Key Alternatives Are Not Feasible" \f C \l "2"  :



Only areas with moderate to high pest pressure are included in this
nomination for critical use of MB.  In several areas MB alternatives
have already been incorporated into strawberry production systems. 
However, in areas where alternatives have not been shown to sufficiently
manage major pests economically, MB currently is considered to be the
most reliable treatment.  MB is used in strawberry production for
managing nutsedges and other weeds, nematodes, and pathogens.  Some
major reasons that MB will continue to be a critical treatment for 2007,
are lack of precise protocols for combination treatments (e.g., 1,3-D,
chloropicrin, metam-sodium, etc.) that can be applied to commercial
operations, physical or regulatory limitations to some important
treatments (e.g., 1,3-D, virtually impermeable film), increased costs
for some alternative methods, and market issues due to change in crop
rotation and time of planting/harvesting.  

7. (i) Proportion of Crops Grown Using Methyl Bromide  TC "7.
Proportion of Crops Grown Using Methyl Bromide" \f C \l "2"    



Table 7.1: Proportion of Crops Grown Using Methyl Bromide  TC "Table
7.1: Proportion of Crops Grown Using Methyl Bromide" \f F \l "1"  

Region where Methyl Bromide use is requested	Total crop area 

2001 & 2002 Average

(ha)	Proportion of total crop area treated with methyl bromide 

(%)

California	11,109 ha

(NASS*, 2002 for CA= 11,538 ha)	74%

(NASS*, 2002 for CA=55% treated w/MB)

Eastern U.S.	Not available for region 

(NASS*, 2000 for NC= 729 ha)	Not available for region 

(region estimate, 80%; Ferguson et al., 2003)

(NASS*, 2000 for NC=35% treated w/MB)

Florida	2,873

(NASS*, 2002 for FL= 2,794 ha)	94

(NASS*, 2002 for FL=100% treated w/MB)

National Total**:	19,486	65

* National Agricultural Statistics Service, U.S. Department of
Agriculture, 2002 Vegetable Crops Report

** National total includes other regions not requesting methyl bromide.

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.



Strawberry producers in the three areas where MB is being requested are
faced with different pest problems.  In the eastern U.S., other than
Florida, the generally small-scale farmers contend with yellow and
purple nutsedges, which are significant problems in some areas more than
others.  Those that are faced with a lower incidence of nutsedge may be
able to use other chemicals, chloropicrin, 1,3-D, and metam-sodium, for
example, whereas these treatments may not be effective in areas with
severe infestations.  In Florida, a significant portion of production
areas sits above karst geological formations, which proscribes the use
of 1,3-D because of ground water contamination.  In California, some
areas are prevented from using 1,3-D, because of township caps.  These
areas rely on MB as a critical tool for successful strawberry
production.  In California, hilly fields impact the application of some
alternatives (e.g., drip application of 1,3-D).

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?



Researchers have been testing MB alternatives and are committed to
finding effective replacements for MB.  Research trials continue to be
conducted each season to assess feasibility and consistency of results. 
Research suggests that there may be some good alternatives on the
horizon (e.g., Fennimore et al., 2003, 2004; Ajwa et al., 2003a, 2003b,
2004; Browne et al., 2003; Duniway et al., 2003; Ajwa and Trout, 2004;
Trout and Damodaran, 2004; Noling and Gilreath, 2004; Hamill et al.,
2004; Sydorovych et al., 2004).  However, additional research will be
required to develop protocols and resolve problems (e.g., application
methods for VIF, cost concerns).  California researchers are examining
the use of various high barrier films to address efficacy and cost
issues.  VIF manufacturers believe that physical problems associated
with applying VIF can be fixed in the near future (Rimini and Wigley,
2004), but California has restrictions on use of VIF, as well as 1,3-D.

8. Amount of Methyl Bromide Requested for Critical Use  TC "8. Amount of
Methyl Bromide Requested for Critical Use" \f C \l "2"   



California - Table 8.1: Amount of Methyl Bromide Requested for Critical
Use  TC "California - Table 8.1: Amount of Methyl Bromide Requested for
Critical Use" \f F \l "1"  

Region: California	California

Year of Exemption Request	2007

Kilograms of Methyl Bromide	1,451,520

Use: Flat Fumigation or Strip/Bed Treatment	Flat Fumigation

Formulation (ratio of methyl bromide/chloropicrin mixture) to be used
for the CUE	67:33

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	8,097

Application rate* (kg/ha) for the active ingredient	179

Dosage rate* (g/m2)  of active ingredient used to calculate requested
kilograms of methyl bromide	17.9

* For Flat Fumigation treatment application rate and dosage rate may be
the same.

Eastern US - Table 8.2: Amount of Methyl Bromide Requested for Critical
Use  TC "Eastern US - Table 8.2: Amount of Methyl Bromide Requested for
Critical Use" \f F \l "1"   

Region:  EASTERN UNITED States	Eastern U. S.

Year of Exemption Request	2007

Kilograms of Methyl Bromide	359,847

Use: Flat Fumigation or Strip/Bed Treatment	Bed

Formulation (ratio of methyl bromide/Chloropicrin mixture) to be used
for the CUE	67:33

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	2,378

Application rate* (kg/ha) for the active ingredient	151

Dosage rate* (g/m2)  of active ingredient used to calculate requested
kilograms of methyl bromide	15.1

* For Flat Fumigation treatment application rate and dosage rate may be
the same.

Florida - Table 8.3: Amount of Methyl Bromide Requested for Critical Use
 TC "Florida - Table 8.3: Amount of Methyl Bromide Requested for
Critical Use" \f F \l "1"  

Region:  Florida	Florida

Year of Exemption Request	2007

Kilograms of Methyl Bromide	579,691

Use: Flat Fumigation or Strip/Bed Treatment*	Bed

Formulation (ratio of methyl bromide/Chloropicrin mixture) to be used
for the CUE**	98:2

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	2,873

Application rate* (kg/ha) for the active ingredient	202

Dosage rate* (g/m2)  of active ingredient used to calculate requested
kilograms of methyl bromide	14

* A typical strawberry bed in Florida is 71 cm wide and 132 cm from bed
center to center; 54% of the area is treated. 

** Florida growers use a 98:2 formulation for sting nematode control.



9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity
Nominated for Each Region  TC "9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region" \f C \l "2"
 



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.  Values greater than 100% are due to the inclusion of
additional varieties in the applicant’s request that were not included
in the USDA National Agricultural Statistics Service surveys of the
crop.  

Hectares counted in more than one application, or rotated within one
year of an application to a crop that also uses 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.  The three applicants that included growth in their request
had the growth amount removed.  

Quarantine and pre-shipment (QPS) hectares is the area in the
applicant’s request subject to QPS treatments.  QPS was not applicable
in this sector.

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, karst geology, buffer zones, and unsuitable terrain.






 

California - Part B: Crop Characteristics and Methyl Bromide Use  TC
"California - Part B: Crop Characteristics and Methyl Bromide Use" \f F
\l "1"    TC "California - Part B: Crop Characteristics and Methyl
Bromide Use" \f C \l "1"  



California - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request  TC " California - 10.
Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request" \f C \l "2"  



California - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request  TC "California - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide is needed 

California

	Diseases: Black root rot (Rhizoctinia and Pythium spp.), crown rot
(Phytophthora cactorum), 	At moderate to severe pest pressure where MB
is not currently used, protocols for commercial application of
alternatives have not been sufficiently developed to be implemented for
the 2007 season.  Uses of some alternatives are limited by regulatory
restrictions, such as the township caps on 1,3-D.  MB applications in
strawberries are typically made using 67:33 or, where feasible, 57:43
mixtures with chloropicrin under plastic mulch.  If high barrier tarps
becomes available to California growers and technical problems and cost
concerns can be resolved, some research suggests that fumigant rates,
including MB, might be lowered with near efficacy of current rates under
standard films (e.g., Hamill et al., 2004; Noling and Gilreath, 2004;
Ajwa et al., 2004; Fennimore et al., 2004). 

	Nematodes: root knot nematode (Meloidogyne spp.) Sting nematode
(Belonolaimus spp.) 



Weeds:  Yellow nutsedge (Cyperus esculentus), purple nutsedge (Cyperus
rotundus), ryegrass, and winter annual weeds.  

	

California - 11. (i) Characteristics of Cropping System and Climate  TC
" California - 11. Characteristics of Cropping System and Climate" \f C
\l "2"  



California - Table 11.1: Characteristics of Cropping System  TC "
California - Table 11.1: Characteristics of Cropping System" \f F \l "1"
 

Characteristics	California

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Fruiting plants
grown from transplants

Annual or Perennial Crop: (# of years between replanting) 	Cultured as
annual

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	Vegetables (e.g. broccoli, celery, lettuce,
radish, leeks, cauliflower, artichokes)

Soil Types:  (Sand, loam, clay, etc.)	Light and medium soils 

Frequency of methyl bromide Fumigation: 

(e.g. every two years)	Yearly

Other relevant factors:	None identified



California - Table 11.2 Characteristics of Climate and Crop Schedule  TC
" California - Table 11.2 Characteristics of Climate and Crop Schedule"
\f F \l "1"  

	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb	Mar	Apr	May	Jun

Climatic Zone	9 B

Rainfall (mm)	trace	1.0	trace	0	44.7	56.9	9.9	30.5	16	72.1	17.3	0

Outside Temp. ((C)*	30.3	27.4	25.1	18.4	13.4	9.6	10.3	10.6	14.4	14.8
20.8	25.7

Fumigation Schedule

X











Planting  in North**

	X	X	X	X







Planting  in South**	X

X	X









*For Fresno, California.

** In Northern California the crop is planted in the fall and harvested
from December through June/July.  In Northern California rotational crop
planting occurs in October/November and harvesting occurs from April
thru October; average farm size is 24 ha; rotational crops include
lettuce, strawberries, broccoli and cauliflower.  In Southern California
the crop is planted in both the summer and fall.  The rotational crop,
often celery, lettuce, or broccoli, is grown from March thru May. 
Average farm size in this area is about 12 ha, all of which is treated. 


California – 11. (ii) Indicate if any of the above characteristics in
11. (i) prevent the uptake of any relevant alternatives?



It is likely that 1,3-D township caps will limit the further adoption of
1,3-D as an alternative.  It is possible that use can be reduced,
especially in Northern California, by using drip irrigation of
1,3-D—however, move to drip irrigation will result in a 2-3 week delay
in schedule.  This would be significant for growers who plant long day
cultivars such as ‘Diamonte’ (see Appendix B).  Hilly terrain also
impacts the application of 1,3-D.

California - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested 
TC "California - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested"
\f C \l "2"   



California - Table 12.1 Historic Pattern of Use of Methyl Bromide  TC
"California - Table 12.1 Historic Pattern of Use of Methyl Bromide" \f F
\l "1"  

For as many years as possible as shown specify:	1998	1999	2000	2001	2002
2003

Area Treated (hectares)	7,401	8,600	8,248	8,456	7,912	8,249

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	All Flat Fumigation

Amount of methyl bromide active ingredient used 

(total kilograms)	1,928,597	2,264,789	1.919,240	1,611,775	1,592,156
1,651,250

formulations of methyl bromide 	Typically  67:33 (methyl bromide
/chloropicrin)

Method by which methyl bromide applied )	Shank injected 25 to 30 cm deep

Application rate of formulations in kg/ha*	260	275	244	191	201	201

Actual dosage rate of formulations (g/m2)*	26	27.5	24.4	19.1	20.1	20.1

* For Flat Fumigation treatment application rate and dosage rate may be
the same.

California - Part C: Technical Validation  TC "California - Part C:
Technical Validation" \f F \l "1"    TC "California - Part C: Technical
Validation" \f C \l "1"  



California - 13. Reason for Alternatives Not Being Feasible  TC
"California - 13. Reason for Alternatives Not Being Feasible" \f C \l
"2"   



California – Table 13.1: Reason for Alternatives Not Being Feasible 
TC "California – Table 13.1: Reason for Alternatives Not Being
Feasible" \f F \l "1"  

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-Dichloropropene 

(1,3-D)	Used alone, 1,3- D does not adequately control diseases and
weeds.  Buffer zones of 30 m are constraining for small fields. 
Required protective equipment (protective suits) pose a health risk to
workers in hot and humid weather.  Long pre-planting intervals affect
cultivar selection, Integrated Pest Management practices, time of
harvest, marketing window options, land leasing decisions and crop
rotation schedules.  In CA, state regulations require township caps,
which limits use of 1,3-D.  	No

Basamid	Basamid is not registered in the U.S. for strawberry fruit
production.  	

No

Chloropicrin	Chloropicrin alone provides poor nematode and weed control,
although it provides good disease control 	No

Metam sodium	Metam-sodium alone provides inconsistent nematode and weed
control, most likely due to irregular distribution through soil.  	No

Methyl iodide	Not currently registered in the U.S. 	No

Nematicides	Addressed individually (e.g., 1,3-D). 	No

Ozone	Ozone is not technically feasible alone because it doesn’t
control diseases and weeds.  	No

Non Chemical Alternatives

Biofumigation	Biofumigation is not technically feasible because of the
quantity of Brassica crop that would be needed to control target pests
in strawberries (approximately three hectares would be required for
every hectare of strawberry production).  Incorporation of Brassica at
these levels is likely to have allelopathic effects on the target crop. 
In addition, field trials growing tomatoes in cabbage residue produced
inconsistent and inadequate efficacy, and poor yield in two years out of
three trials.  Research is being conducted to determine efficacy against
selected pathogens, nematodes, and weeds (e.g., Daugovish et al, 2003).
No

Solarization	Solarization, when used alone for pre-plant fumigation, is
not technically feasible because it does not provide adequate control of
a wide range of soil-borne diseases and pests.  This process is highly
weather dependent and works best in combination with IPM for control of
pests and diseases.  	No

Steam	Although used successfully in greenhouse situations, fumigation
with steam, when used alone in the field for pre-plant fumigation, is
not operationally practical due to low application speeds and high
energy requirements (1-3 weeks to treat one hectare). 	No

Biological Control	Biological control is not technically feasible as a
stand alone replacement for methyl bromide because it does not provide
adequate control of target pests.  	No

Cover Crops and Mulching	Already in use as part of an Integrated Pest
Management Program, cover crops and mulching alone do not provide
sufficient control of the target pests.  	No

Crop rotation/fallow	Crop rotation is already being used in many
strawberry production areas, but does not adequately control the target
pests.  	No

Flooding and water management	Flooding and water management are not
feasible due to limited water resources, uneven topography in California
and in the eastern states, unsuitable sandy soil types that would not
retain the flood for an adequate time to control the pests.	No

General IPM	General IPM is already practiced in strawberry production,
but it is not technically feasible as a stand-alone replacement for
methyl bromide since a combination of IPM methods do not offer adequate
pest control by itself.  	No

Grafting/Resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding is not being used and it is not technically
feasible because grafting is not possible given the physical
characteristics of strawberry plants.  Breeding for resistance to
pathogens is valuable as a long-term endeavor and the U.S. continues
work in this area (e.g., Duniway et al., 2003).  At this point in time,
plant breeding has not resulted in a cultivar that is sufficiently
resistant to the major target pests.  	No

Organic Amendments/Compost	Organic Amendments/Compost is already being
used in certain regions of the U.S., but is not technically feasible as
a stand-alone replacement for methyl bromide.  	No

Organic production	In certain regions of the U.S. some organic
production of strawberries occurs.  However, as a stand alone
replacement for methyl bromide it is not technically feasible because of
reduced yields.  	No

Resistant cultivars	Resistant cultivars are already being used in
certain regions of the U.S. (e.g., Browne et al., 2003), but it is not
technically feasible as a stand-alone replacement for methyl bromide.  
No

Soil-less culture	Soil-less culture is not being used and it is not
technically feasible because it requires a complete transformation of
the U.S. production system.  There are high costs associated with this
as compared to current production practices.  	No

Substrates/Plug plants	Substrates/plant plugs are currently being used
but are not technically feasible as a stand-alone replacement for methyl
bromide.   Although plug plants can be more vigorous than bare root
transplants in research trials, disease problems can be severe.  One
study found significant contamination with Colletotrichum acutatum as a
result of contaminated nursery stock from Canada and numerous growers
lost entire plantings in several states (Sances, 2003).  These problems
can be overcome (Sances, 2004), but the technology is not ready for
widespread commercial application until further studies are conducted. 
Weed control would still be an issue and adopting this use would also
require major retooling of the industry.    	No

Tarps	Research on virtually impermeable films (e.g., Ajwa et al., 2003a,
2004; Duniway et al., 2003; Fennimore et al., 2003, 2004; Hamill et al.,
2004) shows promise in improving efficacy of chemical fumigants. 
However, CA currently does not allow the use of VIF due to concerns
about worker exposure upon outgassing.  In addition, technical issues of
application feasibility and costs could hamper implementation.	No

Hand-weeding	Hand-weeding not listed as a standard option.  Hand-weeding
strawberries is not a desirable practice for controlling weeds because
they cannot be removed without damaging the plastic and thereby reducing
its effectiveness in excluding weeds, insects, and pathogens.  	No

Combinations of Alternatives

1,3-Dichloropropene/ Chloropicrin	This combination is considered
feasible as an alternative in circumstances where weed pressures are
low.  Together treatment provides good nematicidal and fungicidal
capabilities, but would likely require an herbicide partner to control
weeds such as nutsedge.  Regulatory restrictions for each of the
chemicals may further limit their use.  Ongoing research indicates that
efficacy can be enhanced with use of VIF, but VIF is currently not
allowed in California. 	No, in areas with moderate to severe pest
infestation and if not allowed by local regulations.  

1,3-Dichloropropene/ Chloropicrin and Metam sodium	These combinations
also provide good nematicidal and fungicidal capabilities, but would
likely require an herbicide partner (or hand weeding) to control. 
Regulatory restrictions for each of the chemicals may further limit
their use.	No, in areas with moderate to severe pest infestation and if
not allowed by local regulations.  

Basamid + Chloropicrin	Basamid is not registered in the U.S. for
strawberry fruit production.  	No

* Regulatory reasons include local restrictions (e.g. occupational
health and safety, local environmental regulations) and lack of
registration.

California - 14. List and Discuss Why Registered (and Potential)
Pesticides and Herbicides Are Considered Not Effective as Technical
Alternatives to Methyl Bromide  TC "California - 14. List and Discuss
Why Registered (and Potential) Pesticides and Herbicides Are Considered
Not Effective as Technical Alternatives to Methyl Bromide" \f C \l "2"  



California – Table 14.1: Technically Infeasible Alternatives
Discussion  TC "California – Table 14.1: Technically Infeasible
Alternatives Discussion" \f F \l "1"  

Name of Alternative	Discussion

1,3-Dichloropropene	Township caps restrict the use in California.  Where
available, if used alone 1,3-D is not a sufficiently effective weed or
disease control treatment.  Drip applications of 1,3-D in California,
are less expensive and require smaller buffer zones than broadcast
applications, making it the preferred application method for this
alternative (drip, 90%; broadcast, 10%).  However, when 1,3-D
fumigations by drip are used other production costs are significantly
higher due to the need for herbicide applications (i.e., metam sodium)
and hand weeding operations.  Recent studies in California found that
fruit production costs were 20-212% higher than with methyl
bromide/chloropicrin (Goldhue), with the smaller cost estimates coming
from VIF mulch treatments (not currently available due to regulatory
constraints). 

Chloropicrin	Chloropicrin alone is not a technically feasible
alternative because it provides poor nematode and weed control, although
it provides good disease control 

Metam sodium	Metam-sodium alone is not a technically feasible
alternative because it provides unpredictable disease, nematode, and
weed control.  Metam sodium suffers from erratic efficacy most likely
due to irregular distribution of the product through soil.  Metam sodium
if not technically feasible in California because it has limited
activity against soilborne pathogens in strawberry fields.  

1,3-D/chloropicrin/metam-sodium	This combination is being researched as
a possible alternative treatment to MB in areas where township caps and
label restrictions are not restrictive.  Together they provide good
nematicidal, weed, and fungicidal capabilities.  Research studies are
examining the appropriate rates and water amounts required (Ajwa and
Trout, 2004).  Repeated seasonal trials will be necessary to validate
efficacy.  Research suggests greater efficacy if VIF is used if
regulatory, technological and cost issues are resolved (VIF is not
currently allowed in California)..



California - 15. List Present (and Possible Future) Registration Status
of Any Current and Potential Alternatives  TC "California - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives" \f C \l "2"  :



California – Table 15.1: Present Registration Status of Alternatives 
TC "California – Table 15.1: Present Registration Status of
Alternatives" \f F \l "1"  

Name of Alternative	Present Registration Status	Registration being
considered by national authorities? (Y/N)	Date of possible future
registration:

Basamid	Not registered for use on strawberries.	Yes	Unknown

Methyl Iodide	Not registered in U.S.	Yes	Unknown

Propargyl bromide	Not registered in U.S.	No	Unknown

Furfural	Not registered for use on strawberries.	Unknown	Unknown



California – 16. State Relative Effectiveness of Relevant Alternatives
Compared to Methyl Bromide for the Specific Key Target Pests and Weeds
for which It Is Being Requested  TC "California - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested"
\f C \l "2"   



California – Table 16.1: Effectiveness of Alternatives – Key Pest 1
Yellow Nutsedge  TC "California – Table 16.1: Effectiveness of
Alternatives – Key Pest 1" \f F \l "1"  

Key Pest: Key Pest 1	Average disease % or rating and yields in past 3~5
years

Methyl Bromide formulations and Alternatives 	# of Trials	Actual Yields
(t/ha)	Citation

Control (untreated) [1]

Chloropicrin (drip):  [2] (56 kg/ha)

[3] (112 kg/ha)

[4] (224 kg/ha)

[5] (336 kg/ha)

[6] (448 kg/ha)

1,3-D/Chloropicrin (Inline drip): 

[7] (56 kg/ha)

[8] (112 kg/ha)

[9] (224 kg/ha)

[10] (336 kg/ha)

[11] (448 kg/ha)

MB/Chloropicrin (shank): [12] 392 kg/ha	2 (4 reps each)

(data from Oxnard, CA trial)

	Native weed biomass (kg/ha)

w/VIF

[1] 1350 a

[2] 600 bcdef

[3] 696 bcdef

[4] 957 b

[5] 398 ef

[6] 369 ef

[7] 832 bcde

[8] 537 bcdef

[9] 302 f

[10] 319 f

[11] 334 f

[12] 919 bc

Means within column followed by the same letter do not differ at 0.05
according to Duncan’s multiple range test	Native weed biomass (kg/ha)

w/HDPE

[1] 1435 a

[2] 822 bcde

[3] 658 bcdef

[4] 490 cdef

[5] 391 ef

[6] 520 bcdef

[7] 891 bcd

[8] 694 bcdef

[9] 586 bcdef

[10] 565 bcdef

[11] 427 ef

[12] 440 def

Means within column followed by the same letter do not differ at 0.05
according to Duncan’s multiple range test	Fennimore et al., 2003



Control (untreated) [1]

Chloropicrin (drip):  [2] (56 kg/ha)

[3] (112 kg/ha)

[4] (224 kg/ha)

[5] (336 kg/ha)

[6] (448 kg/ha)

1,3-D/Chloropicrin (Inline drip): 

[7] (56 kg/ha)

[8] (112 kg/ha)

[9] (224 kg/ha)

[10] (336 kg/ha)

[11] (448 kg/ha)

MB/Chloropicrin (shank): [12] 392 kg/ha	3 

(data from Oxnard, CA trial)

[no pests identified]	Strawberry yield (%) relative to MB/Pic treatment

w/VIF

[1] 87

[2] 104

[3] 105

[4] 112

[5] 120

[6] 116

[7] 98

[8] 107

[9] 117

[10] 120

[11] 120

[12] 111

No significant difference between chemical trts; untreated significantly
different from other trts (P=0.05).	Strawberry yield (%) relative to
MB/Pic treatment

w/HDPE

[1] 83

[2] 103

[3] 106

[4] 108

[5] 115

[6] 112

[7] 99

[8] 108

[9] 105

[10] 121

[11] 115

[12] 100 (=44,751 kg/ha)

No significant difference between chemical trts; untreated significantly
different from other trts (P=0.05).	Ajwa et al., 2003a

MBR: Chloropicrin (67:33) 200 lb

Telone: chloropicrin 17.5 gal. drip

Chloropicrin EC 100 lb drip

Metam sodium 35 gal drip	1	lb/A 

14109 

15551

14613

15117

(N.S.)	Ferguson, 2001



MBR: Chloropicrin 390kg/ha

Telone + 35% chloropicrin (327 L)

Telone + 17% chloropicrin (327 L)

Metam sodium (300L)

Metam NA + chloropicrin (300L +170 kg)

Solarization (painted black)

	1 of 2	flats/ha 

4131 (a)

3541 (ab)

3620 (ab)

2552 (bcd)

2199 (cd)

2710 (bcd)	Locascio, 1999



MBR: Chloropicrin 390kg/ha

Telone + 35% chloropicrin (327 L)

Telone + 17% chloropicrin (327 L)

Metam NA + chloropicrin (300L +170 kg)

 Metam sodium (300L)

Solarization (painted black)

	2 of 2	flats/ha

3511 (ab)

3553 (ab)

3333 (ab)

3279 (ab)

2933 (bc)

3210 (b)	Locascio, 1999



California – Table 16.2: Effectiveness of Alternatives – Multiple
Pests

Effects of Soil Fumigation with Methyl Bromide/Chloropicrin (MB/CP) vs.
Dichloropropene/Chloropicrin (DP/CP) on Yields (grams/plant) of
Strawberry in 10 Studies  TC "Table 16.2.  Effects of Soil Fumigation
with Methyl Bromide/Chloropicrin (MB/CP) vs.
Dichloropropene/Chloropicrin (DP/CP) on Yields (grams/plant) of
Strawberry in 10 Studies" \f F \l "1"  



MB:CP treated	DP:CP treated





Study	No Reps.	Mean Yield	SD	Mean Yield	SD	Percent Increasez	ty	py	dy

2	6	992	177	856	109	15.9	1.60	0.070	0.93

5	6	1331	40	1046	55	27.2	10.27	<0.001	5.93

7	5	1096	110	687	62	59.5	6.76	<0.001	4.28

21	6	886	71	914	48	-2.9	-0.78	0.727	-0.45

31	4	655	65	647	54	1.0	0.15	0.443	0.11

58	6	871	56	836	11	4.3	1.52	0.077	0.88

64	36	1381	146	1180	185	17.0	5.12	<0.001	1.21

65	10	1742	131	1489	141	17.0	4.16	<0.001	1.86

66	6	994	88	981	97	1.3	0.37	0.355	0.15

67	4	610	46	591	46	3.2	0.58	0.291	0.41

(From Shaw and Larson, 1999).

z Unweighted percent increase in yield for the MB:CP treatment over the
DP:CP treatment group.

y t is Student’s t test value, p is a one-tailed probability (requires
P<0.025 for conventional significance), and d is the standardized effect
size.

Average Percent Increase across all studies is 14.35%.  

California – Table C.1: Alternatives Yield Loss Data Summary  TC
"California – Table C.1: Alternatives Yield Loss Data Summary" \f F \l
"1"  

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3-Dichloropropene/

Chloropicrin	Weeds, nematodes and diseases	1% gain to 14% loss	14.4%
(Shaw and Larson, 1999)

Chloropicrin/Metam sodium	Multiple pests	6.6-47%	27% Locascio, 1999

Metam sodium 	Weeds, nematodes and diseases	16%-29.8%	29.8% (Shaw and
Larson,1999) 

Overall Loss Estimate for All Alternatives to Pests	14% 



California - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?  TC
"California - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"  



Research evaluating various chemical alternatives to MB suggests that
some (e.g., mixture of 1,3-D with chloropicrin—as with Inline product,
and possibly coupled with a separate metam-sodium application, use of
tolerant germplasm, and use of high barrier films) have the potential to
be effective treatments for strawberry pests (e.g., Fennimore et al.,
2003, 2004; Ajwa et al., 2003a, 2003b, 2004; Browne et al., 2003;
Duniway et al., 2003; Ajwa and Trout, 2004; Trout and Damodaran, 2004;
Noling and Gilreath, 2004; Hamill et al., 2004; Sydorovych et al.,
2004).  Research trials must be conducted over several seasons to assess
consistency of efficacy (e.g., Ferguson et al., 2003).  In addition, for
large scale strawberry production technical and cost issues must be
resolved, such as high barrier film application and regulatory problems,
and consistency of metam-sodium distribution, before these alternatives
can be used effectively.  Timelines for transition to MB are being
considered.  Concerns by growers in Northern California include costs
associated with shifting from broadcast fumigation to drip application
and loss of 2-3 weeks for long-day cultivars (see Appendix B).  In some
systems, the loss of two or three weeks may be the difference between
planting two vegetable crops in rotation, or only one.

Current research priorities include the following:  

Continue to identify and further define optimal conditions and
procedures required to maximize performance of 1,3-D, chloropicrin, and
other fumigant and herbicide products.  Develop a more comprehensive
understanding of the possible biologic and economic impacts of
implementing the proposed alternatives in commercial strawberry
production.  

Continue to identify and resolve implementation constraints to MB
alternatives (i.e., costs, efficacy, production or environmental risks,
regulatory constraints, and farm profitability) that impact adoption of
such alternatives.

Continue to develop effective multi-crop, IPM based systems, including
characterization of impacts and residual effects within current double
cropping systems.  

Maintain technology transfer projects to educate growers to learn how to
effectively choose, apply, and incorporate alternative chemical so as to
maximize pest control, as well as avoid problems of plant phytotoxicity,
accidents, and crop loss.

Continue to evaluate mulch technologies and procedures to minimize
emissions of MB and other soil fumigant compounds.

Continue to identify and evaluate emerging nonchemical alternatives and
amendments, such as VIF. 





California - 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?:  TC "California - 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?" \f C \l "2"  



As stated in section 17, research is making progress in defining
protocols (such as fumigant use rates, tarp types, tolerant cultivars,
and optimal water amounts).  Additional field trials are necessary to
confirm results over a multi-year period.  However, due to significant
regulatory issues (with 1,3-D and VIF) it has been difficult to
formulate an exact timeline for transition to alternatives for many
critical uses of MB.

Shank injection of alternatives such as 1,3-D, or 1,3-D with
chloropicrin, are feasible on hilly terrain but is greatly affected by
township caps.  However, research results from California (e.g.,
Fennimore et al., 2003; Ajwa et al., 2003a, 2003b; Browne et al., 2003;
Duniway et al., 2003; Ajwa and Trout, 2004) have suggested that this
type of application is less effective than when applied through drip
irrigation equipment.  The technical and economic assessment for the
eastern U.S. and Florida indicted a 14% yield loss and $ 47 and $ 62
loss per kilogram of MB respectively with the best 1,3-D and
chloropicrin application techniques.  Because of the lower efficacy, the
California strawberry growers would need to use flat fumigation for
effective pest control which would require 40% more material to be used
than in a typical drip irrigation application to the beds.  Growers with
weed control problems would need to factor in the additional cost of a
companion herbicide.  In addition, the township cap restriction requires
a different multiplier depending on mode of application. 



California - Summary of Technical Feasibility  TC "California - Summary
of Technical Feasibility" \f C \l "2"  



The U.S. nomination is only for those areas where the alternatives are
not suitable.  Use of MB for strawberries in California is critical
until commercial applications of research findings can be developed. 
While recent research results (e.g., Fennimore et al., 2003, 2004; Ajwa
et al., 2003a, 2003b, 2004; Browne et al., 2003; Duniway et al., 2003;
Ajwa and Trout, 2004; Trout and Damodaran, 2004; Noling and Gilreath,
2004; Hamill et al., 2004; Sydorovych et al., 2004) indicate that there
are potentially effective alternatives to MB, they must be tested for
additional seasons to confirm efficacy and especially must be field
tested in commercial settings to ensure production will not suffer. 
Problems facing transition to alternatives include regulatory
constraints, such as township caps, biological considerations, such as
heavy pressure from pathogens, nematodes and weeds, potential phytotoxic
effects, variation in yields, time lost due to delays in planting as a
result of drip equipment setup.  

Township caps are significant for important strawberry areas.  There are
over 4,000 townships (9,300 ha each) represented in the California
township assessment.  The information used to develop the estimate of
area impacted by township caps in California was from Carpenter, Lynch,
and Trout (1999 and 2001), supplemented by discussions with Dr. Trout to
ensure that any recent regulatory changes have been properly accounted
for.  

The current rule in effect for 1,3-D use was used for the this
nomination.  This is based on 1,3-D usage being allowed at the baseline
amount (1X level), not the short term exemption limits (2X).  The
California Department of Pesticide Regulations (Cal DPR) was contacted
for clarification on the 1,3-D township cap question.  Cal DPR explained
the use of 1,3-D starting in 2005, and beyond, would be based on:
current and historic use patterns in each individual township, future
enhancements to the air concentration model and health impact models,
and assumptions on the use of adjacent land in the models.  Because of
the uncertainties in all of these parameters they are currently unable
to speculate what the future 1,3-D township caps will be in California. 
Accordingly, we believe that the CUE must cover the level of MB needed
to meet the existing 1X regulatory limit.  



Eastern US - Part B: Crop Characteristics and Methyl Bromide Use  TC
"Eastern US - Part B: Crop Characteristics and Methyl Bromide Use" \f F
\l "1"    TC "Eastern US - Part B: Crop Characteristics and Methyl
Bromide Use" \f C \l "1"  



Eastern US - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request  TC " Eastern US - 10.
Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request" \f C \l "2"   



Eastern US - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request  TC "Eastern US - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide needed 

Eastern U.S.	Diseases: Black root rot (Pythium, Rhizoctonia),  Crown rot
(Phytopthora cactorum), 	At moderate to severe pest pressure, protocols
for commercial application of alternatives have not been sufficiently
developed to be implemented for the 2007 season.  MB applications in
strawberries are typically made using 67:33 or, where feasible, 57:43
mixtures with chloropicrin under plastic mulch.  If VIF technical
problems and cost concerns can be resolved, research suggests that
fumigant rates, including MB, can be lowered with equal efficacy to
higher rates under standard films (e.g., Hamill et al., 2004; Noling and
Gilreath, 2004; Ajwa et al., 2004; Fennimore et al., 2004).

	Nematodes: Root knot nematode (Meloidogyne spp.)



Weeds: Yellow nutsedge (Cyperus escultentus)

Purple nutsedge (Cyperus rotundus)

Ryegrass (Lolium spp.)

	

Eastern US - 11. (i) Characteristics of Cropping System and Climate  TC
" Eastern US - 11. Characteristics of Cropping System and Climate" \f C
\l "2"  



Eastern US - Table 11.1: Characteristics of Cropping System  TC "
Eastern US - Table 11.1: Characteristics of Cropping System" \f F \l "1"
 

Characteristics	Eastern US

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Fruiting plants
grown from transplants.

Annual or Perennial Crop: (# of years between replanting) 	Cultured as
annual.

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	Varies

Soil Types:  (Sand, loam, clay, etc.)	50% light, 45% medium, 5% heavy

Frequency of methyl bromide Fumigation: (e.g. every two years)	Yearly

Other relevant factors:	None identified



Eastern US - Table 11.2 Characteristics of Climate and Crop Schedule  TC
" Eastern US - Table 11.2 Characteristics of Climate and Crop Schedule"
\f F \l "1"  

	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb	Mar	Apr	May

Climatic Zone	5b – 8b

Rainfall (mm)*	248.2	trace	158	84.3	121.9	108.7	136.9	36.6	131.3	206
107.7	147.8

Outside Temp. ((C)*	25.6	27.2	27.5	25.1	20.0	11.4	7.5	6.2	9.7	15.1	17.7
22.9

Fumigation Schedule

	X	X









Planting 

Schedule



X	X







	* Macon, GA

Eastern US – 11. (ii) Indicate if any of the above characteristics in
11. (i) prevent the uptake of any relevant alternatives?



The above characteristics would not prevent adoption of any relevant
alternative.



Eastern US - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested 
TC "Eastern US - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested"
\f C \l "2"   



Eastern US, Southeastern United states - Table 12.1 Historic Pattern of
Use of Methyl Bromide  TC "Eastern US - Table 12.1 Historic Pattern of
Use of Methyl Bromide" \f F \l "1"  

For as many years as possible as shown specify:	1998	1999	2000	2001	2002
2003

Area Treated (hectares)	1446	1593	1694	1823	1879	2121

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	All strip/bed	All strip/bed	All strip/bed	All
strip/bed	All strip/bed	All strip/bed

Amount of methyl bromide active ingredient used 

(total kg)	317,918	239,851	254,689	274,405	283,530	320,133

formulations of methyl bromide (methyl bromide /chloropicrin)	67:33
67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied (e.g. injected at 25cm depth, hot
gas)	Pressurized injection at 20 cm depth – two shanks/bed
(approximately 76 cm wide bed; 25 cm height at crown of bed)

Actual dosage rate of active Ingredient (g/m2)*	22.0	15.1	15.0	15.1	15.1
15.1

* For Flat Fumigation treatment application rate and dosage rate may be
the same.

Eastern US - Part C: Technical Validation  TC "Eastern US - Part C:
Technical Validation" \f F \l "1"    TC "Eastern US - Part C: Technical
Validation" \f C \l "1"  



Eastern US - 13. Reason for Alternatives Not Being Feasible  TC "Eastern
US - 13. Reason for Alternatives Not Being Feasible" \f C \l "2"   



Eastern US – 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 Dichloropropene 

(1,3-D, Telone)	Used alone, 1,3-D does not adequately control diseases
and weeds, especially nutsedges.  Buffer zones of 30 m are too
constraining for small fields.  Required protective equipment
(protective suits) pose a health risk to workers in hot and humid
weather.  Long pre-planting intervals affect cultivar selection,
Integrated Pest Management practices, timing of harvest, marketing
window options, land leasing decisions and crop rotation schedules 	No

Basamid	Basamid is not registered in the U.S. for strawberry fruit
production.  	No

Chloropicrin	Chloropicrin alone is not a technically feasible
alternative because it provides poor nematode and weed control, although
it provides good disease control 	No

Metam sodium	Metam-sodium alone is not a technically feasible
alternative because it provides unpredictable disease, nematode, and
weed control.  	No

Methyl iodide	Not currently registered in the U.S. 	No

Nematicides	Addressed individually. 	No

Ozone	Ozone is not technically feasible alone because it doesn’t
control diseases and weeds.  	No

Non Chemical Alternatives

Biofumigation	Biofumigation is not technically feasible because of the
quantity of Brassica crop that would be needed to control target pests
in strawberries (approximately three hectares would be required for
every hectare of strawberry production).  Incorporation of Brassica at
these levels is likely to have allelopathic effects on the target crop. 
In addition, field trials of growing tomatoes in cabbage residue
produced inconsistent and inadequate efficacy, and poor yield in two
years out of three.  	No

Solarization	Solarization, when used alone for pre-plant fumigation, is
not technically feasible because it does not provide adequate control of
a wide range of soil-borne diseases and pests.  This process is highly
weather dependent and works best in combination with IPM for control of
pests and diseases.  However, solarization only suppresses nutsedge at
best.  (Chase et.al., 1998; Egley, 1983)	No

Steam	Steam, although successfully used in greenhouse situations, when
used alone in the field for pre-plant fumigation, is not operationally
practical due to low application speeds and high energy requirements
(1-3 weeks to treat one hectare).  In addition results from field
experiments steam treatment have been erratic.    	No

Biological Control	Biological control is not technically feasible as a
stand-alone replacement for methyl bromide because it does not provide
adequate control of target pests (e.g., Leandro et al., 2004).  	No

Cover Crops and Mulching	Although already in use as part of an
Integrated Pest Management Program, cover crops and mulching alone do
not provide adequate control of the target pests.  	No

Crop rotation/fallow	Crop rotation is already being used in many
strawberry production areas, but does not adequately control the target
pests.  	No

Flooding and water management	Flooding and water management are not
feasible due to limited water resources, uneven topography in
California, and in the eastern states by sandy soil types that would not
retain the flood for an adequate time to control the pests.	No

General IPM	General IPM is already practiced in strawberry production,
but it is not technically feasible as a stand-alone replacement for
methyl bromide since a combination of IPM methods do not offer adequate
pest control by itself.  	No

Grafting/Resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding is not being used and it is not technically
feasible because grafting is not possible given the physical
characteristics of strawberry plants.  Breeding for resistance to
pathogens is valuable as a long-term endeavor and the U.S. continues
work in this area.  At this point in time, plant breeding has not
resulted in a cultivar that is sufficiently resistant to the major
target pests.  	No

Hand-weeding	Hand weeding strawberries is not a desirable practice for
controlling nutsedge.  Sedges reproduce through below-ground tubers or
nutlets.  When a sedge plant is removed by hand the 10 to 30 tubers,
which grow 2 to 30 cm (1 to 12 inches) below ground, will rapidly
produce new plants.  Therefore, had weeding can lead to a rapid 10- to
30-fold increase in weeds.  In addition, those sedges that germinate
under the plastic mulch cannot be removed by hand without damaging the
plastic and reducing its effectiveness in excluding weeds, insects, and
pathogens.  	No

Organic Amendments/Compost	Organic Amendments/Compost is already being
used in certain regions of the U.S., but is not technically feasible as
a stand-alone replacement for methyl bromide.  	No

Organic production	In certain regions of the U.S. some organic
production of strawberries occurs.  However, as a stand alone
replacement for methyl bromide it is not technically feasible because of
reduced yields.  	No

Resistant cultivars	Resistant cultivars are already being used in
certain regions of the U.S., but it is not technically feasible as a
stand-alone replacement for methyl bromide.  	No

Soil-less culture	Soil-less culture is not being used and it is not
technically feasible because it requires a complete transformation of
the U.S. production system.  There are high costs associated with this
as compared to current production practices.  	No

Substrates/Plug plants	Substrates/plant plugs are currently being used
but are not technically feasible as a stand-alone replacement for methyl
bromide.   Although plug plants can be more vigorous than bare root
transplants in research trials, disease problems can be severe.  One
study found significant contamination with Colletotrichum acutatum as a
result of contaminated nursery stock from Canada and numerous growers
lost entire plantings in several states (Sances, 2003).  These problems
can be overcome (Sances, 2004), but the technology is not ready for
widespread commercial application until further studies are conducted
and analyzed.  Weed control would still be an issue and adopting this
use would also require major retooling of the industry.	No

Tarps	Research on virtually impermeable films (e.g., Ajwa et al., 2003a,
2004; Duniway et al., 2003; Fennimore et al., 2003, 2004; Hamill et al.,
2004) shows promise in improving efficacy of chemical fumigants. 
However, technical issues of application feasibility and costs could
hamper implementation.	No

Combinations of Alternatives

1,3-Dichloropropene/ Chloropicrin	This combination is considered
feasible as an alternative in circumstances where weed pressures are
low.  Together treatment provides good nematicidal and fungicidal
capabilities, but would likely require an herbicide partner to control
weeds such as nutsedge.  Regulatory restrictions for each of the
chemicals may further limit their use.   	No, in areas with moderate to
severe weed infestation and if not allowed by local regulations.

1,3-Dichloropropene/ Chloropicrin and Metam sodium	These combinations
also provide good nematicidal and fungicidal capabilities, but would
likely require an herbicide partner (or hand weeding) to control. 
Regulatory restrictions for each of the chemicals may further limit
their use.  VIF may improve efficacy, if technological and cost issues
are resolved.	No, in areas with moderate to severe weed infestation and
if not allowed by local regulations.

* Regulatory reasons include local restrictions (e.g. occupational
health and safety, local environmental regulations) and lack of
registration.



Eastern US - 14. List and Discuss Why Registered (and Potential)
Pesticides and Herbicides Are Considered Not Effective as Technical
Alternatives to Methyl Bromide:  TC "Eastern US - 14. List and Discuss
Why Registered (and Potential) Pesticides and Herbicides Are Considered
Not Effective as Technical Alternatives to Methyl Bromide:" \f C \l "2" 




Eastern US – Table 14.1: Technically Infeasible Alternatives
Discussion  TC "Eastern US – Table 14.1: Technically Infeasible
Alternatives Discussion" \f F \l "1"  

Name of Alternative	Discussion

Metam sodium	This potential alternative has an extended time between
application and crop planting (compared to MB) and is not very effective
on nutsedge.  

Chloropicrin	The alternative does not give effective control of
nutsedge.  It also produces objectionable odors (a serious issue in
urban fringe areas where strawberries are grown.)  Insufficient root
knot nematode control.  

1,3-D	The alternative does not give effective control of nutsedge. 
Excessive PPE requirements, and set or buffer space requirements.

1,3-D, chloropicrin	The alternative does not give effective control of
nutsedge.  Excessive PPE requirements, and set or buffer space
requirements.  There are occasional phytotoxicity problems associated
with this alternative.  

1,3-D, chloropicrin, metam sodium	This combination is considered
feasible as an alternative where weed pressure is low.  Together they
provide good nematicidal and fungicidal capabilities, but may require a
herbicide partner to control weeds such as nutsedge.  Regulatory
restrictions may limit their use.  Experiments (Gilreath, Motis, Santos,
Noling, 2003) with VIF and 1,3-D/chloropicrin indicate nutsedge control
may be achievable but rates and formulations are still be investigated
for optimal efficacy.  VIF may improve efficacy, if technological and
cost issues are resolved.

Metam sodium, chloropicrin	Will not effectively control nematodes.

Nematicides 	None registered except 1,3-D.



Eastern US - 15. List Present (and Possible Future) Registration Status
of Any Current and Potential Alternatives  TC "Eastern US - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives" \f C \l "2"  



Eastern US – 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:

Basamid	Not registered for use on strawberries.	Y	Unknown

Methyl Iodide	Not registered in U.S.	Y	Unknown

Propargyl bromide	Not registered in U.S.	N	Unknown

Furfural	Not registered for use on strawberries.	Unknown	Unknown



  TC "Eastern US – Table 15.1: Present Registration Status of
Alternatives" \f F \l "1"  

Eastern US - 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  TC "Eastern US - 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"
\f C \l "2"   



See California region, Section 16, for discussion of studies of relevant
alternatives.  

Eastern US – Table C.1: Alternatives Yield Loss Data Summary  TC
"Eastern US – Table C.1: Alternatives Yield Loss Data Summary" \f F \l
"1"  

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3-Dichloropropene/

Chloropicrin	Weeds, nematodes and diseases	1% gain to 14% loss	14.4%
(Shaw and Larson, 1999)

Chloropicrin/Metam sodium	Multiple pests	6.6-47%	27% Locascio, 1999

Metam sodium 	Weeds, nematodes and diseases	16%-29.8%	29.8% (Shaw and
Larson,1999) 

Overall Loss Estimate for All Alternatives to Pests	14%



Eastern US - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?  TC
"Eastern US - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"  



Research evaluating various chemical alternatives to MB suggests that
some (e.g., mixture of 1,3-D with chloropicrin—as with Inline product,
and possibly coupled with a separate metam-sodium application, use of
tolerant germplasm, and use of VIF) have the potential to be effective
treatments for strawberry pests (e.g., Fennimore et al., 2003, 2004;
Ajwa et al., 2003a, 2003b, 2004; Browne et al., 2003; Duniway et al.,
2003; Ajwa and Trout, 2004; Trout and Damodaran, 2004; Noling and
Gilreath, 2004; Hamill et al., 2004; Sydorovych et al., 2004).  Research
trials must be conducted over several seasons to assess consistency of
efficacy (e.g., Ferguson et al., 2003).  In addition, for large scale
strawberry production technical and cost issues must be resolved, such
as VIF application and regulatory problems, and consistency of
metam-sodium distribution, before these alternatives can be used
commercially.  

Current research priorities include the following:  

Continue to identify and further define optimal conditions and
procedures required to maximize performance of 1,3-D, chloropicrin, and
other fumigant and herbicide products.  Develop a more comprehensive
understanding of the possible biologic and economic impacts of
implementing the proposed alternatives in commercial strawberry
production.  

Continue to identify and resolve implementation constraints to MB
alternatives (i.e., costs, efficacy, production or environmental risks,
regulatory constraints, and farm profitability) that impact adoption of
such alternatives.

Continue to develop effective multi-crop, IPM based systems, including
characterization of impacts and residual effects within current double
cropping systems.  

Maintain technology transfer projects to educate growers to learn how to
effectively choose, apply, and incorporate alternative chemical so as to
maximize pest control, crop response and to avoid problems of plant
phytotoxicity and crop loss.

Continue to evaluate mulch technologies and procedures to minimize
emissions of MB and other soil fumigant compounds from soil.

Continue to identify and evaluate emerging nonchemical alternatives and
amendments, such as VIF. 





Eastern US - 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?  TC "Eastern US - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?" \f C \l "2"  



As stated in section 17, research is making progress in defining
protocols (such as fumigant use rates, tarp types, tolerant cultivars,
and optimal water amounts).  Additional field trials are necessary to
confirm results over a multi-year period.  



Eastern US - Summary of Technical Feasibility  TC "Eastern US - Summary
of Technical Feasibility" \f C \l "2"  



The U.S. nomination is only for those areas where the alternatives are
not suitable.  Use of MB for strawberries in the eastern U.S. is
critical until commercial applications of research findings can be
developed.  While recent research results (e.g., Fennimore et al., 2003,
2004; Ajwa et al., 2003a, 2003b, 2004; Browne et al., 2003; Duniway et
al., 2003; Ajwa and Trout, 2004; Trout and Damodaran, 2004; Noling and
Gilreath, 2004; Hamill et al., 2004; Sydorovych et al., 2004) indicate
that there are potentially effective alternatives to MB, they must be
tested for additional seasons to confirm efficacy and especially must be
field tested in commercial settings to ensure production will not
suffer.  Problems facing transition to alternatives include regulatory
constraints of 30 m buffer zones, biological considerations, such as
heavy pressure from pathogens, nematodes and especially nutsedge,
potential phytotoxic effects, variation in yields, time lost due to
delays in planting.

The U.S. estimates of the area impacted by 30 m buffer zones are 40% for
the eastern U.S. and 1% for Florida.  These estimates used information
from applicants and alternatives manufacturers including: average field
size, the density of habitable structures near strawberry fields,
population distributions, and surveys of extension agents.  For example,
the eastern U.S. has many small “pick-your-own” strawberry farms
(less than 4 hectares) where the impact of a 30 m buffer is more
pronounced than on the larger farms in California or Florida.  Because
of the significant impact that these estimates have on the overall
request for MB, the U.S. EPA is evaluating additional methods to further
substantiate and quantify the impacts of buffer zones.  

One of the key barriers to adoption of a fumigant and herbicide
combination (using fumigants such as chloropicrin, metam sodium with
chloropicrin) is the lack of selective herbicides for strawberry weed
control.  Of the herbicides registered in the U.S., only s-metolachlor
will provide suppression of yellow nutsedge, but will provide no control
of purple nutsedge at current label rates.  However, ongoing work by
Noling and Gilreath (2004) indicates that nutsedge control can be
achieved with lower rates of MB when used with VIF compared to MB with
standard film.  







Florida - Part B: Crop Characteristics and Methyl Bromide Use  TC
"Florida - Part B: Crop Characteristics and Methyl Bromide Use" \f F \l
"1"    TC "Florida - Part B: Crop Characteristics and Methyl Bromide
Use" \f C \l "1"  



Florida - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request  TC " Florida - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request" \f C \l "2"  



Florida, Florida - Table 10.1: Key Diseases and Weeds and Reason for
Methyl Bromide Request  TC "Florida - Table 10.1: Key Diseases and Weeds
and Reason for Methyl Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide needed 

Florida

	Diseases: Crown rot, (Phytophthora citricola, P. cactorum) 

	At moderate to severe pest pressure, protocols for commercial
application of alternatives have not been sufficiently developed to be
implemented for the 2007 season.  The use of some alternatives are
limited in some areas because the soil overlays a vulnerable water table
(karst geology).  In addition, there are other areas where regulatory
restrictions, such as mandatory buffers around inhabited structures make
alternatives infeasible.  MB applications in Florida strawberries are
typically made using 98:2 or 67:33 mixtures with chloropicrin under
plastic mulch.  If VIF technical problems and cost concerns can be
resolved, research suggests that fumigant rates, including MB, can be
lowered with equal efficacy to higher rates under standard films (e.g.,
Hamill et al., 2004; Noling and Gilreath, 2004; Ajwa et al., 2004;
Fennimore et al., 2004).

	Nematodes: Sting (Belonolaimus longicaudatus); Root-knot (Meloidogyne
spp.)



Weeds: Yellow nutsedge (Cyperus esculentus); Purple nutsedge (Cyperus
rotundus); Carolina Geranium (G. carolinianum);

Cut-leaf Evening Primrose (Onoethera laciniata)

	

A critical use of MB in this region is to control yellow and purple
nutsedge.  While it is generally accepted by scientific experts that the
incidence of these weeds in the southeastern U.S. is very high, exact
figures have been difficult to obtain. 

In 2004, Dr. Stanley Culpepper of the University of Georgia submitted to
EPA the results of a survey that characterized the incidence of nutsedge
in vegetable operations.  In this survey, extension agents in 34 Georgia
vegetable producing counties were polled to better understand the level
of nutsedge infestation in eggplants and peppers, among other vegetable
crops.  Their responses are based on their extensive interactions with
vegetable growers in their jurisdictions.  The portion of the survey
data related to eggplants and peppers, used as a surrogate for
strawberries, is summarized below (see Tables 10.2 & 10.3).

Florida-Table 10.2.  Percent Current Nutsedge Infestation in Georgia
Counties While Methyl Bromide is Available (Culpepper, 2004).*

Crop	No Infestation	Light Infestation	Moderate Infestation	Severe
Infestation

Pepper	1.3	18.9	65.6	14.2

Eggplant	1.0	40.6	39.0	19.4







*No infestation = no nutsedge infesting production area

*Light infestation = < 5 nutsedge plants per square meter

*Moderate infestation = 5 to 30 nutsedge plants per square meter

*Severe infestations = >30 nutsedge plants per square meter

Florida-Table 10.3.  Percent Anticipated Nutsedge Infestation The Year
After the Inability to Use Methyl Bromide (Culpepper, 2004). *

Crop	No Infestation	Light Infestation	Moderate Infestation	Severe
Infestation

Pepper	0.0	9.1	31.6	59.3

Eggplant	0.2	11.9	50.3	37.6







*No infestation = no nutsedge infesting production area

*Light infestation = < 5 nutsedge plants per square meter

*Moderate infestation = 5 to 30 nutsedge plants per square meter

*Severe infestations = >30 nutsedge plants per square meter

While this survey focused on Georgia, EPA believes it is reasonable to
expect that the levels of nutsedge infestations reported for these crops
is likely to be representative of other areas of the southern USA.  

Florida - 11. (i) Characteristics of Cropping System and Climate  TC "
Florida - 11. Characteristics of Cropping System and Climate" \f C \l
"2"  



Florida - Table 11.1: Characteristics of Cropping System  TC " Florida -
Table 11.1: Characteristics of Cropping System" \f F \l "1"  

Characteristics	Florida

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Transplants

Annual or Perennial Crop: (# of years between replanting) 	Cultured as
annual.

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	Cucurbits and peppers

Soil Types:  (Sand, loam, clay, etc.)	Sandy to loam soil

Frequency of methyl bromide Fumigation: (e.g. every two years)	Annually

Other relevant factors:	None identified



Florida - Table 11.2 Characteristics of Climate and Crop Schedule  TC "
Florida - Table 11.2 Characteristics of Climate and Crop Schedule" \f F
\l "1"  

	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan 	Feb

Climatic Zone

(e.g. temperate, tropical)	9a-10b	9a-10b	9a-10b	9a-10b	9a-10b	9a-10b
9a-10b	9a-10b	9a-10b	9a-10b	9a-10b	9a-10b

Rainfall (mm)	65.5	50	72.6	134.1	175.8	193.3	152.7	65	42.7	158.8	62	66.8

Outside Temp. ((C)	19.4	22.1	25.3	27.6	28.2	28.2	27.3	24.1	19.2	17.3	16
16.9

Fumigation Schedule





X	X





	Planting 

Schedule





	X	X







Florida – 11. (ii) Indicate if any of the above characteristics in 11.
(i) prevent the uptake of any relevant alternatives?



Severe weather can impact pest pressure. 



Florida - 12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested  TC
"Florida - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested"
\f C \l "2"   



Florida - Table 12.1 Historic Pattern of Use of Methyl Bromide  TC
"Florida - Table 12.1 Historic Pattern of Use of Methyl Bromide" \f F \l
"1"  

For as many years as possible as shown specify:	1998	1999	2000	2001	2002
2003

Area Treated (hectares)	2509	2509	2509	2630	2792	2873

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	All strip



Amount of methyl bromide active ingredient used

(total kg)	551,205	464,025	471,282	486,477	516,414	708,523

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 	Chiseled into soil 30-45 cm
below surface of bed

Dosage rate of active ingredient in kg/ha*	22.0	18.5	18.8	18.5	18.5	24.7

* For Flat Fumigation treatment application rate and dosage rate may be
the same.

Florida - Part C: Technical Validation  TC "Florida - Part C: Technical
Validation" \f F \l "1"    TC "Florida - Part C: Technical Validation"
\f C \l "1"  



Florida - 13. Reason for Alternatives Not Being Feasible  TC "Florida -
13. Reason for Alternatives Not Being Feasible" \f C \l "2"   



Florida – 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 Dichloropropene 

(1,3-D, Telone)	Used alone, 1,3- D does not adequately control diseases
and weeds.  Buffer zones of 30 m are constraining for small fields. 
Required protective equipment (protective suits) pose a health risk to
workers in hot and humid weather.  Long pre-planting intervals affect
cultivar selection, Integrated Pest Management practices, time of
harvest, marketing window options, land leasing decisions and crop
rotation schedules.  In Florida, there are regulatory constraints on
1,3-D in fields over karst geology.	No

Basamid	Basamid is not registered in the U.S. for strawberry fruit
production.  	

No

Chloropicrin	Chloropicrin alone is not a feasible alternative because it
provides poor nematode and weed control, although it provides good
disease control. 	No

Metam sodium	Metam-sodium alone is not a feasible alternative because it
provides unpredictable disease, nematode, and weed control.  Research is
ongoing (e.g., Gilreath, Santos, and Noling, 2003) examining issues such
as rates and water delivery volume to determine ways to improve
consistency.	No

Methyl iodide	Not currently registered in the U.S.	No

Nematicides	Addressed individually (e.g., 1,3-D).	No

Ozone	Ozone is not technically feasible alone because it doesn’t
control diseases and weeds.  	No

Non Chemical Alternatives

Biofumigation	Biofumigation is not technically feasible because of the
quantity of Brassica crop that would be needed to control target pests
in strawberries (approximately three hectares would be required for
every hectare of strawberry production).  Incorporation of Brassica at
these levels is likely to have allelopathic effects on the target crop. 
In addition, filed trials on tomatoes grown in cabbage residue produced
inconsistent and inadequate efficacy, and poor yield in two years out of
three.  	No

Solarization	Solarization, when used alone for pre-plant fumigation, is
not technically feasible because it does not provide adequate control of
a wide range of soil-borne diseases and pests.  This process is highly
weather dependent and works best in combination with IPM for control of
pests and diseases.  However, solarization only suppresses  nutsedge at
best.  (Chase et.al. 1998. Egley, 1983)	No

Steam	Steam, when used alone for pre-plant fumigation, is not
operationally practical due to low application speeds and high energy
requirements (1-3 weeks to treat one hectare).  In addition results from
field experiments steam treatment have been erratic.    	No

Biological Control	Biological control is not technically feasible as a
stand alone replacement for methyl bromide because it does not provide
adequate control of target pests.  	No

Cover Crops and Mulching	Although already in use as part of an
Integrated Pest Management Program, cover crops and mulching alone do
not provide adequate control of the target pests.  	No

Crop rotation/fallow	Crop rotation is already being used in many
strawberry production areas, but does not adequately control the target
pests.  	No

Flooding and water management	Flooding and water management  are not
feasible due to limited water resources, uneven topography in Florida,
and in the eastern states by sandy soil types that would not retain the
flood for an adequate time to control the pests.	No

General IPM	General IPM is already practiced in strawberry production,
but it is not technically feasible as a stand alone replacement for
methyl bromide since even a combination of IPM methods do not offer
adequate pest control by itself.  	No

Grafting/Resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding is not being used and it is not technically
feasible because grafting is not possible given the physical
characteristics of strawberry plants.  Breeding for resistance to
pathogens is valuable as a long-term endeavor and the U.S. continues
work in this area.  At this point in time, plant breeding has not
resulted in a cultivar that is sufficiently resistant to the major
target pests.  	No

Hand-weeding	Hand weeding strawberries is not a desirable practice for
controlling nutsedge.  Nutsedges reproduce through below-ground tubers
or nutlets.  When a nutsedge plant is removed by hand the 10 to 30
tubers, which grow 2 to 30 cm (1 to 12 inches) below ground, will
rapidly produce new plants.  Therefore, had weeding can lead to a rapid
10- to 30-fold increase in weeds.  In addition, those nutsedges that
germinate under the plastic mulch cannot be removed by hand without
damaging the plastic and reducing its effectiveness in excluding weeds,
insects, and pathogens.  	No

Organic Amendments/Compost	Organic Amendments/Compost is already being
used in certain regions of the U.S., but is not technically feasible as
a stand-alone replacement for methyl bromide.  	No

Organic production	In certain regions of the U.S. some organic
production of strawberries occurs.  However, as a stand alone
replacement for methyl bromide it is not technically feasible because of
reduced yields.  	No

Resistant cultivars	Resistant cultivars are already being used in
certain regions of the U.S., but it is not technically feasible as a
stand-alone replacement for methyl bromide.  	No

Soil-less culture	Soil-less culture is not being used currently and it
is not now technically feasible because it requires a complete
transformation of the Florida production system.  There are high costs
associated with this as compared to current production practices. 
Research is being conducted to address important concerns (e.g.,
Paranjpe et al., 2003).	No

Substrates/Plug plants	Substrates/plant plugs are currently being used
but are not technically feasible as a stand-alone replacement for methyl
bromide.   Although plug plants can be more vigorous than bare root
transplants (Kokalis-Burelle, 2003), diseases must be carefully
monitored.  One study found significant contamination with
Colletotrichum acutatum as a result of contaminated nursery stock from
Canada and numerous growers lost entire plantings in several states
(Sances, 2003). These problems can be overcome (Sances, 2004), but
further studies are necessary.  Weed control would still be an issue and
adopting this use would also require major retooling of the industry.   
No

Tarps	Research on virtually impermeable films (e.g., Ajwa et al., 2003a,
2004; Duniway et al., 2003; Fennimore et al., 2003, 2004; Hamill et al.,
2004) shows promise in improving efficacy of chemical fumigants. 
However, technical issues of application feasibility and costs could
hamper implementation.	No

Combinations of Alternatives

1,3-Dichloropropene/ Chloropicrin	This combination is considered
technically feasible as an alternative in certain circumstances where
weed pressure is low.  Together they provide good nematicidal and
fungicidal capabilities, but would still require a herbicide partner to
control weeds such as nutsedge.  Regulatory restrictions for each of the
chemicals may further limit their use.   Experiments (Gilreath, Motis,
Santos, Noling, 2003) with VIF and 1,3-D/chloropicrin indicate nutsedge
control may be achievable but rates and formulations are still be
investigated for optimal efficacy.	No, in areas with moderate to severe
pest infestation and if not allowed by local regulations.  

1,3-Dichloropropene/ Chloropicrin and Metam sodium	This combination
provides good nematicidal and fungicidal capabilities, and weed control
in some areas, but would likely require a herbicide partner (or hand
weeding).  Experiments (Gilreath, Motis, Santos, Noling, 2003) with VIF
and 1,3-D/chloropicrin indicate nutsedge control may be achievable but
rates and formulations are still be investigated for optimal efficacy. 
VIF may improve efficacy, if technological and cost issues are resolved.
No, in areas with moderate to severe pest infestation and if not allowed
by local regulations.  

* Regulatory reasons include local restrictions (e.g. occupational
health and safety, local environmental regulations) and lack of
registration.

Florida - 14. List and Discuss Why Registered (and Potential) Pesticides
and Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide  TC "Florida - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:" \f C \l "2"  



Florida – Table 14.1: Technically Infeasible Alternatives Discussion 

Name of Alternative	Discussion

1,3-Dichloropropene	Drip application of 1,3-D in Florida are less
expensive and require smaller buffer zones than broadcast applications,
making it the preferred application method for this alternative (drip,
90%;broadcast, 10%).  However, when drip fumigations are used production
costs are increased due to the need for herbicide applications, or metam
sodium, or hand weeding.  Recent studies in California found that fruit
production costs were 20-212% higher than with MB/chloropicrin
(Goldhue), with the smaller cost estimates coming from VIF mulch
treatments that are not currently available due to technical issues. 

Chloropicrin	Chloropicrin alone is not a technically feasible
alternative because it provides poor nematode and weed control, although
it provides good disease control 

Metam sodium	Metam-sodium alone is not a feasible alternative because it
provides unpredictable disease, nematode, and weed control.  Metam
sodium suffers from erratic efficacy most likely due to irregular
distribution of the product through soil.   

1,3-D/chloropicrin/metam-sodium	This combination is considered feasible
as an alternative where weed pressure is low.  Together they provide
good nematicidal and fungicidal capabilities, but may require a
herbicide partner to control weeds such as nutsedge.  Regulatory
restrictions may limit their use.   



Florida - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives  TC "Florida - 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives" \f C \l "2"  :



Florida – 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:

Basamid	Not registered for use on strawberries	Y	Unknown

Methyl Iodide	Not registered for use in U.S.	Y	Unknown

Propargyl bromide	Not registered for use in U.S.	N	Unknown

Furfural	Not registered for use on strawberries	Not known	Unknown



  TC "Florida – Table 15.1: Present Registration Status of
Alternatives" \f F \l "1"  

Florida - 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  TC "Florida - 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"
\f C \l "2"    



See California Region, Section 16, for discussion of studies of relevant
alternatives.  

Florida – Table C.1: Alternatives Yield Loss Data Summary  TC "Florida
– Table C.1: Alternatives Yield Loss Data Summary" \f F \l "1"  

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3-Dichloropropene/

Chloropicrin	Weeds, nematodes and diseases	1% gain to 14% loss	14.4%
(Shaw and Larson, 1999)

Chloropicrin/Metam sodium	Multiple pests	6.6-47%	27% Locascio, 1999

Metam sodium 	Weeds, nematodes and diseases	16%-29.8%	29.8% (Shaw and
Larson,1999) 

Overall Loss Estimate for All Alternatives to Pests	25%



Florida - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?  TC
"Florida - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"   



Research evaluating various chemical alternatives to MB suggests that
some (e.g., mixture of 1,3-D with chloropicrin—as with Inline product,
and possibly coupled with a separate metam-sodium application, use of
tolerant germplasm, and use of VIF) have the potential to be effective
treatments (e.g., Fennimore et al., 2003, 2004; Ajwa et al., 2003a,
2003b, 2004; Browne et al., 2003; Duniway et al., 2003; Ajwa and Trout,
2004; Trout and Damodaran, 2004; Noling and Gilreath, 2004; Hamill et
al., 2004; Sydorovych et al., 2004) for strawberry pests if efficacy and
economic issues are not problematic.  Use of plug plants, rather than
bare root transplants, appears to have a significant effect on increased
yield (Kokalis-Burelle, 2003).  Research trials must be conducted over
several seasons to assess consistency of efficacy (e.g., Ferguson et
al., 2003).  In addition, for large scale strawberry production
technical and cost issues must be resolved, such as VIF application and
regulatory problems, and consistency of metam-sodium distribution,
before these alternatives can be used commercially.  

Current research priorities include the following:  

Continue to identify and further define optimal conditions and
procedures required to maximize performance of 1,3-D, chloropicrin, and
other fumigant and herbicide products.  Develop a more comprehensive
understanding of the possible biologic and economic impacts of
implementing the proposed alternatives in commercial strawberry
production.  

Continue to identify and resolve implementation constraints to MB
alternatives (i.e., costs, efficacy, production or environmental risks,
regulatory constraints, and farm profitability) that impact adoption of
such alternatives.

Continue to develop effective multi-crop, IPM based systems, including
characterization of impacts and residual effects within current double
cropping systems.  

Maintain technology transfer projects to educate growers to learn how to
effectively choose, apply , and incorporate alternative chemicals to
maximize pest control, crop response and to avoid problems of plant
phytotoxicity and crop loss.

Continue to evaluate mulch technologies and procedures to minimize
emissions of MB and other soil fumigant compounds from soil.

Continue to identify and evaluate emerging nonchemical alternatives and
amendments, such as VIF. 





Florida – 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?  TC "Florida - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?" \f C \l "2"   



Researchers are making progress in developing protocols (such as
fumigant use rates, tarp types, tolerant cultivars, and optimal water
amounts).  Additional field trials are necessary to confirm results over
a multi-year period.



Florida Summary of Technical Feasibility  TC "Florida - Summary of
Technical Feasibility" \f C \l "2"  



The U.S. nomination is only for those areas where the alternatives are
not suitable.  Use of MB for strawberries in Florida is critical until
commercial applications of research findings can be developed.  While
recent research results (e.g., Fennimore et al., 2003, 2004; Ajwa et
al., 2003a, 2003b, 2004; Browne et al., 2003; Duniway et al., 2003; Ajwa
and Trout, 2004; Trout and Damodaran, 2004; Noling and Gilreath, 2004;
Hamill et al., 2004; Sydorovych et al., 2004) indicate that there are
potentially effective alternatives to MB, they must be tested for
additional seasons to confirm efficacy and especially must be field
tested in commercial settings to ensure production will not suffer. 
Problems facing transition to alternatives include regulatory
constraints, such as karst geology preventing use of 1,3-D, biological
considerations, such as heavy pressure from weeds, especially nutsedge,
pathogens, and nematodes, and other factors such as potential phytotoxic
effects, variation in yields, time lost due to delays in planting.

The estimates of the area impacted by karst geology in Florida,
restricting the use of 1,3-D, were developed and mapped by the Florida
Department of Agriculture (1984).  The estimates of karst geology for
Georgia and the southeast U.S. were developed from applicant and
university survey information.  In addition see the Reregistration
Eligibility Decision (RED) for 1,3-D (U.S. EPA, 1998).  A map of the
karst geology in the U.S. is available online at   HYPERLINK
"http://www2.nature.nps.gov/nckri/map/maps/engineering_aspects/davies_ma
p_PDF.pdf" 
http://www2.nature.nps.gov/nckri/map/maps/engineering_aspects/davies_map
_PDF.pdf .  The proportion of the current Florida strawberry crop that
cannot use 1,3-D because of karst geology may be high (even 100%)
according to some interpretations of label restrictions due to “karst
geology”.

Based on research cited above, under moderate to severe pest pressure
the alternatives would lead to an overall yield loss of 25%. 
Chloropicrin alone was not specifically evaluated because it does not
provide adequate control of nematodes or weeds.  Of the herbicides
registered in the U.S. only s-metolachlor will provide suppression of
yellow nutsedge, but will provide no control of purple nutsedge at
current label rates.  One of the key barriers to adoption of a fumigant
and herbicide combination is the lack of selective herbicides for
strawberry weed control.  However, ongoing work by Noling and Gilreath
(2004) indicates that nutsedge control can be achieved with lower rates
of MB when used with VIF compared to MB with standard film.

Part D: Emission Control  TC "Part D: Emission Control" \f F \l "1"   
TC "Part D: Emission Control" \f C \l "1"  



19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use
and Emissions in the Particular Use  TC "19. Techniques That Have and
Will Be Used to Minimize Methyl Bromide Use and Emissions in the
Particular Use" \f C \l "2"   



Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions  TC
"Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions" \f
F \l "1"  

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?	Although
research appears to be promising, early adoption has come upon serious
logistical and practical limitations such as: 1. Unreliable supplies of
the VIF film since no US source of VIF film exists (only European
sources); 2. US requires season long UV protection in film vs.
Europe’s 2 weeks; and 3. Difficulty applying VIF under US production
systems without damaging film.

	Between 1997 and 2000 the US has reduced the use of methyl bromide in
strawberries grown for fruit production by 24%.	Reduction of MB/Pic in
mixtures, i.e. changes from 98:2 to 67:33– this may have some promise,
but  nutsedge is a primary pest in the Eastern region and Florida. 

	The US anticipates that the decreasing supply of methyl bromide will
motivate growers to try less frequent applications.

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Investigations are going to be initiated
in 2004-2005 with VIF in Eastern region (North Carolina); research is
ongoing in CA, FL and other areas (e.g., Gilreath, Motis, Santos,
Noling, 2003; Duniway et al., 2003; Ajwa et al., 2003a)

	None identified	None identified	None identified

Other measures 	None identified	None identified	None identified	None
identified





20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used

or Are Not Planned for the Circumstances of the Nomination, State
Reasons   TC "20. If Methyl Bromide Emission Reduction Techniques Are
Not Being Used, or Are Not Planned for the Circumstances of the
Nomination, State Reasons" \f C \l "2"  



1.	1.  Chloropicrin (drip and shank) shows promise for disease
management, but has to be used with other chemicals for efficacy on
weeds.  In addition, economic feasibility is a concern with
chloropicrin.  Multiple field studies and economic evaluation have been
conducted by Dr. Frank Louws (frank_louws@ncsu.edu) and Lisa Ferguson ( 
HYPERLINK "mailto:lisa_ferguson@ncsu.edu"  lisa_ferguson@ncsu.edu ) and
researchers elsewhere (e.g., Stall, 1999, Fennimore et al., 2003, 2004;
Ajwa et al., 2003a, 2003b, 2004; Browne et al., 2003; Duniway et al.,
2003; Ajwa and Trout, 2004).  Also, the USDA-Methyl Bromide Alternatives
Research/Extension interdisciplinary working group at NCSU (contact Lisa
Ferguson) is preparing an important summary of multiple years of
alternatives research for several eastern region states and a manuscript
is now being written by Dr. Charles Safley, NCSU, Economist, “O.
Sydorovych, C. D. Safley, L. M. Ferguson, F. J. Louws, G. E. Fernandez,
and E. B. Poling, Economic Evaluation of the Methyl Bromide Alternatives
for the Production of Strawberries in the Southeastern United States

	2.	VIF OR HIGH BARRIER FILMS –E.B. POLING is initiating work in late
summer 2004 with harvest in spring, 2005 – reports available in
summer, 2005.  Also, research in California and Florida continues to
explore means of integrating more effective plastic tarps (Fennimore et
al., 2003, 2004; Ajwa et al., 2003a, 2003b, 2004; Browne et al., 2003;
Duniway et al., 2003; Ajwa and Trout, 2004; Hamill et al., 2004; Noling
and Gilreath, 2004).  VIF barriers are not currently used in California
due to concerns of worker exposure after film removal.  This situation
may change if regulatory authorities are persuaded that workers would
not be exposed unduly to fumigant during outgassing.

	3.	1,3-D (Telone-C35/InLine) – extensive work has been conducted with
InLine especially in California (e.g., Fennimore et al., 2003, 2004;
Ajwa et al., 2003a, 2003b, 2004; Browne et al., 2003; Duniway et al.,
2003; Ajwa and Trout, 2004), and yields are frequently comparable to MB,
but limitations with use of 1,3-D + Pic have already been described.

	4.	Iodomethane may be a “drop-in” replacement for MB, when it is
available.  However, this active ingredient has not been registered in
the U.S. and it is unknown when, or if, this will take place.

Part E: Economic Assessment  TC "Part E: Economic Assessment" \f F \l
"1"    TC "Part E: Economic Assessment" \f C \l "1"  



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

21. Operating Costs of Alternatives Compared to Methyl Bromide Over
3-Year Period  TC "21. Operating Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period" \f C \l "2"  :



Table 21.1: Operating Costs of Alternatives Compared to Methyl Bromide
Over 3-Year Period  TC "Table 21.1: Operating Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period" \f F \l "1"  

Region	Alternative	Yield*	Cost in year 1 (US$/ha)	Cost in year 2
(US$/ha)	Cost in year 3 (US$/ha)

California	Methyl Bromide	100%	$65,888	$65,888	$65,888

	Chloropicrin + Metam sodium	73%	$65,683	$65,683	$65,683

	1,3-D + chloropicrin	86%	$65,664	$65,664	$65,664

	Metam Sodium	70%	$65,684	$65,684	$65,684

Florida	Methyl Bromide	100%	$44,254	$44,254	$44,254

	1,3-D + chloropicrin	86%	$43,030	$43,030	$43,030

	Chloropicrin + Metam Sodium	73%	$39584	$39584	$39584

	Metam Sodium	70%	$38,818	$38,818	$38,818

Eastern United States	Methyl Bromide	100%	$29,482	$29,482	$29,482

	Chloropicrin + Metam sodium	73%	$30,555	$30,555	$30,555

	1,3-D + chloropicrin	86%	$31,658	$31,658	$31,658

	Metam 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  TC "22. Gross and Net Revenue" \f C \l "2"  



Table 22.1: Year 1, 2, 3 Gross and Net Revenue  TC "Table 22.1: Year 1
Gross and Net Revenue" \f F \l "1"  

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)

California	Methyl Bromide	$76,252	$10,363

	Chloropicrin+ Metam sodium	$55,664	($10,020)

	1,3-D chloropicrin	$65,548	($3,840)

	Metam Sodium	$53,376	($12,307)

Florida	Methyl Bromide	$55,168	$10,914

	1,3-D + chloropicrin	$47,224	$4,194

	Chloropicrin + Metam Sodium	$40,273	$689

	Metam Sodium	$38,728	($90)

Eastern United States	Methyl Bromide	$51,892	$22,410

	Chloropicrin+ Metam sodium	$37,881	$7,327

	1,3-D chloropicrin	$44,608	$12,950

	Metam Sodium	$36,624	$6,054



Measures of Economic Impacts of Methyl Bromide Alternatives



California - Table E.1: Economic Impacts of Methyl Bromide Alternatives 
TC "California - Table E.1: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"  

California	Methyl Bromide	Pic+Metam Sodium	1,3-d+pic	Metam 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

= Gross Revenue per Hectare (us$)	$73,683	51,099	60,173	48,999

- Operating Costs per Hectare (us$)	$60,131	55,339	58,438	54,921

= Net Revenue per Hectare (us$)	$13,552	(4,240)	(1,735)	(5,922)

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  TC
"Florida - Table E.2: Economic Impacts of Methyl Bromide Alternatives"
\f F \l "1"  

Florida	Methyl Bromide	1,3-d+pic	Pic+Metam Sodium	Metam 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%	12%	19%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	62%	94%	101%



Eastern United States - Table E.3: Economic Impacts of Methyl Bromide
Alternatives  TC "Eastern United States - Table E.3: Economic Impacts of
Methyl Bromide Alternatives" \f F \l "1"  

Eastern United States	Methyl Bromide	Pic+Metam Sodium	1,3-d+pic	Metam
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$)	29,623	30,555	31,658	30,270

= Net Revenue per Hectare (us$)	22,269	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%



Summary of Economic Feasibility  TC "Summary of Economic Feasibility" \f
C \l "2"  



The economic analysis evaluated methyl bromide alternative control
scenarios for strawberry production of fruit in Eastern United States,
Florida, and California by comparing the economic outcomes of methyl
bromide oriented production systems to those using alternatives.   

The economic factors that most influence the feasibility of methyl
bromide alternatives for fresh market strawberry production are: (1)
yield losses, referring to reductions in the quantity produced, (2)
increased production costs, which may be due to the higher-cost of using
an alternative, additional pest control requirements, and/or resulting
shifts in other production or harvesting practices, and (3) missed
market windows due to plant back time restrictions, which also affect
the quantity and price received for the goods.

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

(1) Loss per Hectare.  For crops, this measure is closely tied to
income.  It is relatively easy to measure, but may be difficult to
interpret in isolation.

(2) Loss per Kilogram of Methyl Bromide.  This measure indicates the
nominal marginal value of methyl bromide to crop production.

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

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

(5) Operating Profit Margin.  We define operating profit margin to be
net operating revenue divided by gross revenue per hectare.  This
measure would provide the best indication of the total impact of the
loss of methyl bromide to an enterprise.  Again, operating costs may be
difficult to measure and fixed costs even more difficult, therefore
fixed costs were not included in the analysis.

These measures represent different ways to assess the economic
feasibility of methyl bromide alternatives for methyl bromide users. 
Because producers (suppliers) represent an integral part of any
definition of a market, we interpret the threshold of significant market
disruption to be met if there is a significant impact on commodity
suppliers using methyl bromide.  The economic measures provide the basis
for making that determination.

Several methodological approaches will help interpret the findings.
Economic estimates were first calculated in pounds and acres and then
converted to kilograms and hectares.  Costs for alternatives are based
on market prices for the control products multiplied by the number of
pounds of active ingredient that would be applied.  Baseline costs were
based on the average number of annual applications necessary to treat
strawberries with methyl bromide.

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

Loss per hectare measures the value of methyl bromide based on changes
in operating costs and/or changes in yield.  Loss expressed as a
percentage of the gross revenue is based on the ratio of the revenue
loss to the gross revenue.  This is also true for the loss as a
percentage of net revenue.  The profit margin percentage is the ratio of
net revenue to gross revenue per hectare.   The values to estimate gross
revenue and the operating costs for each alternative were derived for
three alternative fumigation scenarios for the Eastern States and
California, relative to methyl bromide: 1) metam sodium + chloropicrin;
2) 1,3-D + chloropicrin; and 3) metam sodium.  Yield loss estimates were
based on data from the CUE’s and EPA data, as well as expert opinion.

Florida

In 2002, Florida had 2,792 hectares (6,900 acres) or 100% of harvested
area treated with an average of 75 kilograms (166 pounds) of methyl
bromide per hectare (acre).  The closest chemical alternative to methyl
bromide is 1,3-D plus chloropricrin (as Telone C-35).  However, US-EPA
estimates that approximately 40% of Florida’s strawberry growing areas
overlay karst geology, which prohibits the use of 1,3-D because of the
potential for groundwater contamination.  The use of 1,3-D also requires
a 100-foot buffer around inhabited structures.  This would reduce the
strawberry producing acreage by about 10%.  Nematodes and nutsedge are
key pests in Florida strawberry controlled with methyl bromide. 
Chloropicrin is not as effective in controlling weeds as methyl bromide.
 Using chloropicrin adds to production costs through increased weeding
and labor costs (to search for and pick the fruit).  

The least-loss scenario for Florida in the absence of methyl bromide is
for growers to use 1,3-D plus chloropicrin.  Under that scenario, yield
loss would be approximately 14%, not including increases in labor costs
for hand weeding, drip irrigation costs, or changes in market prices due
to later harvests missing early market price-premiums.  A delay in
planting occurs due to the longer plant-back interval for 1,3-D, which
means delayed harvesting.  According to U.S. Department of Agriculture
data, market prices for Florida strawberries decline approximately 18%
between December and January.  Yield and price impacts together make up
impacts on gross revenues.  If growers miss the December market window,
a loss of approximately one month’s revenue would reduce grower gross
revenues by about 22% in addition to the yield loss of 25%.  

California

In California, 1,3-D plus chloropicrin would also be the primary
replacement for methyl bromide.  California restricts total use of
1,3-D, at the local level (township cap).  Approximately 63% of
California’s strawberry production lands are fumigated with MB, and
35% are fumigated with alternatives (2% of production is organic). 
Approximately 10% of the strawberry acreage is on hillsides with slopes
severe enough to make drip irrigation impractical.

Increased production preparation time would delay planting in the
Southern Region and reduce the harvest period in the Northern Region,
leading to decreases in the prices farmers receive.  Ground preparation
between crops takes three to four weeks longer using 1,3-D and
chloropicrin because of the time required to prepare drip irrigation. 
According to U.S. Department of Agriculture data, market prices for
strawberries in California decline 5% between January and February.  If
using the alternatives delays the harvest period, US-EPA estimates there
will be a market price decline in addition to a yield loss.  

Eastern United States: 

Market price data was not available for the Eastern United States but it
is assumed that the net effect of shifting from methyl bromide to any of
the alternatives would result in additional revenue reductions due
fluctuations in market price due to changes in production and harvesting
times.

It should be noted that the applicants do not consider any alternative
to be feasible and that these estimates are an attempt to measure
potential impacts.  



Part F. Future Plans  TC "Part F. Future Plans" \f F \l "1"    TC "Part
F. Future Plans" \f C \l "1"  



23. What Actions Will Be Taken to Rapidly Develop and Deploy
Alternatives for This Crop?  TC "23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?" \f C \l "2"   



A specific timeline for implementing alternative strategies for current
MB use areas is difficult primarily due to the complex and long term
nature of transfer of technological information from research to
commercial applications and the uncertainties associated with regulatory
constraints for some alternatives.  Nevertheless, as described in this
document, alternative methodologies are being streamlined to improve
efficacy.  In California, according to Trout and Damodaran (2004),
“…[m]ost growers do not believe that, in the near term with moderate
pest pressures, yields with alternatives are less than those with
MeBr:chloropicrin mixtures.  Some growers are more concerned about loss
of chloropicrin (currently under re-registration) than MeBr”.  Prior
to implementation of alternatives for commercial use, research,
including treatments with MB, is necessary.  The U.S. estimates that
strawberry fruit research will require 2377 kg per year of MB for 2005
and 2006.  This amount is necessary to conduct research on alternatives
and is in addition to the amounts requested in the submitted CUE
applications.  

Based on preliminary research results, researchers believe that a mix of
fumigants together possibly with herbicide treatments is the best
possible alternative to MB.  In addition, use of impermeable tarps can
improve efficacy of fumigants.  Combinations of 1,3-D/chloropicrin, and
metam-sodium/chloropicrin are being tested for disease and weed control.
 Future research plans will test combinations of these fumigants with
chemicals (not necessarily registered for use, but valuable for research
trials for possible future registration) such as halosulfuron,
metolachlor, and sulfentrazone.  A program to evaluate host resistance
to Phytophthora root and crown rot has been implemented.  Growers are
starting to deploy lines identified as having both genetic resistance
and acceptable horticultural qualities.

As demonstrated by the chart and description below, U.S. efforts to
research alternatives for MB have been substantial, and they have been
growing in size as the phase out has approached.  The U.S. is committed
to sustaining its research efforts out into the future until technically
and economically viable alternatives are found for each and every
controlled use of methyl bromide.   The U.S. is also committed to
continuing to share our research, and enable a global sharing of
experience.  Toward that end, for the past several years, key U.S.
government agencies have collaborated with industry to host an annual
conference on alternatives to methyl bromide.  This conference, the
Methyl Bromide Alternatives Outreach (MBAO), has become an important
forum for researchers and others to discuss scientific findings and
progress in this field.

                                    Methyl Bromide Alternatives Research
Funding History

Year

Amount (Million)

1993 

  US$ 7.255 M

1994 

  US$ 8.453 M

1995 

US$ 13.139 M

1996 

US$ 13.702 M

1997 

US$ 14.580 M

1998 

US$ 14.571 M

1999 

US$ 14.380 M

2000 

US$ 14.855 M

2001 

US$ 16.681 M

2002 

US$ 17.880 M 

The numerous MB alternative research trials that have produced
quantitative yield data are summarized in the table below.  This table
shows that, even among studies that demonstrate significant yields using
the alternatives, there is significant variation in the performance of
the alternative.  Thus, while a given alternative may perform well in
one study, it may also perform below acceptable standards in another
study.  The standard used to characterize success in the analysis
presented here is if the alternative produced crops with at least 95% of
the yield of the crop with a methyl bromide control.  However, in some
instances, even a 95% yield may involve some profit losses.

Summary of Research Results for Methyl Bromide Alternatives on U.S.
Strawberry.

Alternatives

Total Number of Studies

Number of Studies with Yield at Least 95% of Methyl Bromide

Basamid (Dazomet) and combinations

27

12

Chloropicrin and combinations

58

36

Compost systems

11

6

Enzone

3

0

Metam sodium (Vapam) and combinations

73

24

Organic production

5

1

Ozone

1

1

Solarization and Combinations

22

6

Tarps

3

1

Telone (1,3-dichloropropene) and combinations

93

41

Registration

The U. S. has invested in efforts to register MB alternatives, as well
as efforts to support technology transfer and education activities with
the private sector.  The U.S. has programs for ensuring that new
pesticides are safe for both health and the environment.  It can take a
new pesticide, or new pesticide use, several years to be registered. 
This is in addition to the time it takes to perform, draft results, and
deliver the health and safety studies that are required for
registration.  U.S. registration decisions are often the basis for other
countries’ pesticide regulations.

Since 1997, the U.S. has made the registration of alternatives to MB a
high registration priority.  By virtue of being a top registration
priority, MB alternatives enter the science review process as soon as
U.S. EPA receives the application and supporting data.  This review
process takes an average of 38 months to complete.  Additionally, the
applicant has spent, in most cases, approximately 7-10 years developing
the data necessary to support registration.  Iodomethane (methyl iodide)
is a promising alternative that is currently under review and may have
application for strawberries.





24. How Do You Plan to Minimize the Use of Methyl Bromide for the
Critical Use in the Future?  TC "24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?" \f C \l "2"   



The U.S. nomination for critical use of MB, for 2007, is only for those
areas where the alternatives are not suitable, such as constraints due
to regulatory, topographical, geological, or soil conditions. 
Furthermore, as in the past, the U.S. nomination subtracts increased
area of production from consortia requests.  Minimizing the use of MB in
the future will be a function of implementing protocols developed in
appropriate research studies.  The greatest barrier to implementation of
new techniques that can reduce or eliminate the use of MB is the time
required to adequately test treatments that appear to be effective
against the variety of pests that pose problems for commercial
strawberry production.  Numerous studies have been cited in this
nomination indicating the various possibilities that may allow growers
to produce their crops with MB alternatives.  Positive results have been
observed for options such as 1,3-D/chloropicrin, metam-sodium, VIF
tarps, etc.  However, alternatives can only be commercially viable when
economic, regulatory, biological, and geological considerations are
factored into strawberry production.  Alternatives will become more
acceptable in the coming years as research studies consolidate results
over multiyear trials and effective fumigation protocols are developed
for commercial applications.  

As an example to minimize MB use, the eastern strawberry consortium has
presented a plan.  Research and grower trials in the eastern region
suggest that further alterations in the MB:pic formulation offers the
best near term strategy to achieve significant reductions in MB
dependency, without creating significant market disruption. 
Chloropicrin is expected to be a very important part of pest control
practices in the eastern region when MB is no longer available.  Either
alone, or in combination with other materials, chloropicrin has
performed well in research trials, and two years of recent research has
demonstrated high strawberry yields in plots treated with 280 kg/ha of
96% chloropicrin (Plymouth, 2000-2001, and 2001-2002).  However, this
formulation of chloropicrin is also objectionable to workers.  Worker
protection standards must be high, and because of objectionable odor, it
may be impractical to use in “pick-your-own” and ready-pick
operations. 

Growers will achieve further reductions in MB use where nutsedge is not
a primary pest (representing about 60% of the industry, or 1333 ha) by
changing the formulation to 57:43; this change can result in a 9%
reduction in MB use by 2005(Table 24.2).  By 2006, it may be feasible to
use 50:50 mixtures with chloropicrin under plastic mulch beds to achieve
further reductions (Table 24.1).  Increasing the percentage of Pic can
occur with the fewest obstacles to implementation, and can potentially
reduce MB use by 15% in 2006 and 2007 (Table 24.3).  It is more
difficult to accomplish comparable reductions by formulation changes in
nutsedge infested regions, as experience has shown that MB dosages below
30.2 g/m2 do not provide satisfactory nutsedge control.  These growers
will likely implement alternative methods, such as VIF or high barrier
films that could reduce MB by one third.  Ongoing research will help
define the best approach.  If the use of VIF or high barrier tarps
proves effective, there is potential, in 2006 and 2007, to significantly
reduce MB use from 140,216 kg to 93,947 kg (Table 24.4).  The net effect
of implementing steps 1 and 2 on the eastern region would be a 28.4 %
reduction in 2006, and 28.4% reduction in 2007 (relative to the current
request), and a lowering of the average application rate for the region
to 108 kg/ha. 

Stepwise Reductions Proposed for the Eastern Region (January 2004)

Table 24.1.  Base information before implementation of stepwise
reductions

Eastern Region

(hectares)

Year

Nutsedge areas = 40% Consortium

Non-nutsedge areas = 60% of Consortium

Total MB

a.i.

Application rate for the a.i. (kg/ha)

2222

2005

134,278

201,418

335,696

151

2317

2006

140,216

210,324

350,841

151

2376

2007

143,936

215,905

359,841

151

Table 24.2.  Reductions for Step 1 – With adoption of 57:43 by
non-nutsedge group

Eastern Region

(hectares)

Year

Nutsedge areas = 40% Consortium

Non-nutsedge areas = 60% of Consortium

Table 1 MB

Kg (a.i.)

Adjusted MB 

Kg (a.i.)

Ave.

Appl.

Rate

(kg/h)

2222

2005

134,278

171,356

335,696

305,634

138

2317

2006

140,216

178,932

350,841

319,148

138

2376

2007

143,936

183,680

359,841

327,616

138

Table 24.3.  Reductions for Step 1 – With adoption of 50:50 by
non-nutsedge group in 2006

Eastern Region

(hectares)

Year

Nutsedge areas = 40% Consortium

Non-nutsedge areas = 60% of Consortium

Table 1 MB

Kg (a.i.)

Adjusted MB 

Kg (a.i.)

Ave.

Appl.

Rate

(kg/h)

2222

2005

134,278

171,356

335,696

305,634

138

2317

2006

140,216

156,958

350,841

297,174

128

2376

2007

143,936

161,122

359,841

305,058

128

Table 24.4.  Reductions for Step 2 – With adoption of  High Barrier
Films by Nutsedge 

Eastern Region

(hectares)

Year

Nutsedge areas = 40% Consortium

Non-nutsedge areas = 60% of Cons.

Table 1 MB

Kg (a.i.)

Adjusted MB 

Kg (a.i.)

Ave.

Appl.

Rate

(kg/h)

2222

2005

134,278

171,356

335,696

305,634

138

2317

2006

93,947

156,958

350,841

250,905

108

2376

2007

96,437

161,122

359,841

257,559

108





25. Additional Comments on the Nomination?  TC "25. Additional Comments
on the Nomination" \f C \l "2"  



For the current nomination, the U. S. believes that MB is a critical
treatment for strawberry producers until research protocols are
developed that can describe effective soil treatments for the key pests.
 In the absence of heavy pest pressure and regulatory constraints, 1,3-D
with chloropicrin, and metam sodium, may be feasible, and the U.S.
request has been reduced to take into account areas that meet these
circumstances.  However, the following factors could make the
alternatives inappropriate for commercial application:

Regulatory constraints such as township caps, buffer zones, and karst
geology 

Heavy pest pressure such as nutsedge where tests can not confirm
reliability of alternative

Phytotoxicity from alternatives

Significant variation in yields from season to season

Significantly increased costs due to delays in planting with
alternatives

Increased costs due to change of harvest time and missing optimal market
window

Reduced vigor of starter plants if strawberry nurseries cannot use MB

U.S. researchers are continuing their efforts to find and commercialize
alternatives. 

In addition, significant efforts have been made to reduce the use and
emissions of MB associated with strawberries.  For example, strawberry
producers in California have routinely integrated sustainable and
environmentally compatible techniques into their production system. 
These strategies include the use of insects for biological control, and
many techniques that limit losses to disease, including use of crop
rotation, alternating fungicides to limit resistance buildup, clean
tillage, water management and field sanitation.  Still, soil treatments
are required.  For 2007, in the absence of defined methods for MB
alternatives that can effectively be used in commercial production, MB
is critical for strawberry production.





26. Citations  TC "26. Citations" \f C \l "2"  



Ajwa, H. A., Fennimore, S., Kabir, Z., Martin, F., Duniway, J., Browne,
G., Trout, T., Khan, A., and Daugovish, O. 2004.  Strawberry yield with
chloropicrin and INLINE in combination with metam sodium and VIF. Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions, 2004. www.mbao.org.

Ajwa, H. A., Fennimore, S., Kabir, Z., Martin, F., Duniway, J., Browne,
G., Trout, T., Goodhue, R., and Guerrero, L. 2003a.  Strawberry yield
under reduced application rates of chloropicrin and INLINE in
combination with metam sodium and VIF.  Submitted by the California
Strawberry Commission, CUE Request for 2007 (Part 2).  Appendix EE.07.B.

Ajwa, H., Klose, S., Nelson, S., Minuto, A., Gullino, M., Lamberti, F.,
and Lopez-Aranda, J. 2003b. Alternatives to methyl bromide in strawberry
production in the United States of America and the Mediterranean region.
 Phytopathologia Mediterranea 42:220-244. [also submitted by the
California Strawberry Commission, CUE Request for 2007 (Part 2). 
Appendix GG.07.A.]

Ajwa, H. A. and Trout, T. 2004. Drip application of alternative
fumigants to methyl bromide for strawberry production. HortScience 39
(6):?. [also submitted by the California Strawberry Commission, CUE
Request for 2007 (Part 2).  Appendix GG.07.B.]

Brannen, P. M., Ferguson, L. M., and Louws, F. J.  2003.  Alternatives
to methyl bromide use for control of black root rot of strawberry in
Georgia, 2003.  F&N Tests Vol. 59:SMF007.

Browne, G., Becherer, H., McLaughlin, S., Fennimore, S., Duniway, J.,
Martin, F., Ajwa, H. A., Winterbottom, C., and Guerrero, L. 2003. 
Integrated management of Phytophthora on strawberry without methyl
bromide.  Submitted by the California Strawberry Commission, CUE Request
for 2007 (Part 2).  Appendix EE.07.C. (also   HYPERLINK
"http://www.mbao.org"  www.mbao.org , 2003).

Kokalis-Burelle, N.  2003.  Effects of transplant type, plant
growth-promoting rhizobacteria, and soil treatment on growth and yield
of strawberry in Florida.  Plant and Soil 256:273-280.

California Department of Food and Agriculture. California Agricultural
Statistics Service.

Carpenter, J., L. Lynch and T. Trout.  2001.  Township Limits on 1,3-DC
will Impact Adjustment to Methyl bromide Phase-out.  California
Agriculture, Volume 55, Number 3.

Carpenter, Janet and Lori Lynch.  1999.  Impact of 1,3-D Restrictions in
California after a Ban on Methyl Bromide.  Presentation at the 1999
Annual International Conference of Methyl Bromide Alternatives and
Emissions Reductions.

Crop Profile for Strawberries in California. 1999.  United States
Department of Agriculture, 

NSF Center for Integrated Pest Management. 

Crop Profile for Strawberries in Florida.  2004.  United States
Department of Agriculture, NSF Center for Integrated Pest Management. 
http://pestdata.ncsu.edu/cropprofiles/docs/FLstrawberries.html

Crop Profile for Strawberries in Virginia.  2000.  United States
Department of Agriculture, NSF Center for Integrated Pest Management. 

Culpepper, S.  2004.  Survey of infestations of nutsedges in Georgia
vegetable crops. (Unpublished).

Daugovish, O., Downer, J., and Becker, O. 2003.  Exploring
biofumigational potential of mustards.  Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions,
2003. www.mbao.org.

Duniway, J. M., Hao, J. J., Dopkins, D. M., Ajwa, H., and Browne, G. T.
2003.  Soil fumigant, plastic mulch, and variety effects on Verticillium
wilt and yield of strawberry.  Submitted by the California Strawberry
Commission, CUE Request for 2007 (Part 2).  Appendix EE.07.D. (also  
HYPERLINK "http://www.mbao.org"  www.mbao.org , 2003)

Florida Department of Agriculture and Consumer Services.  Florida
Agricultural Statistics Service.

Florida Summary of Plant Protection Regulations.  Oct. 2002.  Florida
Department of Agriculture and Consumer Services.

Fennimore, S., Kabir, Z., Ajwa, H., Daugovish, O., Roth, K., and Rachuy,
J. 2004.  Weed response to chloropicrin and INLINE dose under VIF and
standard film.  Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions, 2004. www.mbao.org.

Fennimore, S., Kabir, Z., Ajwa, H., Daugovish, O., Roth, K., and Valdez,
J. 2003.  Chloropicrin and INLINE dose-response under VIF and HDPE film:
weed control results.  Submitted by the California Strawberry
Commission, CUE Request for 2007 (Part 2).  Appendix EE.07.A.

Ferguson L. M., Louws F. J., Abad, Z. G., Fernandez, G. E., Poling, E.
B., and Brannen, P. M. 2003. Impacts of alternatives on strawberry yield
and root colonization by fungal pathogens.  Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions, 2003. www.mbao.org.

Ferguson L. M., Ducharme D.T., Driver J.G., Louws F. J., Snelson J.D.
Alternatives to methyl bromide to control black root rot of strawberry
in North Carolina, 2001-2002. Undated.  Publication not stated or
unpublished data.  No untreated control reported.  

Gamini,S. and R.K. Nishimoto. 1987.  Propagules of purple nutsedge
(Cyperus rotundus) in soil. Weed Technol. 1:217-220.

Georgia Summary of Plant Protection Regulations.  Jan. 2000.  Georgia
Department of 

Agriculture.

Gilreath, J.P., Motis, T. N., Santos, B. M., and J.W. Noling. 2003. 
Retention of 1,3-dichloropropene and nutsedge control with virtually
impermeable film.  Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions, 2003.   HYPERLINK
"http://www.mbao.org"  www.mbao.org .

Gilreath, J.P., Santos, B. M., and J.W. Noling. 2003.  Response of
nutsedge to concentration of metam potassium and delivery water volume. 
Annual International Research Conference on Methyl Bromide Alternatives
and Emissions Reductions, 2003.   HYPERLINK "http://www.mbao.org" 
www.mbao.org .

Gilreath, J.P., J.W. Noling, and P.R. Gilreath. 1999.  Nutsedge
management with cover crop for  tomato in the absence of methyl bromide.
 Research summary, USDA Specific Cooperative Agreement 58-6617-6-013.

Hamill, J., Dickson, D., T-Ou, L., Allen, L., Burelle, N., and Mendes,
M. 2004. Reduced rates of MBR and C35 under LDPE and VIF for control of
soil pests and pathogens.  Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions, 2004.   HYPERLINK
"http://www.mbao.org"  www.mbao.org .

Holm, L.G., D.L. Plucknett, J.V. Pancho, and J.P. Herberger. 1977. The
world’s worst weeds: distribution and biology.  Honolulu, HI:
University of Hawaii Press, pp.8-24.

Leandro, L., Ferguson, L., Fernandez, G., and Louws, F. 2004.
Integration of biological control for management of strawberry root rot.
 Annual International Research Conference on Methyl Bromide Alternatives
and Emissions Reductions, 2004.

Locascio S.J., Olson S.M., Chase C.A., Sinclair T.R., Dickson D.W.,
Mitchell D.J. and Chellemi D.O. 1999.  Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.  

Noling, J. W., and Gilreath, J. P. 2004. Use of virtually impermeable
plastic mulches (VIF) in Florida strawberry.  Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions, 2004.   HYPERLINK "http://www.mbao.org"  www.mbao.org .

North Carolina Department of Agriculture and Consumer Services.  North
Carolina Agricultural Statistics Service.

North Carolina Summary of Plant Protection Regulations.  Jan. 2003. 
North Carolina Department of Agriculture and Consumer Services.

Paranjpe, A. V., Cantliffe, D. J., Chandler, C K., Smither-Kopperl, M.,
Rondon, S., and Stansly, P. A. 2003. Protected culture of strawberry as
a methyl bromide alternative: cultivar trial. Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions, 2003. www.mbao.org.

Patterson, D.T. 1998.  Suppression of purple nutsedge (Cyperus rotundus)
with polyethylene film mulch. Weed Technol.12:275-280.

Rimini, R. and Wigley, S. 2004. VIF: A supplier’s view.  Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions, 2004.   HYPERLINK "http://www.mbao.org" 
www.mbao.org .

Sances, F. V. 2004. Use of plug plants and ozone safe chemical fumigants
as alternatives to methyl bromide on California strawberries and other
coastal high-cash crops. Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions, 2004.
www.mbao.org.

Sances, F. V. 2003. Conventional and organic alternatives to methyl
bromide on California strawberries and other high-cash crops. Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions, 2003. www.mbao.org.

Shaw V.S., and Larson K.D., 1999.  A meta-analysis of Strawberry Yield
Response to Pre-plant Soil Fumigation with Combinations of Methyl
Bromide-chloropicrin and Four Alternative Systems.  HortScience
34:839-845.  

SoilZone, 1999.  Ozone Gas as a Soil Fumigant.  1998 Research Program. 
Electric Power Research Institute.

Sorenson, Kenneth A., W. Douglas Gubler, Norman C. Welch, and Craig
Osteen.  The Importance of Pesticides and Other Pest Management
Practices in U.S. Strawberry Production.  1997.  Special Funded Project
of the United States Department of Agriculture, National Agricultural
Pesticide Impact Assessment program.  Document Number 1-CA-97.

Stall, W. M. 1999. Weed control in strawberry.  University of Florida
Extension.  http://edis.ifas.ufl.edu/WG037

Sydorovych, O., Safley, C., Poling, E., Ferguson, L., Fernandez, G.,
Brannen, P., and Louws, F. 2004. Economic evaluation of methyl bromide
alternatives for strawberry production. Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions,
2004. www.mbao.org.

Tennessee State Department of Agriculture. Tennessee Agricultural
Statistics Service. Tennessee Summary of Plant Protection Regulations.
Apr. 2000.  Tennessee Department of Agriculture.

Trout, T. and Damodaran, N. 2004. Adoption of methyl bromide
alternatives by California strawberry growers.  Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions, 2004.   HYPERLINK "http://www.mbao.org"  www.mbao.org .

Thullen, R.J. and P.E. Keeley. 1975. Yellow nutsedge sprouting and
resprouting potential. Weed Sci. 23:333-337.

Virginia Department of Agriculture and Consumer Services.  Virginia
Agricultural Statistics Service.  

Webster, T.M., A.S. Casinos, A.W. Johnson, C.C. Dowler, D.R. Sumner, and
R.L. Fery.  2001(a). Methyl bromide alternatives in a bell pepper-squash
rotation. Crop Rotation 20:605-614 

Webster, T.M. and G.E. Macdonald. 2001(b). A survey of weeds in various
crops in Georgia.  Weed Technol. 15:771-790.

APPENDIX A.  2007 Methyl Bromide Usage Numerical Index (BUNI).  TC
"APPENDIX A.  2007 Methyl Bromide Usage Numerical Index (BUNI)." \f C \l
"1"  

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

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. 

% 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.

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. 

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.

Quarantine and Pre-Shipment – Quarantine and pre-shipment (QPS)
hectares is the percentage (%) of the applicant’s request subject to
QPS treatments.

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. 

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.

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.

Subtractions from Requested Amounts – Subtractions from Requested
Amounts are the elements that were subtracted from the initial request
amount.

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.

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. 

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.

Subtractions from Requested Amounts, QPS - Subtractions from Requested
Amounts, QPS is the estimate measured in kilograms of the request
subject to QPS treatments.  This subtraction estimate is calculated as
the 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 %) 

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.

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. 

(%) Karst geology – Percent karst geology 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 geology.

(%) 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.

(%) 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.

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.  

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.

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.

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
geology, 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 geology.

Qualifying Area - Qualifying area (ha) is calculated by multiplying the
adjusted hectares by the combined impacts.

Use Rate - Use rate is the lower of requested use rate for 2007 or the
historic average use rate.

CUE Nominated amount - CUE nominated amount is calculated by multiplying
the qualifying area by the use rate.

Percent Reduction - Percent reduction from initial request is the
percentage of the initial request that did not qualify for the CUE
nomination. 

Sum of CUE Nominations in Sector - Self-explanatory. 

Total US Sector Nomination - Total U.S. sector nomination is the most
likely estimate of the amount needed in that sector.

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.

Strip Bed Treatment – Strip bed treatment is ‘yes’ if the
applicant uses such treatment, no otherwise.

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.

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.

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.

Pest-free cert. Required - This variable is a ‘yes’ when the product
must be certified as ‘pest-free’ in order to be sold

Other Issues.- Other issues is a short reminder of other elements of an
application that were checked

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.

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.

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.

Economic Analysis – provides summary economic information for the
applications.

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.

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.

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.

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.

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.

Marginal Strategy -This is the strategy that a particular methyl bromide
user would use if not permitted to use methyl bromide.

APPENDIX B.  Transitional Issues for Strawberry growers in Northern
California  TC "APPENDIX B.  Transitional Issues for Strawberry growers
in Northern California " \f C \l "2"  

December 17, 2004

By Dan Legard, California Strawberry Commission

There are two options for using methyl bromide alternatives in northern
California.  The first is broadcast applications of Telone C35 or
straight chloropicrin.  This option is attractive because it fits into
the current production practices (i.e. fumigation method) that growers
use with methyl bromide.  However, neither of these options currently
provides sufficient savings on the cost of the fumigation to offset the
increase weeding costs and higher risk associated with using the
alternatives for many growers.  For chloropicrin, the County
Agricultural Commissions are currently hesitant to allow growers to
broadcast fumigate in Monterey and Santa Cruz Counties due to concerns
that this would result in an increase in public complaints relating to
fumigants since a majority currently are associated with exposure to
chloropicrin.  There is not a similar concern with fumigations using
Telone C35 or methyl bromide even thought chloropicrin is also a major
component of those fumigations.  This is probably an education issue and
we are planning to work with the chloropicrin task force on educating
growers and Ag Commissions in the safe use of straight Pic.  

The main concern associated with broadcast fumigation with Telone C35 is
related to the Telone township cap.  There are different emission ratios
used for the different application methods that adjust the amount of
Telone applied to the township cap.  The lbs used are “adjusted” by
the following factors (1x for deep shank, 1.1x for drip applied, 1.8x
for shallow shank).  Hopefully, most growers would use deep shank where
possible for broadcast Telone applications.  However, broadcast
applications still involve treating approximately 40% more acreage than
drip (2 row bed and slightly lower for 3 and 4 row beds, which are
becoming more popular in the North).  

The second option for growers switching from methyl bromide is the use
of drip applied Inline or chloropicrin.  The main issue for drip applied
fumigants is that the entire field and irrigation equipment must be set
up before you can apply the fumigants.  Growers here have told me that
this requires at least an additional 2-3 weeks longer than with
broadcast fumigation.  The extension of this time is not a serious
problem on fields with short day cultivars like Camarosa, however, it is
an important problem on fields with day-neutral cultivars like Diamonte
(a majority of the acreage in the Watsonville / Salinas area).  

On ranches growing predominantly day-neutral (long day) cultivars the
production season overlaps with the next crops planting season, so
fields of day-neutral cultivars are typically rotated with vegetable
crops (i.e. half the ranch is planted in strawberry and the other half
is rotated out each year).  The normal cycle is strawberry (September 04
– November 05) followed by two vegetable crops (November 05 –
September 06) then back to strawberry (September 06 – November 07). 
The value of the October / November fruit harvests from the day-neutral
cultivars is so high that growers cannot shorten the length of their
season (not economically possible since this is when most ranches
breakeven and make their profit).  The need for an additional 2-3 weeks
to prepare a field for drip fumigation forces strawberry growers to take
back the land from the rotation vegetable growers 2-3 weeks earlier. 
Normally, vegetable growers can produce two crops between the strawberry
rotations.  However, the shortening of the season by 2-3 weeks would
cause result in only one vegetable crop on 80% of the land instead of
two.  Land sublease rates to vegetable growers are approximately $1000
for one crop and $1800 for two (the land leases for $2200 for full
year).  Therefore, strawberry growers would need to absorb the $800
increase in rent on 80% of their crop acreage due to the loss of one of
the two vegetable crops.     

A second issue with the transition to drip applied fumigants is the need
to setup the entire irrigation system before they fumigate.  In the
traditional production system (i.e. broadcast fumigation), growers
migrate most of their irrigation headers and other main line pipes over
from the previous season’s crop to the new after the end of that
season (in November/December/January).  However, with drip applied
fumigants growers will need two sets of this equipment, an increased
cost that is difficult for many growers to absorb.  It is difficult to
get firm prices on this but I have an estimate of $500 / acre for the
additional equipment.  Another related issue is that growers cannot use
drip applied fumigants on land that has not had strawberries on it
before due to a similar issue.  The main valves and pipes for the
irrigation system need to be setup for strawberry, and this can’t be
done while another crop is in the ground, and there is insufficient time
put this equipment in and setup for drip applied fumigation.  Growers in
this situation will have to use broadcast fumigation for the first year
on new non-strawberry ground.

APPENDIX C.  2006 Methyl Bromide Reconsideration for Strawberry Fruit. 
TC "APPENDIX C.  2006 Methyl Bromide Reconsideration for Strawberry
Fruit." \f C \l "1"  

Overview of the U.S. Nomination

The U.S. is requesting 1,918.4 metric tons of methyl bromide for use on
field grown strawberries in California (1,452.732 metric tons), Florida
(310.997 metric tons) , and the southeastern U.S. (152.294 metric tons).


The U.S. nomination is only for those areas where the alternatives are
not suitable.  In U.S. strawberry fruit production there are several
factors that make the potential alternatives to methyl bromide
unsuitable.  These include:

pest control efficacy of alternatives: the efficacy of alternatives may
not be comparable to methyl bromide in some areas, making these
alternatives technically and/or economically infeasible for use in
strawberry fruit production.

geographic distribution of key target pests: i.e., some alternatives may
be comparable to methyl bromide as long as key pests occur at low
pressure, and in such cases the U.S. is only nominating a CUE for
strawberry fruit where the key pest pressure is moderate to high such as
nutsedge in the Southeastern US.

regulatory constraints: e.g., telone use is limited in California due to
townships caps and in Florida due to the presence of karst geology.

delay in planting and harvesting: e.g., the plant-back interval for
telone+chloropicrin is two weeks longer than methyl
bromide+chloropicrin.  Delays in planting and harvesting result in users
missing key market windows, and adversely affect revenues through lower
prices.

unsuitable topography: e.g., alternatives that must be applied with drip
irrigation may not be suitable in areas with rolling or sloped
topography due to uneven distribution of the fumigant.

MBTOC recommended that 1,520.803 metric tons of methyl bromide be
allocated to this use as follows: Florida, 224.142 metric tons, the
southeastern U.S. 134.476 metric tons, and California 1162.186 metric
tons.  

MBTOC reasons that the amount calculated by the USG was predicated on a
1X township cap but that the ‘Ornamental’ portion of the U.S.
nomination indicates that a greater availability of 1,3-D is expected
for 2006.  MBTOC further argues that there are available substitutes for
methyl bromide and cites “Porter, in press”, to justify a 20%
reduction in the nominated amount.  MBTOC states that Pic EC® or metam
and pic are ‘technically suitable’ for Florida and the southeastern
US.   MBTOC also states that reduced dosage is appropriate because the
treated portion of the beds can be held to 200kg/ha and because dosages
can be reduced when higher density films (including VIF) are used,
citing Fennimore et al 2005 and Gilreath et al 2003.

The U.S. nomination for strawberry field grown strawberry fruit is a
critical need for an amount of methyl bromide in areas with moderate to
severe pest pressure, because currently there are no feasible
alternatives and farmers would face severe economic hardships in the
absence of methyl bromide.  Where there is moderate to severe pest
pressure, the suggested alternatives for strawberry fruit production
fail to provide the necessary degree of pest control or their use is not
easily adoptable due to state-imposed restrictions.  The nomination also
notes that applying alternatives is further complicated when plant-back
restrictions prevent farmers from meeting marketing windows (e.g.,
winter or early spring) when strawberry sale prices are as much as 100%
higher than during the rest of the year (see Market Window Information).
 The nomination notes significant progress in adopting emission
reduction technologies and changing formulations and application rates
to reduce methyl bromide dosage rates to some of the lowest in the
world, and that further trials are being conducted to evaluate new
alternatives, and to test ways of overcoming constraints in further
lowering methyl bromide formulations and adopting even more impermeable
barriers.

Despite use of many alternatives, many of which have already been
incorporated into standard strawberry production systems, methyl bromide
is believed to be the only currently available treatment that
consistently provides reliable control of nutsedge species, nematodes
and the disease complex affecting strawberry production.  Only acreage
with moderate to high pest pressure is included in this nomination.  

Township caps

MBTOC indicates their understanding that the nomination was based on 1X
township caps.  In fact, a weighted average of expected probability of
1X and 2X cap was used in developing the U.S. request, so the MBTOC
assumption on this issue is incorrect.  MBTOC reasons that the
availability of 1,3,-D for strawberry production will be greater than
the 1X township cap but this is by no means certain (see footnote
below).  MBTOC cites the ‘Ornamentals’ section of the nomination to
bolster their assertion.  The ‘Ornamentals’ section was in error,
and the USG thanks MBTOC for noting this discrepancy (which has now been
corrected).

Alternatives are technically and economically feasible  so a 20%
reduction for phase-in of alternatives such as 1,3-D/Pic or metam sodium
was used: alternatives can be used in areas where 1,3-D is not
appropriate

MBTOC appears to disagrees with the U.S. assessments of yield loss.

The U.S. assessments of yield loss were developed from technically
appropriate studies relevant to the specific circumstances of the U.S.
situation.  Technically appropriate studies are those which:

Included an untreated control for comparison purposes

Included information on the (key) pests present in the treated area

Give estimates of yield changes (differences)

Include methyl bromide as a standard

The U.S. nomination was restricted to those situations where ‘key’
pest pressure was moderate to severe and where these pests could not be
controlled by alternatives and, therefore, would result in yield loss.

MBTOC used what they describe, interchangeably as a “meta analysis”
or an ‘average’.  The procedure MBTOC used was not a meta analysis
in the sense thata meta analysis includes only studies which are similar
enough from a statistical standpoint that they can be combined and
analyzed as if they comprised one study, and the studies need to be
identified, appraised and summarized according to an explicit and
reproducible methodology that is designed to answer a specific research
question.  In this case, the appropriate research question would be the
performance of alternatives to methyl bromide under the conditions of
the U.S. nomination (i.e. with moderate to severe pressure from key
pests).  The null hypothesis would be that alternatives work as well as
methyl bromide in the circumstances of the U.S. nomination.  The U.S.
nomination is specifically for the use of methyl bromide where key pests
(pests not adequately controlled by alternatives to methyl bromide) are
present at moderate to severe levels and/or soil, climate, terrain, or
regulatory conditions are such that alternatives to methyl bromide
either cannot be used or result in significant economic losses when
used.  These economic losses must be of sufficient magnitude that they
render the alternative “not economically feasible”.

Although it is difficult to be certain how the MBTOC analysis was
conducted and what it includes because it has not been reviewed and
published and was not provided to the U.S. experts to evaluate, U.S.
experts were able to make some educated guesses about the analysis.  The
analysis for strawberry fruit is described in a paper is listed as being
“in press” as conference proceedings with a date after the MBTOC
recommendations on the U.S. nomination were tendered.

A version of the paper was presented by Dr. Ian Porter at the Methyl
Bromide Alternatives Organization meeting in San Diego, November 2003
and the subject of considerable controversy and questioning among
participants.  Dr. Porter’s paper included a number of papers which
U.S. experts believe are not representative of the specific conditions
included in the U.S. nomination  in determining the usefulness of
alternatives because the research was carried out under conditions of no
pest pressure.  If no pests are present any alternative, or indeed not
using any pesticide at all, will all work equally well.  By including
situations where there is no pest pressure one in effect adds (many)
“0” to the equation describing the differences in yield between
crops grown using methyl bromide and those grown using an alternative. 
This has the effect of lowering the average difference between yields
using methyl bromide and yields using an alternative.  If a sufficient
number of “0” are added, the result will be to (falsely) eliminate
the yield differences between methyl bromide and the alternative
treatments.

In other studies, pests were present but they were not the same pests
that were present in all of the U.S. circumstances.  Taking the case of
the southeastern U.S., for example, weeds, diseases, fungi, and
nematodes all infest the crops.  Some of these pests can be controlled
with alternatives, but some of the weeds, in particular nutsedges (nut
grasses), nightshades, and some hard seed coated weeds, cannot. 
Situations without weeds will show small or no yield losses when
alternatives are used while the true situation when (key) weeds are
present is that there are large yield losses.  Including these factors
has the effect of adding “0” yield difference as many times as there
are papers.

If the issue had been to average all results, describing an
“average” worldwide situation, the procedure would be correct. 
However, The U.S. submitted requests for continued methyl bromide use
only for situations with sufficiently high pest pressure (not average),
which cannot be controlled by alternatives to methyl bromide.

The U.S.  disagrees with the MBTOC assessment of yield loss in the
specific circumstances of the U.S. nomination.

Market Windows

As to the component of economic loss that is a consequence of market
timing, we believe that MBTOC has not accounted for losses arising from
market windows.

Experts are familiar with the occurrence of high prices for fresh
produce early in the season, prices which decline as the produce becomes
abundant (and more familiar) later in the season.  The U.S. has provided
marketing data documenting the existence of these market windows and
their effects on the revenue and profits earned by farmers.  Farmers
tell us that nearly all of their net revenue (approximately 90%) above
cost is earned during the short period of high prices.  For some crops,
75% of the economic loss is due to missing a market window rather than
through smaller crops, lower fruit quality, or higher costs.

Many of the alternatives will cause farmers to miss the market window. 
For some alternatives, for example, the “plant-back” interval is 2-4
weeks longer, relative to methyl bromide plant back times.  Requiring a
longer interval before a crop can be planted will delay the harvesting,
causing a farmer to miss a market window.  Some alternatives also
require a different bed preparation, which will also delay the planting
time.  The strawberry crop in California is one example of this
situation.

The main issue for drip applied fumigants is that the entire field and
irrigation equipment must be set up before you can apply the fumigants. 
Growers here have told me that this requires at least an additional 2-3
weeks longer than with broadcast fumigation.  The extension of this time
is not a serious problem on fields with short day cultivars like
Camarosa, however, it is an important problem on fields with day-neutral
cultivars like Diamonte (a majority of the acreage in the Watsonville /
Salinas area).  

On ranches crowing predominantly day-neutral (long day) cultivars the
production season overlaps with the next crops planting season, so
fields of day-neutral cultivars are typically rotated with vegetable
crops (i.e. half the ranch is planted in strawberry and the other half
is rotated out each year).  The normal cycle is strawberry (September 04
– November 05) followed by two vegetable crops (November 05 –
September 06 ) then back to strawberry (September 06 – November 07). 
The value of the October / November fruit harvests from the day-neutral
cultivars is so high that growers cannot shorten the length of their
season (not economically possible since this is when most ranches break
even and make their profit).  The need for an additional 2-3 weeks to
prepare a field for drip fumigation forces strawberry growers to take
back the land from the rotation vegetable growers 2-3 weeks earlier. 
Normally, vegetable growers can produce two crops between the strawberry
rotations.  However, the shortening of the season by 2-3 weeks would
cause result in only one vegetable crop on 80% of the land instead of
two.  Land sublease rates to vegetable growers are approximately $1000
for one crop and $1800 for two (the land leases for $2200 for full
year).  Therefore, strawberry growers would need to absorb the $800
increase in rent on 80% of their crop acreage due to the loss of one of
the two vegetable crops.     

A second issue with the transition to drip applied fumigants is the need
to setup the entire irrigation system before they fumigate.  In the
traditional production system (i.e. broadcast fumigation), growers
migrate most of their irrigation headers and other main line pipes over
from the previous season’s crop to the new after the end of that
season (in November/December/January).  However, with drip applied
fumigants growers will need two sets of this equipment, an increased
cost that is difficult for many growers to absorb.  It is difficult to
get firm prices on this but I have an estimate of $500 / acre for the
additional equipment.  Another related issue is that growers cannot use
drip applied fumigants on land that has not had strawberries on it
before due to a similar issue.  The main valves and pipes for the
irrigation system need to be setup for strawberry, and this can’t be
done while another crop is in the ground, and there is insufficient time
put this equipment in and setup for drip applied fumigation.  Growers in
this situation will have to use broadcast fumigation for the first year
on new non-strawberry ground.

Losses result not only from missing market windows but also from the
inability to plant other crops in rotation with strawberries, losing the
revenue from these crops

USG experts have examined a “Porter paper in press” and have a
number of concerns with the applying the results of this paper in the
context of the specific circumstances of the U.S. nomination.   Although
it has a ‘publication date” of one year later than the San Diego
presentation, we find thatour concerns on this issue remain the same. 
The studies used in the meta analysis are not listed and no indication
is given of the criteria used to include or exclude a study from the
analysis.

A specific requirement of the Montreal Protocol findings is that they be
made “in the circumstances of the nomination”.  There is no
indication that MBTOC considered the specific circumstances of the U.S.
nomination (which are that methyl bromide is requested only for
situations where regulatory concerns preclude use of an alternative or
where there are ‘key’ pests present at moderate to severe levels, or
where terrain conditions (temperature, topography) result in no
alternative being technically and economically feasible).  MBTOC has not
cited research findings to support their contention that alternatives
are both technically and economically feasible.The U.S. has relied upon
and presented specific results in the circumstances of the nomination to
support our request.

California

At moderate to severe pest pressure only MB can effectively control the
target pests found in California.  Uses of alternatives are limited by
regulatory restrictions such as the township caps on the amount of 1,3-D
that can be used.  MB applications in strawberries are typically made
using 67:33 or, where feasible, 57:43 mixtures with chloropicrin under
plastic mulch.  Related dosage rates of 202 kg/ha are below the
threshold in the MBTOC 2002 Report, making further reduction difficult
to achieve without compromising pest management.  

Florida

At moderate to severe pest pressure only MB can effectively control the
target pests found in Florida.  In addition, the use of alternatives are
limited in some areas because the soil overlays a vulnerable water table
(karst geography).  Finally, there are other areas where regulatory
restrictions such as mandatory buffers around inhabited structures make
alternatives infeasible.  MB applications in strawberries are typically
made using 67:33 or, where feasible, 50:50 mixtures with chloropicrin
under plastic mulch.  Related dosage rates of 202 kg/ha are below the
threshold in the MBTOC 2002 Report, making further reduction difficult
to achieve without compromising pest management.  

Southeastern U.S.

At moderate to severe pest pressure only MB can effectively control the
target pests found in the southeastern U.S.  In addition, the use of
alternatives are limited in some areas because the soil overlays a
vulnerable water table (karst geography).  Finally, there are other
areas where regulatory restrictions such as mandatory buffers around
inhabited structures make alternatives infeasible.  MB applications in
strawberries are typically made using 67:33 or, where feasible, 50:50
mixtures with chloropicrin under plastic mulch.  Related dosage rates of
202 kg/ha are below the threshold in the MBTOC 2002 Report, making
further reduction difficult to achieve without compromising pest
management.  

A requirement for obtaining a critical use exemption for methyl bromide
under the Montreal Protocol is that there are no alternatives that are
both technically and economically feasible.  In making its assessment,
MBTOC has ignored the issue of economic feasibility.  Presented below
are economic considerations for each of the regions applying for a
critical use exemption.

Table 1: Costs of Alternatives Compared to Methyl Bromide Over 3-Year
Period  TC "Table 21.1: Costs of Alternatives Compared to Methyl Bromide
Over 3-Year Period" \f F \l "1"  

Alternative	Yield*	Cost in year 1 (US$/ha)	Cost in year 2 (US$/ha)	Cost
in year 3 (US$/ha)

Methyl Bromide	100	1,248	1,248	1,248

Chloropicrin+ metam sodium	73	964	964	964

1,3-d chloropicrin	86	1,416	1,416	1,416

Metam Sodium	70	849	849	849

* As percentage of typical or 3-year average yield, compared to methyl
bromide. 

Table 2: Year 1 Gross and Net Revenue  TC "Table 22.1: Year 1 Gross and
Net Revenue" \f F \l "1"  

Year 1

Alternatives 

(as shown in question 21)	Gross revenue for last reported year

(US$/ha)	Net Revenue for last reported year 

(US$/ha)

Methyl Bromide	$29,818	$5484

Chloropicrin+ metam sodium	$20,679	$-1,716

1,3-d chloropicrin	$24,362	$702

Metam Sodium	$19,829	$-2,396



Table 3: Year 2 Gross and Net Revenue  TC "Table 22.2: Year 2 Gross and
Net Revenue" \f F \l "1"  

Year 2

Alternatives 

(as shown in question 21)	Gross revenue for last reported year

(US$/ha)	Net Revenue for last reported year 

(US$/ha)

Methyl Bromide	$29,818	$5484

Chloropicrin+ metam sodium	$20,679	$-1,716

1,3-d chloropicrin	$24,362	$702

Metam Sodium	$19,829	$-2,396



Table 4: Year 3 Gross and Net Revenue  TC "Table 22.3: Year 3 Gross and
Net Revenue" \f F \l "1"  

Year 3

Alternatives 

(as shown in question 21)	Gross revenue for last reported year

(US$/ha)	Net Revenue for last reported year 

(US$/ha)

Methyl Bromide	$29,818	$5484

Chloropicrin+ metam sodium	$20,679	$-1,716

1,3-d chloropicrin	$24,362	$702

Metam Sodium	$19,829	$-2,396



California - Table 5: Economic Impacts of Methyl Bromide Alternatives 
TC "California - Table E.1: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"  

California	Methyl Bromide	Alternative Pic+MS	Alternative 1,3-d+pic
Alternative MS

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

= Gross Revenue per Hectare (us$)	$73,683	51,099	60,173	48,999

- Operating Costs per Hectare (us$)	$60,131	55,339	58,438	54,921

= Net Revenue per Hectare (us$)	$13,552	(4,240)	(1,735)	(5,922)

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 6: Economic Impacts of Methyl Bromide Alternatives  TC
"Eastern U.S. - Table E.2: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"  

Florida	Methyl Bromide	Alternative 1,3-d+pic 

Yield Loss (%) 	0	25

   Yield per Hectare 	3,138	2,353

* Price per Unit (us$)	23.10	23.10

= Gross Revenue per Hectare (us$)	72,511	54,360

- Operating Costs per Hectare (us$)	44,459	40,795

= Net Revenue per Hectare (us$)	28,012	13,565

Loss Measures 

1. Loss per Hectare (us$)	$0	14,447

2. Loss per Kilogram of Methyl Bromide (us$)	$0	77.72

3. Loss as a Percentage of Gross Revenue (%)	0%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	52%



Eastern United States - Table 7: Economic Impacts of Methyl Bromide
Alternatives  TC "Florida - Table E.3: Economic Impacts of Methyl
Bromide Alternatives" \f F \l "1"  

Eastern United States	Methyl Bromide	Alternative Pic+MS	Alternative
1,3-d+pic	Alternative MS

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$)	29,623	30,555	31,658	30,270

= Net Revenue per Hectare (us$)	22,269	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%



Summary of Economic Feasibility

The economic analysis evaluated methyl bromide alternative control
scenarios for strawberry production of fruit in Southeastern states,
Florida, and California by comparing the economic outcomes of methyl
bromide oriented production systems to those using alternatives.   

The economic factors that most influence the feasibility of methyl
bromide alternatives for fresh market strawberry production are: (1)
yield losses, referring to reductions in the quantity produced, (2)
increased production costs, which may be due to the higher-cost of using
an alternative, additional pest control requirements, and/or resulting
shifts in other production or harvesting practices, and (3) missed
market windows due to plant back time restrictions, which also affect
the quantity and price received for the goods.

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

(1) Loss per Hectare.  For crops, this measure is closely tied to
income.  It is relatively easy to measure, but may be difficult to
interpret in isolation.

(2) Loss per Kilogram of Methyl Bromide.  This measure indicates the
nominal marginal value of methyl bromide to crop production.

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

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

(5) Operating Profit Margin.  We define operating profit margin as net
operating revenue divided by gross revenue per hectare.  This measure
would provide the best indication of the total impact of the loss of
methyl bromide to an enterprise.  Again, operating costs may be
difficult to measure and fixed costs even more difficult, therefore,
fixed costs were not included in the analysis.

These measures represent different ways to assess the economic
feasibility of methyl bromide alternatives for methyl bromide users,
strawberry farmers in this case.  Because producers (suppliers)
represent an integral part of any definition of a market, we interpret
the threshold of significant market disruption to be met if there is a
significant impact on commodity suppliers using methyl bromide.  The
economic measures provide the basis for making that determination.

Several methodological approaches will help interpret the findings.
Economic estimates were first calculated in pounds and acres and then
converted to kilograms and hectares.  Costs for alternatives are based
on market prices for the control products multiplied by the number of
pounds of active ingredient that would be applied.  Baseline costs were
based on the average number of annual applications necessary to treat
strawberry fields with methyl bromide.

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

Loss per hectare measures the value of methyl bromide based on changes
in operating costs and/or changes in yield.  Loss expressed as a
percentage of the gross revenue is based on the ratio of the revenue
loss to the gross revenue.  Likewise, for the loss as a percentage of
net revenue.  The profit margin percentage is the ratio of net revenue
to gross revenue per hectare.   The values to estimate gross revenue and
the operating costs for each alternative were derived for three
alternative fumigation scenarios for the Eastern States and California,
relative to methyl bromide: 1) metam sodium + chloropicrin; 2) 1,3-d +
chloropicrin; and 3) metam sodium.  Yield loss estimates were based on
data from the CUE’s and EPA data, as well as expert opinion.

For Florida, three scenarios were compared to the methyl bromide
baseline: 1) 1,3-D plus chloropicrin; 2) Iodomethane; and 3) Iodomethane
+ chloropicrin.  Because Iodomethane is not registered, it is not
considered a feasible alternative but the analysis is provided for
comparative purposes.

Florida

In 2002, Florida had 2,792 hectares (6,900 acres) or 100% of harvested
area treated with an average of 75 kilograms (166 pounds) of methyl
bromide per hectare (acre).  The closest chemical alternative to methyl
bromide is 1,3-D plus chloropicrin (as Telone C-35).  However, US-EPA
estimates that approximately 40% of Florida’s strawberry growing areas
overlay Karst geology, which prohibits the use of 1,3-D because of the
potential for groundwater contamination.  The use of 1,3-D also requires
a 30 m buffer around inhabited structures.  This would reduce the
strawberry producing acreage by about 10%.  Nematodes and nutsedge are
key pests in Florida strawberry controlled with methyl bromide. 
Chloropicrin is not as effective in controlling weeds as methyl bromide.
 Using chloropicrin adds to production costs through increased labor
costs for weeding and harvesting.

The least-loss scenario for Florida in the absence of methyl bromide is
for growers to use 1,3-d plus chloropicrin.  Under that scenario, yield
loss would be approximately 27%, not including increases in labor costs
for hand weeding, drip irrigation costs, or changes in market prices due
to later harvests missing early market price-premiums.  A delay in
planting occurs due to the longer plant-back interval for 1,3-d, which
means delayed harvesting.  According to U.S. Department of Agriculture
data, market prices for Florida strawberries decline approximately 18%
between December and January.  Yield and price impacts together make up
impacts on gross revenues.

Under Alternative 1  (1,3-d plus chloropicrin), the yield loss was
estimated to be 25% with operating costs in U.S. dollars per hectare of
$40,795.  The estimated net revenue was $13,565 per hectare.  The
estimated loss per hectare is estimated to be $14. The loss per kilogram
of methyl bromide in U.S. dollars is estimated to be $77.72 per
kilogram.  If growers miss the December market window, a loss of
approximately one month’s revenue would reduce grower gross revenues
by about 22% in addition to the yield loss of 25%.  

The following alternatives are presented for comparative purposes only
as the products are not registered.  Under alternative 2 (Iodomethane),
the yield loss was estimated to be 14%.  Operating costs in U.S. dollars
per hectare are $40,795.  The estimated net revenue was $21,538 per
hectare.  The loss per hectare is estimated to be $6,474. The loss per
kilogram of methyl bromide in U.S. dollars is estimated to be $34.83 per
kilogram.

Under alternative 3 (Iodomethane + chloropicrin), the yield loss was
estimated to be 30%.  Operating costs in U.S. dollars per hectare are
$40,795.  The estimated net revenue was $9,963 per hectare.  The loss
per hectare is estimated to be $18,049. The loss per kilogram of methyl
bromide in U.S. dollars is estimated to be $97.11 per kilogram.

California

In California, 1,3-D plus chloropicrin would also be the primary
replacement for methyl bromide.  California restricts total use of
1,3-D, at the local level (township cap).  Approximately 63% of
California’s strawberry areas are fumigated with methyl bromide, and
31% are fumigated with alternatives.  Approximately 15% of the
strawberry areas are on hillsides with slopes severe enough to make drip
irrigation impractical.

Increased production preparation time would delay planting in the
southern region of California and reduce the harvest period in the
northern region, leading to decreases in the prices farmers receive. 
Ground preparation between crops takes 30 days longer using 1,3-D and
chloropicrin because of the time required to prepare drip irrigation. 
According to U.S. Department of Agriculture data, market prices for
strawberries California decline 5% between January and February.  If
using the alternatives delay the harvest period, US-EPA estimates there
will be a market price decline in addition to a yield loss.  The
following paragraphs illustrate the estimated losses with three
alternatives for California.

Alternative 1 (chloropicrin+metam sodium), yield loss was estimated to
be 27%, and gross revenues are expected to decline 24%.  The estimated
net revenue is estimated to decline more than 131%.  The loss per
kilogram of methyl bromide in U.S. dollars is estimated to be $88.19 per
kilogram. 

Under alternative 2 (1,3-D plus chloropicrin), the yield loss was
estimated to be 14% and prices by 05%, if growers miss key market
windows.  Gross revenue is expected to decline 16%.  The net revenue is
expected to decline by more than 87%.  The loss per kilogram of methyl
bromide in U.S. dollars is estimated to be $58.57 per kilogram.

Under alternative 3 (metam sodium), the yield loss was estimated to be
30%, and the gross revenue loss was estimated to by 26%.  The loss per
kilogram of methyl bromide in U.S. dollars is estimated to be $96.52 per
kilogram.

Southeastern United States: 

Under Alternative 1 (chloropicrin+metam sodium), yield loss was
estimated to be 27%, with gross revenues decline 29%, and a loss in
estimated net revenue of 67%.  The loss per kilogram of methyl bromide
in U.S. dollars is estimated to be $99.49 per kilogram.   

Under alternative 2 (1,3-D + chloropicrin), the yield loss was estimated
to be 14%, with gross revenues declining 18%, and net revenues expected
to decline by 42%.  The loss per kilogram of methyl bromide in U.S.
dollars is estimated to be $62.05 per kilogram.

Under alternative 3 (Metam Sodium), the yield loss was estimated to be
30%, with gross revenues declining 31%, and net revenues expected to
decline by 73%.  The loss per kilogram of methyl bromide in U.S. dollars
is estimated to be $107.96 per kilogram. 

Note: Market price data was not available for the Eastern United States
but it is assumed that the net effect of shifting from methyl bromide to
any of the alternatives would result in additional revenue reductions
due fluctuations in market price due to changes in production and
harvesting times.

It should be noted that the applicants do not consider any alternative
to be feasible and that these estimates are an attempt to measure
potential impacts.  

use of methyl bromide can be reduced because soil pests can be
controlled with a use rate of 200kg/ha and because use of higher density
films (including VIF) will allow pest control at lower dosages.

In making this assertion MBTOC has relied on the work cited in two
papers, Fennimore et al, 2003 and Gilreath et al, 2003.  Fennimore was
contacted to determine whether, in his opinion, his work could be
appropriately used to support lower application rates.  His reply,
reproduced below, indicates that he is very uncomfortable with this
interpretation of his results. 

Technical and Economic Assessment of MBTOC/TEAP Report. 

We have not been provided by MBTOC with information on their technical
assessment of the performance of alternatives, ortheir economic
assessment on the impact of converting to alternatives.  To support the
MBTOC’s recommended change in the U.S. request citations of the
research references and economic assessments that led to the MBTOC
conclusions are needed so we can understand the justification.  The
technical references should describe the species tested, pest numbers,
concentrations, times, and commodity volumes.  Economic references
should describe the costs of converting from methyl bromide to
alternatives, the impact of higher yield losses, longer plant back
intervals, the economic feasibility if key market windows are missed,
and the economic impact of a 20% transition to alternatives including
estimates of management costs for more intensive programs and how the
impact of less reliable alternatives is calculated.   The sources of
estimates of the extent of pest pressure should describe the rationale
for using other estimates, a complete description of the questions,
species being surveyed and quantitative levels used.

U.S. 2006 nomination

In summary, the USG strongly disagrees with MBTOC’s contention that
the U.S. request can be reduced and reiterates its request for an
additional 397.597 metric tons of methyl bromide for a total of 1,918.4
metric tons of methyl bromide.

Citations

California Department of Food and Agriculture. California Agricultural
Statistics Service.

Carpenter, Janet, Lori Lynch and Tom Trout.  2001.  Township Limits on
1,3-DC will Impact Adjustment to Methyl bromide Phase-out.  California
Agriculture, Volume 55, Number 3.

Carpenter, Janet and Lori Lynch.  1999.  Impact of 1,3-D Restrictions in
California after a Ban on Methyl Bromide.  Presentation at the 1999
Annual International Conference of Methyl Bromide Alternatives and
Emissions Reductions.

Crop Profile for Strawberries in California. 1999.  United States
Department of Agriculture, 

NSF Center for Integrated Pest Management. 

Crop Profile for Strawberries in Florida.  2002.  United States
Department of Agriculture, NSF Center for Integrated Pest Management. 

Crop Profile for Strawberries in Virginia.  2000.  United States
Department of Agriculture, NSF Center for Integrated Pest Management. 

Florida Department of Agriculture and Consumer Services.  Florida
Agricultural Statistics Service.

Florida Summary of Plant Protection Regulations.  Oct. 2002.  Florida
Department of Agriculture and Consumer Services.

Furguson L. M., Ducharme D.T., Driver J.G., Louws F. J., Snelson J.D.
Alternatives to methyl bromide to control black root rot of strawberry
in North Carolina, 2001-2002. Undated.  Publication not stated or
unpublished data.  No untreated control reported.  

Gamini,S. and R.K. Nishimoto. 1987.  Propagules of purple nutsedge
(Cyperus rotundus) in soil. Weed Technol. 1:217-220.

Georgia Summary of Plant Protection Regulations.  Jan. 2000.  Georgia
Department of Agriculture.

Gilreath, J.P., J.W. Noling, and P.R. Gilreath. 1999.  Nutsedge
management with cover crop for  tomato in the absence of methyl bromide.
 Research summary., USDA Specific Cooperative Agreement 58-6617-6-013.

Holm, L.G., D.L. Plucknett, J.V. Pancho, and J.P. Herberger. 1977. The
world’s worst weeds: distribution and biology.  Honolulu, HI:
University of Hawaii Press, pp.8-24.

Legard, D., Personal communication, January 3, 2005.

Legard, D., personal communication, January 7, 2005.

Locascio S.J., Olson S.M., Chase C.A., Sinclair T.R., Dickson D.W.,
Mitchell D.J. and Chellemi D.O. 1999.  Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.  

North Carolina Department of Agriculture and Consumer Services.  North
Carolina Agricultural Statistics Service.

North Carolina Summary of Plant Protection Regulations.  Jan. 2003. 
North Carolina Department of Agriculture and Consumer Services.

Patterson, D.T. 1998.  Suppression of purple nutsedge (Cyperus rotundus)
with polyethylene film mulch. Weed Technol.12:275-280.

Shaw V.S., and Larson K.D., 1999.  A meta-analysis of Strawberry Yield
Response to Pre-plant Soil Fumigation with Combinations of Methyl
Bromide-chloropicrin and Four Alternative Systems.  HortScience
34:839-845.  

SoilZone, 1999.  Ozone Gas as a Soil Fumigant.  1998 Research Program. 
Electric Power Research Institute.

Sorenson, Kenneth A., W. Douglas Gubler, Norman C. Welch, and Craig
Osteen.  The Importance of Pesticides and Other Pest Management
Practices in U.S. Strawberry Production.  1997.  Special Funded Project
of the United States Department of Agriculture, National Agricultural
Pesticide Impact Assessment program.  Document Number 1-CA-97.

Tennessee State Department of Agriculture. Tennessee Agricultural
Statistics Service. Tennessee Summary of Plant Protection Regulations.
Apr. 2000.  Tennessee Department of Agriculture.	

Thullen, R.J. and P.E. Keeley. 1975. Yellow nutsedge sprouting and
resprouting potential. Weed Sci. 23:333-337.

Virginia Department of Agriculture and Consumer Services.  Virginia
Agricultural Statistics Service.  

Webster, T.M., A.S. Casinos, A.W. Johnson, C.C. Dowler, D.R. Sumner, and
R.L. Fery.  2001(a). Methyl bromide alternatives in a bell pepper-squash
rotation. Crop Rotation 20:605-614 

Webster, T.M. and G.E. Macdonald. 2001(b). A survey of weeds in various
crops in Georgia.  Weed Technol. 15:771-790.

Citations reviewed but not applicable  TC "Citations Reviewed but Not
Applicable" \f C \l "2"  



Southeastern Literature Citations

Benlioglu S., Boz, O., Yildiz A., Kaskavalci G., Benlioglu, K., 2002. 
Soil Solarization Options in Aydin Strawberry Without Methyl Bromide.  
Annual International Research Conference on Methyl Bromide Alternatives
and Emissions Reductions.  

Eger J.E. Efficacy of Telone Products in Florida Crops: A Seven Year
Summary.  2000. Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.  

Motis T.N., and Gilreath, J.P., 2002.  Stimulation of Nutsedge Emergence
With Chloropicrin.  Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.  

Nelsen K.A., Renner, K. A., and Penner, D., 2002. Yellow Nutsedge
(Cyperus esculentus) Control and Tuber Yield with Glyphosate and
Glufosinate.  Weed Technology 16:360-365.

Shaw V.S., and Larson K.D., 1999.  A meta-analysis of Strawberry Yield
Response to Pre-plant Soil Fumigation with Combinations of Methyl
Bromide-chloropicrin and Four Alternative Systems.  HortScience
34:839-845.  

California Studies:

Ajwa, H. Study conducted from 2001 through 2003.  Iodomethane and Iodine
-based Materials for Strawberry Production in California.  Publication
not specified, UC-Davis.   

Ajwa H., Kabir Z. and Fennimore S. Year of experiment or publication not
specified.  Drip Fumigation.  UC- Davis.

Ajwa H., Trout, T. Mueller S., Wilhelm S., Nelson S.D., Scoppe R. and
Shately D., Application of Alternative Fumigants Through Drip Irrigation
Systems.  Phytopathology 92:1349-1355.  

Browne G.T., Becherer S.T., Bhat R.G. and Lee R.C.M..  2003.  Strategies
for Management of Pytophthora on California Strawberries.  USDA-ARS,
Department of Plant Pathology UC Davis, Monterey Bay Academy Field Day. 


Duniway J.M., Status of Chemical Alternatives to Methyl Bromide for
Pre-plant Fumigation of Soil.  2002.  Phytopathology 92:1337-1343.  

Duniway J., Dopkins D. and Hao J. 2003.  Current Experiments on
Alternatives to Methyl Bromide for Strawberry.  Published for the Annual
Monterey Bay Academy Field Day.  

Fennimore S.A., and Valdez J., Study conducted in 2002 and 2003. 
Strawberry Herbicide Evaluation, Monterey Bay Academy.  UC-Davis,
Publication not specified.    

Kabir Z., Fennimore S., Ajwa H., and Roth K. Study conducted in 2001 and
2002. Chloropicrin and InlineTM Field Dose-Response Study Under VIF and
Standard Tarp: Weed Biomass and Weeding Time at Las Cuevas, CA. 
Publication not stated. 

Kabir Z., Fennimore S., Ajwa, and Roth K. Study conducted in 2002 and
2003.  The Efficacy of Agrizide and Plant Pro Alone or in Combination
with Chloropicrin on Weeds Seeds and Native Weeds at La Cuevas, CA. 
Publication not stated.  

Kabir Z., Fennimore S., Ajwa, and Roth K.  Weed Control Efficacy of Drip
and Shank Applied Iodomethane: Chloropicrin at MBA, CA 2002-3.  
Publication not specified.  

Martin F.N., Management of Root Diseases of Strawberry.  USDA-ARS
Publication not specified.  

Martin F.N., Study conducted in 2002.  The Use of Remote Sensing in
Strawberry Production.  Publication unspecified.  

Martin F.N., and Bull D.T., Biological Approaches for Control of Root
Pathogens of Strawberry.  Phytopathology 92:1356-1362.

Noling J. W. The Practical Realities of Alternatives to Methyl Bromide:
Concluding Remarks.  Presented at the Methyl Bromide Alternatives -
Meeting the Deadlines Symposium.  2002.  Published in Phytopathology
92:1373-1375.  

Subbarao K.V. Methyl Bromide Alternatives - Meeting the Deadlines. 
Presented at the 92nd Annual Meeting of the American Phytopathological
Society, Augus 14, 2000.  Accepted for publication by the American
Phytopathological Society on 23 July 2002.   

Trout, T. and Gartung J., 2003. Irrigation Water Requirements for
California Strawberries.  Not used, neither methyl bromide nor
alternatives were evaluated, just water requirements. Publication
unspecified.

Yates S.R., Gan J. Papiernik S.K. Dungan R. and Wang D.  Reducing
Fumigant Emissions After Soil Application.  2002.  Phytopathology
92:1344-1348.  

 In practice, the weights applied were 1/3 of the 2X cap and 2/3 of the
1X cap.  In the current judgment of USG experts this places too much
likelihood on an increased township cap.  In repeated conversations with
State of California pesticide regulators, USG has been given no
indication that the township caps would be raised beyond the temporary
increase in the cap except as negotiated in individual agreements.  In
order to be eligible for an increased cap amount under these agreements,
a township must have an unused (banked) amount available to increase the
cap.  As the program currently stands, only townships with banked
amounts can increase their use of 1,3-D above the 1X cap.  As townships
exceed the 1X cap they lose their ability to increase the caps by
depleting their ‘banked’ amount.

 In the judgment of U.S. experts pressure was such that yield losses of
the magnitude of those used in the economic assessment would be
sustained.

 The U.S. requested  two of the authors of the paper for references so
that the studies included could be evaluated against the circumstances
of the U.S. nomination, but to date the  references have not been
provided. 

 Some of this material with references had been previously presented at
the Methyl Bromide Alternatives Organization 2003 meeting (San Diego). 
At that time U.S. experts expressed their view that many if not most of
the studies were not an appropriate application of the information.

 For example, some trials are used for residue tests.  These tests are
likely to be carried out in conditions of little or no pest pressure in
order to have enough harvested fruit to to test for residue.  The Porter
paper does not indicate which of the studies that were used (but not
cited) were for the purposes of examining pesticide residues.

 The actual procedure was to add in yields expressed as a percentage of
(anticipated) yield using methyl bromide.  How this yield was estimated
is puzzling as many of the studies did not include a methyl bromide
control.  Because there was no indication of pest pressure in many
instances, many of the entries indicated yields of approximately 100%,
obviating the differences between methyl bromide and the alternatives.

 So, for example, studies conducted in California, where there is less
pressure for weeds will not give an accurate picture of the situation in
the southeastern U.S. where nutsedge, nightshades, and hard seed-coated
weeds are a major problem.

 Daniel Legard, PhD, personal communication, January 3, 2005.

 Porter,I., S. Mattner, R. Mann, R. Gounder, J. Banks, and P. Fraser.
1994. Strawberry Fruit Production and results from trials in Different
Geographic Regions.  A Presentation to the Methyl Bromide Alternatives
Conference, Lisbon, September 1994.

 From: 		 Steven Fennimore [mailto:safennimore@ucdavis.edu]

Sent:		 Fri Jan 07 16:24:43 2005

To:		 Dan Legard

Cc:		 jmduniway@ucdavis.edu; haajwa@ucdavis.edu

Subject:		 MBTOC VIF stance

Hi Dan

I am a bit disturbed to learn from you that the some in MBTOC may have 

come to the conclusion that VIF will allow reduced rates of methyl 

bromide.  While I stand behind my research that indicates clearly that 

the weed control efficacy of drip-applied chloropicrin and Inline are 

improved under VIF compared to standard film, these fumigants are used
to 

control many other pests besides weeds.  For example, results do not 

necessarily suggest that VIF improves phytopthora cactorum control.  Our


research results presented at MBAO are preliminary and we are currently 

preparing peer reviewed publications.  When those are written we will 

have a more clear understanding of the potential benefits and
limitations 

of VIF than we have now.  I do believe that VIF offers real potential 

benefits, however I caution anyone to make policy decisions about VIF 

based on my preliminary results presented at MBAO

Steve Fennimore

Extension Specialist

University of California, Davis

1636 East Alisal St

Salinas, CA 93905

831-755-2896

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