Methyl Bromide Critical Use Nomination for Preplant Soil Use for Orchard
Replant

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                              CUN:



Nominating Party:	The United States of America

Brief Descriptive Title of Nomination:	Methyl Bromide Critical Use
Nomination for Preplant Soil Use for Orchard Replant (Submitted in 2006
for 2008 Use Season)



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:	Richard Keigwin

Title:	Acting 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) 308-8200

Fax:	(703) 308-8090

E-mail:	Keigwin.Richard@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 "_Toc125443729"  Part A: Summary	 
PAGEREF _Toc125443729 \h  10  

  HYPERLINK \l "_Toc125443730"  1. Nominating Party	  PAGEREF
_Toc125443730 \h  10  

  HYPERLINK \l "_Toc125443731"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125443731 \h  10  

  HYPERLINK \l "_Toc125443732"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125443732 \h  10  

  HYPERLINK \l "_Toc125443733"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125443733 \h  11  

  HYPERLINK \l "_Toc125443734"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125443734 \h  11  

  HYPERLINK \l "_Toc125443735"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125443735 \h  13  

  HYPERLINK \l "_Toc125443736"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125443736 \h  13  

  HYPERLINK \l "_Toc125443737"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125443737 \h  15  

  HYPERLINK \l "_Toc125443738"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125443738 \h  15  

  HYPERLINK \l "_Toc125443739"  California Grape and Tree Fruit League
– Stone Fruit - Part B: Crop Characteristics and Methyl Bromide Use	 
PAGEREF _Toc125443739 \h  16  

  HYPERLINK \l "_Toc125443740"  California Grape and Tree Fruit League
– Stone Fruit - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request	  PAGEREF _Toc125443740
\h  16  

  HYPERLINK \l "_Toc125443741"  California Grape and Tree Fruit League
– Stone Fruit - 11. Characteristics of Cropping System and Climate	 
PAGEREF _Toc125443741 \h  16  

  HYPERLINK \l "_Toc125443742"  California Grape and Tree Fruit League
– Stone Fruit - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested	
 PAGEREF _Toc125443742 \h  18  

  HYPERLINK \l "_Toc125443743"  California Grape and Tree Fruit League
– Stone Fruit - Part C: Technical Validation	  PAGEREF _Toc125443743
\h  19  

  HYPERLINK \l "_Toc125443744"  California Grape and Tree Fruit League
– Stone Fruit - 13. Reason for Alternatives Not Being Feasible	 
PAGEREF _Toc125443744 \h  19  

  HYPERLINK \l "_Toc125443745"  California Grape and Tree Fruit League
– Stone Fruit - 14. List and Discuss Why Registered (and Potential)
Pesticides and Herbicides Are Considered Not Effective as Technical
Alternatives to Methyl Bromide:	  PAGEREF _Toc125443745 \h  21  

  HYPERLINK \l "_Toc125443746"  California Grape and Tree Fruit League
– Stone Fruit - 15. List Present (and Possible Future) Registration
Status of Any Current and Potential Alternatives	  PAGEREF _Toc125443746
\h  21  

  HYPERLINK \l "_Toc125443747"  California Grape and Tree Fruit League
– Stone Fruit - 16. State Relative Effectiveness of Relevant
Alternatives Compared to Methyl Bromide for the Specific Key Target
Pests and Weeds for which It Is Being Requested	  PAGEREF _Toc125443747
\h  22  

  HYPERLINK \l "_Toc125443748"  California Grape and Tree Fruit League
– Stone Fruit - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?	 
PAGEREF _Toc125443748 \h  23  

  HYPERLINK \l "_Toc125443749"  California Grape and Tree Fruit League
– Stone Fruit - 18. Are There Technologies Being Used to Produce the
Crop which Avoid the Need for Methyl Bromide?	  PAGEREF _Toc125443749 \h
 23  

  HYPERLINK \l "_Toc125443750"  California Grape and Tree Fruit League
– Stone Fruit - Summary of Technical Feasibility	  PAGEREF
_Toc125443750 \h  24  

  HYPERLINK \l "_Toc125443751"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Part B: Crop Characteristics and Methyl
Bromide Use	  PAGEREF _Toc125443751 \h  25  

  HYPERLINK \l "_Toc125443752"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 10. Key Diseases and Weeds for which Methyl
Bromide Is Requested and Specific Reasons for this Request	  PAGEREF
_Toc125443752 \h  25  

  HYPERLINK \l "_Toc125443753"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 11. Characteristics of Cropping System and
Climate	  PAGEREF _Toc125443753 \h  25  

  HYPERLINK \l "_Toc125443754"  California Grape and Tree Fruit
League—Raisin & Table Grapes.  11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125443754 \h  26  

  HYPERLINK \l "_Toc125443755"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 12. Historic Pattern of Use of Methyl
Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125443755 \h  26  

  HYPERLINK \l "_Toc125443756"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Part C: Technical Validation	  PAGEREF
_Toc125443756 \h  28  

  HYPERLINK \l "_Toc125443757"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 13. Reason for Alternatives Not Being
Feasible	  PAGEREF _Toc125443757 \h  28  

  HYPERLINK \l "_Toc125443758"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:	  PAGEREF _Toc125443758 \h  30
 

  HYPERLINK \l "_Toc125443759"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 15. List Present (and Possible Future)
Registration Status of Any Current and Potential Alternatives	  PAGEREF
_Toc125443759 \h  30  

  HYPERLINK \l "_Toc125443760"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 16. State Relative Effectiveness of Relevant
Alternatives Compared to Methyl Bromide for the Specific Key Target
Pests and Weeds for which It Is Being Requested	  PAGEREF _Toc125443760
\h  31  

  HYPERLINK \l "_Toc125443761"  California Grape and Tree Fruit League
– Raisin & Table Grapes - 17. Are There Any Other Potential
Alternatives Under Development which Are Being Considered to Replace
Methyl Bromide?	  PAGEREF _Toc125443761 \h  33  

  HYPERLINK \l "_Toc125443762"  California Grape and Tree Fruit
League—Raisin & Table Grapes. 18. Are There Technologies Being Used to
Produce the Crop which Avoid the Need for Methyl Bromide?	  PAGEREF
_Toc125443762 \h  33  

  HYPERLINK \l "_Toc125443763"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Summary of Technical Feasibility	  PAGEREF
_Toc125443763 \h  33  

  HYPERLINK \l "_Toc125443764"  Central California Winegrowers – Wine
Grapes - Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125443764 \h  34  

  HYPERLINK \l "_Toc125443765"  Central California Winegrowers – Wine
Grapes - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request	  PAGEREF _Toc125443765
\h  34  

  HYPERLINK \l "_Toc125443766"  Central California Winegrowers – Wine
Grapes - 11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125443766 \h  34  

  HYPERLINK \l "_Toc125443767"  Central California Winegrowers – Wine
Grapes - 11. Characteristics That Prevent Uptake of Relevant
Alternatives	  PAGEREF _Toc125443767 \h  35  

  HYPERLINK \l "_Toc125443768"  Central California Winegrowers –Wine
Grapes - 12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125443768 \h  36  

  HYPERLINK \l "_Toc125443769"  Central California Winegrowers – Wine
Grapes - Part C: Technical Validation	  PAGEREF _Toc125443769 \h  36  

  HYPERLINK \l "_Toc125443770"  Central California Winegrowers –Wine
Grapes 13. Reason for Alternatives Not Being Feasible	  PAGEREF
_Toc125443770 \h  36  

  HYPERLINK \l "_Toc125443771"  Central California Winegrowers –Wine
Grapes - 14. List and Discuss Why Registered (and Potential) Pesticides
and Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:	  PAGEREF _Toc125443771 \h  39  

  HYPERLINK \l "_Toc125443772"  Central California Winegrowers –Wine
Grapes - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives	  PAGEREF _Toc125443772 \h  39  

  HYPERLINK \l "_Toc125443773"  Central California Winegrowers –Wine
Grapes - 16. State Relative Effectiveness of Relevant Alternatives
Compared to Methyl Bromide for the Specific Key Target Pests and Weeds
for which It Is Being Requested	  PAGEREF _Toc125443773 \h  40  

  HYPERLINK \l "_Toc125443774"  Central California Winegrowers –Wine
Grapes - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?	 
PAGEREF _Toc125443774 \h  41  

  HYPERLINK \l "_Toc125443775"  Central California Winegrowers –Wine
Grapes - 17. Are There Technologies Being Used to Produce the Crop Which
Avoid the Need for Methyl Bromide?	  PAGEREF _Toc125443775 \h  42  

  HYPERLINK \l "_Toc125443776"  Central California Winegrowers –Wine
Grapes - Summary of Technical Feasibility	  PAGEREF _Toc125443776 \h  42
 

  HYPERLINK \l "_Toc125443777"  California Walnut Commission. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125443777 \h 
43  

  HYPERLINK \l "_Toc125443778"  California Walnut Commission - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125443778 \h  43  

  HYPERLINK \l "_Toc125443779"  California Walnut Commission - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125443779
\h  43  

  HYPERLINK \l "_Toc125443780"  California Walnut Commission.  11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125443780 \h  44  

  HYPERLINK \l "_Toc125443781"  California Walnut Commission - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125443781 \h  45  

  HYPERLINK \l "_Toc125443782"  California Walnut Commission - Part C:
Technical Validation	  PAGEREF _Toc125443782 \h  45  

  HYPERLINK \l "_Toc125443783"  California Walnut Commission - 13.
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125443783 \h 
45  

  HYPERLINK \l "_Toc125443784"  California Walnut Commission - 14. List
and Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:	 
PAGEREF _Toc125443784 \h  48  

  HYPERLINK \l "_Toc125443785"  California Walnut Commission - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125443785 \h  48  

  HYPERLINK \l "_Toc125443786"  California Walnut Commission - 16. State
Relative Effectiveness of Relevant Alternatives Compared to Methyl
Bromide for the Specific Key Target Pests and Weeds for which It Is
Being Requested	  PAGEREF _Toc125443786 \h  48  

  HYPERLINK \l "_Toc125443787"  California Walnut Commission - 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125443787 \h  49  

  HYPERLINK \l "_Toc125443788"  California Walnut Commission. 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?	  PAGEREF _Toc125443788 \h  49  

  HYPERLINK \l "_Toc125443789"  California Walnut Commission - Summary
of Technical Feasibility	  PAGEREF _Toc125443789 \h  50  

  HYPERLINK \l "_Toc125443790"  Almond Hullers & Processors Association
- Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125443790 \h  50  

  HYPERLINK \l "_Toc125443791"  Almond Hullers & Processors Association
- 10. Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request	  PAGEREF _Toc125443791 \h  50  

  HYPERLINK \l "_Toc125443792"  Almond Hullers & Processors Association
- 11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125443792 \h  51  

  HYPERLINK \l "_Toc125443793"  Almond Hullers & Processors Association.
 11. (ii) Indicate if any of the above characteristics in 11. (i)
prevent the uptake of any relevant alternatives?	  PAGEREF _Toc125443793
\h  52  

  HYPERLINK \l "_Toc125443794"  Almond Hullers & Processors Association
- 12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125443794 \h  53  

  HYPERLINK \l "_Toc125443795"  Almond Hullers & Processors Association
- Part C: Technical Validation	  PAGEREF _Toc125443795 \h  54  

  HYPERLINK \l "_Toc125443796"  Almond Hullers & Processors Association
- 13. Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125443796
\h  54  

  HYPERLINK \l "_Toc125443797"  Almond Hullers & Processors Association
- 14. List and Discuss Why Registered (and Potential) Pesticides and
Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:	  PAGEREF _Toc125443797 \h  56  

  HYPERLINK \l "_Toc125443798"  Almond Hullers & Processors Association
- 15. List Present (and Possible Future) Registration Status of Any
Current and Potential Alternatives	  PAGEREF _Toc125443798 \h  56  

  HYPERLINK \l "_Toc125443799"  Almond Hullers & Processors Association
- 16. State Relative Effectiveness of Relevant Alternatives Compared to
Methyl Bromide for the Specific Key Target Pests and Weeds for which It
Is Being Requested	  PAGEREF _Toc125443799 \h  57  

  HYPERLINK \l "_Toc125443800"  Almond Hullers & Processors Association
- 17. Are There Any Other Potential Alternatives Under Development which
Are Being Considered to Replace Methyl Bromide?	  PAGEREF _Toc125443800
\h  58  

  HYPERLINK \l "_Toc125443801"  Almond Hullers & Processors Association
- 18. Are There Technologies Being Used to Produce the Crop which Avoid
the Need for Methyl Bromide?	  PAGEREF _Toc125443801 \h  59  

  HYPERLINK \l "_Toc125443802"  Almond Hullers & Processors Association
- Summary of Technical Feasibility	  PAGEREF _Toc125443802 \h  59  

  HYPERLINK \l "_Toc125443803"  Part D: Emission Control	  PAGEREF
_Toc125443803 \h  60  

  HYPERLINK \l "_Toc125443804"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125443804 \h  60  

  HYPERLINK \l "_Toc125443805"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125443805 \h  61  

  HYPERLINK \l "_Toc125443806"  Part E: Economic Assessment	  PAGEREF
_Toc125443806 \h  61  

  HYPERLINK \l "_Toc125443807"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125443807 \h  61  

  HYPERLINK \l "_Toc125443808"  22. Gross and Net Revenue	  PAGEREF
_Toc125443808 \h  61  

  HYPERLINK \l "_Toc125443809"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125443809 \h  62  

  HYPERLINK \l "_Toc125443810"  Summary of Economic Feasibility	 
PAGEREF _Toc125443810 \h  62  

  HYPERLINK \l "_Toc125443811"  Part F. Future Plans	  PAGEREF
_Toc125443811 \h  63  

  HYPERLINK \l "_Toc125443812"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125443812 \h  63  

  HYPERLINK \l "_Toc125443813"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125443813 \h  64  

  HYPERLINK \l "_Toc125443814"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125443814 \h  64  

  HYPERLINK \l "_Toc125443815"  26. Citations	  PAGEREF _Toc125443815 \h
 65  

  HYPERLINK \l "_Toc125443816"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125443816 \h  67  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125443579"  Part A:
Summary	  PAGEREF _Toc125443579 \h  10  

  HYPERLINK \l "_Toc125443580"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125443580 \h  11  

  HYPERLINK \l "_Toc125443581"  Table A.1: Executive Summary	  PAGEREF
_Toc125443581 \h  13  

  HYPERLINK \l "_Toc125443582"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125443582 \h  13  

  HYPERLINK \l "_Toc125443583"  Table 8.1: Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125443583 \h  15  

  HYPERLINK \l "_Toc125443584"  California Grape and Tree Fruit League
– Stone Fruit - Part B: Crop Characteristics and Methyl Bromide Use	 
PAGEREF _Toc125443584 \h  16  

  HYPERLINK \l "_Toc125443585"  California Grape and Tree Fruit League
– Stone Fruit - Table 10.1: Key Diseases and Weeds and Reason for
Methyl Bromide Request	  PAGEREF _Toc125443585 \h  16  

  HYPERLINK \l "_Toc125443586"  California Grape and Tree Fruit League
– Stone Fruit - Table 11.1: Characteristics of Cropping System	 
PAGEREF _Toc125443586 \h  17  

  HYPERLINK \l "_Toc125443587"  California Grape and Tree Fruit League
– Stone Fruit - Table 11.2 Characteristics of Climate and Crop
Schedule	  PAGEREF _Toc125443587 \h  17  

  HYPERLINK \l "_Toc125443588"  California Grape and Tree Fruit League
– Stone Fruit - Table 12.1 Historic Pattern of Use of Methyl Bromide	 
PAGEREF _Toc125443588 \h  18  

  HYPERLINK \l "_Toc125443589"  California Grape and Tree Fruit League
– Stone Fruit  - Part C: Technical Validation	  PAGEREF _Toc125443589
\h  19  

  HYPERLINK \l "_Toc125443590"  California Grape and Tree Fruit League
– Stone Fruit – Table 13.1: Reason for Alternatives Not Being
Feasible	  PAGEREF _Toc125443590 \h  19  

  HYPERLINK \l "_Toc125443591"  California Grape and Tree Fruit League
– Stone Fruit – Table 14.1: Technically Infeasible Alternatives
Discussion	  PAGEREF _Toc125443591 \h  21  

  HYPERLINK \l "_Toc125443592"  California Grape and Tree Fruit League
– Stone Fruit – Table 15.1: Present Registration Status of
Alternatives	  PAGEREF _Toc125443592 \h  21  

  HYPERLINK \l "_Toc125443593"  California Grape and Tree Fruit League
– Stone Fruit – Table 16.1: Effectiveness of Alternatives –
Replant Disorder	  PAGEREF _Toc125443593 \h  22  

  HYPERLINK \l "_Toc125443594"  California Grape and Tree Fruit League
– Stone Fruit – Table C.1: Alternatives Yield Loss Data Summary	 
PAGEREF _Toc125443594 \h  23  

  HYPERLINK \l "_Toc125443595"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Part B: Crop Characteristics and Methyl
Bromide Use	  PAGEREF _Toc125443595 \h  25  

  HYPERLINK \l "_Toc125443596"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request	  PAGEREF _Toc125443596 \h  25  

  HYPERLINK \l "_Toc125443597"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Table 11.1: Characteristics of Cropping
System	  PAGEREF _Toc125443597 \h  26  

  HYPERLINK \l "_Toc125443598"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Table 11.2 Characteristics of Climate and
Crop Schedule	  PAGEREF _Toc125443598 \h  26  

  HYPERLINK \l "_Toc125443599"  California Grape and Tree Fruit League
– Raisin & Table Grapes - Table 12.1 Historic Pattern of Use of Methyl
Bromide	  PAGEREF _Toc125443599 \h  27  

  HYPERLINK \l "_Toc125443600"  California Grape and Tree Fruit League
– Raisin & Table Grapes  - Part C: Technical Validation	  PAGEREF
_Toc125443600 \h  28  

  HYPERLINK \l "_Toc125443601"  California Grape and Tree Fruit League
– Raisin & Table Grapes – Table 13.1: Reason for Alternatives Not
Being Feasible	  PAGEREF _Toc125443601 \h  28  

  HYPERLINK \l "_Toc125443602"  California Grape and Tree Fruit League
– Raisin & Table Grapes – Table 15.1: Present Registration Status of
Alternatives	  PAGEREF _Toc125443602 \h  30  

  HYPERLINK \l "_Toc125443603"  California Grape and Tree Fruit League
– Raisin & Table Grapes – Table 16.1: Effectiveness of Alternatives
– Replant Disorder (Nematodes)	  PAGEREF _Toc125443603 \h  31  

  HYPERLINK \l "_Toc125443604"  California Grape and Tree Fruit League
– Raisin & Table Grapes – Table C.1: Alternatives Yield Loss Data
Summary	  PAGEREF _Toc125443604 \h  32  

  HYPERLINK \l "_Toc125443605"  Central California Winegrowers – Wine
Grapes - Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125443605 \h  34  

  HYPERLINK \l "_Toc125443606"  Central California Winegrowers – Wine
Grapes - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request	  PAGEREF _Toc125443606 \h  34  

  HYPERLINK \l "_Toc125443607"  Central California Winegrowers – Wine
Grapes - Table 11.1: Characteristics of Cropping System	  PAGEREF
_Toc125443607 \h  35  

  HYPERLINK \l "_Toc125443608"  Central California Winegrowers – Wine
Grapes - Table 11.2 Characteristics of Climate and Crop Schedule	 
PAGEREF _Toc125443608 \h  35  

  HYPERLINK \l "_Toc125443609"  Central California Winegrowers –Wine
Grapes - Table 12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF
_Toc125443609 \h  36  

  HYPERLINK \l "_Toc125443610"  Central California Winegrowers – Wine
Grapes  - Part C: Technical Validation	  PAGEREF _Toc125443610 \h  36  

  HYPERLINK \l "_Toc125443611"  Central California Winegrowers –Wine
Grapes – Table 13.1: Reason for Alternatives Not Being Feasible	 
PAGEREF _Toc125443611 \h  37  

  HYPERLINK \l "_Toc125443612"  Central California Winegrowers –Wine
Grapes – Table 15.1: Present Registration Status of Alternatives	 
PAGEREF _Toc125443612 \h  39  

  HYPERLINK \l "_Toc125443613"  Central California Winegrowers –Wine
Grapes – Table 16.1: Effectiveness of Alternatives – Replant
Disorder (Nematodes)	  PAGEREF _Toc125443613 \h  40  

  HYPERLINK \l "_Toc125443614"  Central California Winegrowers –Wine
Grapes – Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF
_Toc125443614 \h  41  

  HYPERLINK \l "_Toc125443615"  California Walnut Commission  - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125443615 \h 
43  

  HYPERLINK \l "_Toc125443616"  California Walnut Commission - Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request	 
PAGEREF _Toc125443616 \h  43  

  HYPERLINK \l "_Toc125443617"  California Walnut Commission - Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125443617 \h  44 


  HYPERLINK \l "_Toc125443618"  California Walnut Commission - Table
11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125443618 \h  44  

  HYPERLINK \l "_Toc125443619"  California Walnut Commission - Table
12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125443619
\h  45  

  HYPERLINK \l "_Toc125443620"  California Walnut Commission  - Part C:
Technical Validation	  PAGEREF _Toc125443620 \h  45  

  HYPERLINK \l "_Toc125443621"  California Walnut Commission – Table
13.1: Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125443621
\h  46  

  HYPERLINK \l "_Toc125443622"  California Walnut Commission – Table
14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125443622 \h  48  

  HYPERLINK \l "_Toc125443623"  California Walnut Commission – Table
15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125443623 \h  48  

  HYPERLINK \l "_Toc125443624"  California Walnut Commission – Table
16.1: Effectiveness of Alternatives – Key Pest 1	  PAGEREF
_Toc125443624 \h  48  

  HYPERLINK \l "_Toc125443625"  California Walnut Commission – Table
C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125443625 \h  49
 

  HYPERLINK \l "_Toc125443626"  Almond Hullers & Processors Association
- Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125443626 \h  50  

  HYPERLINK \l "_Toc125443627"  Almond Hullers & Processors Association
- Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide
Request	  PAGEREF _Toc125443627 \h  51  

  HYPERLINK \l "_Toc125443628"  Almond Hullers & Processors Association
- Table 11.1: Characteristics of Cropping System	  PAGEREF _Toc125443628
\h  52  

  HYPERLINK \l "_Toc125443629"  Almond Hullers & Processors Association
- Table 11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125443629 \h  52  

  HYPERLINK \l "_Toc125443630"  Almond Hullers & Processors Association
- Table 12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF
_Toc125443630 \h  53  

  HYPERLINK \l "_Toc125443631"  Almond Hullers & Processors Association
- Part C: Technical Validation	  PAGEREF _Toc125443631 \h  54  

  HYPERLINK \l "_Toc125443632"  Almond Hullers & Processors Association
– Table 13.1: Reason for Alternatives Not Being Feasible	  PAGEREF
_Toc125443632 \h  54  

  HYPERLINK \l "_Toc125443633"  Almond Hullers & Processors Association
– Table 14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125443633 \h  56  

  HYPERLINK \l "_Toc125443634"  Almond Hullers & Processors Association
– Table 15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125443634 \h  56  

  HYPERLINK \l "_Toc125443635"  Almond Hullers & Processors Association
– Table 16.1: Effectiveness of Alternatives – Replant Disorder	 
PAGEREF _Toc125443635 \h  57  

  HYPERLINK \l "_Toc125443636"  Almond Hullers & Processors Association
– Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF
_Toc125443636 \h  57  

  HYPERLINK \l "_Toc125443637"  Part D: Emission Control	  PAGEREF
_Toc125443637 \h  60  

  HYPERLINK \l "_Toc125443638"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125443638 \h  60  

  HYPERLINK \l "_Toc125443639"  Part E: Economic Assessment	  PAGEREF
_Toc125443639 \h  61  

  HYPERLINK \l "_Toc125443640"  Part F. Future Plans	  PAGEREF
_Toc125443640 \h  63  

 

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



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

The United States of America

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 Orchard
Replant (Prepared in 2005 for the 2008 Use Season)

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

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

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

4. Methyl Bromide Nominated  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)

2008

	405,666	1,225

* Includes research amoun of 1,658 kgt, See Appendix A for complete
description of how the nominated amount was calculated.

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 United States (U.S.) Nomination for orchard replant is for areas
where alternatives are not suitable, either because of legal
restrictions or physical features, such as unacceptable soil type or
moisture.  For many sites of orchard replant with stone fruit, grapes,
walnuts, and almonds in California, MeBr is a critical tool for
establishing healthy, long lived orchards.  Where conditions are
acceptable, growers in California currently use alternative measures to
manage orchard replant disorder (Browne et al., 2002b; McKenry, 1999).

In U.S. orchard replant situations there are certain factors that make
some alternatives to MeBr unsuitable.  These include:

The efficacy of alternatives may not be sufficient for commercial
purposes in some areas, making these alternatives infeasible for use in
orchard replant.

Some alternatives may be comparable to MB, especially when key pests
occur at low pressure, and in such cases the U.S. is only nominating a
CUE where the key pest pressure is moderate to high. 

Regulatory constraints, such as 1,3-D limitations in California due to
the township caps, make the best alternatives unavailable in some areas.

The best alternative may not be suitable for use in certain soil
conditions, such as excessive moisture 1-1.5 m deep.

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

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

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

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

Prior to 1990, 1,3-D was considered at least as effective as, and more
economical than, MeBr for treatment of replant problem (McKenry, 1999). 
However, due to environmental and health concerns (it is a B2 carcinogen
and was found off of treatment sites), 1,3-D was banned, and MeBr became
the predominant treatment for orchard replant.  With the re-labeling of
1,3-D in the mid-1990s there were new restrictions on its use and
application, including township caps in California.  The reduced rates
were considered ineffective for some severe replant situations (reduced
to 325 kg/ha from 427 kg/ha).  MB, therefore, remains the standard for
the industry when establishing nearly all of California’s orchards,
except in those with light soils and with appropriate moisture
conditions, where lower rates of 1,3-D can be effective (McKenry, 1999).
 [Each township is allowed a maximum of approximately 41,000 kg per
year, in a township of approximately 9300 ha; at 225 kg/ha, 180 ha can
be treated with 1,3-D per township.]

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

Region	California Grape and Tree Fruit League—Stone Fruit	California
Grape and Tree Fruit League—Raisin & Table Grapes	Central California
Winegrowers	California Walnut Commission	Almond Hullers & Processors
Association

Amount of Applicant Request 

2008 Kilograms	716,449	309,460	97,988	226,796	206,384

Amount of Nomination*

2008 Kilograms	248,724	17,034	43,186	35,268	59,795

*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"  :

The best alternative for orchard replant that has been identified thus
far is 1,3-D or 1,3-D with chloropicrin, and/or metam-sodium, especially
in light soils.  Under some soil and moisture conditions (high moisture
at surface and less than 12% at 1-1.5 meters) 1,3-D can act as an
effective management tool for replant problems.  However, for 2008,
there is a critical need for MeBr in some orchards in California, either
because of legally mandated township caps for 1,3-D, or because surface
moisture requirements can not be met (e.g., soils can not be adequately
dried prior to use of 1,3-D).  

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	Average Total replant area
in 2001 and 2002 (ha) 

[area of MeBr use/total area replanted per year]	Proportion of total
replant area treated with methyl bromide per 2001/2002 year (%)

California Grape and Tree Fruit League—Stone Fruit	5,587 (2005 est.)

(93,117 ha total x 6%)	20% (1,116/5,587)

California Grape and Tree Fruit League—Raisin & Table Grapes	4,219
(2005 est.)

(14,065 ha total x 3%)	2% (82/4,219)

Central California Winegrowers—Wine Grapes	4,676 (2005 est.)

(total 66,802 ha total x 7% replanted)	9% (421/4,676) (based on 2005
request—reported CDPR data may not be accurate)

California Walnut Commission	1851

(83,806 ha total bearing)	(810 ha requested) 75% of replant may be strip
treated—50% of this use MB; 12.5% of replant use no fumigation 

Almond Hullers & Processors Association	6,119

(202,429 ha total x 3%) replanted) 	4% (266/6,119) (65% may be strip
treated)

National Total:	Not available

	

7. (ii) If only part of the crop area is treated with methyl bromide,
indicate the reason why methyl bromide is not used in the other area,
and identify what alternative strategies are used to control the target
pathogens and weeds without methyl bromide there.

Some areas of California amenable to these crops have soil types and
moisture characteristics that allow the use of alternative treatments. 
1,3-D with chloropicrin is an effective alternative to MeBr in areas
with soils that contain less than 12% moisture at 1.5 meters and can be
sufficiently moistened in the top 30 cm.  Areas considered in this
nomination have either regulatory or other reasons (e.g., soil type)
that prevent alternatives being effective in successfully managing
replant problem.  

As an example, the Central California Winegrowers represent growers in
eight counties with approximately 165,000 acres of wine grapes.  Each
year, approximately 7% of the total area is replanted.  Of this,
approximately 15% is fumigated, and of the fumigated land approximately
60% is treated with MB.  Therefore, 85% of the replanted vineyards use
other means besides fumigation, and of the fumigated land, 40% use
alternatives to MB.  The proportion of land that is treated with MeBr is
relatively small.  Other growers in this sector experience similar
situations, with varying percentages of MeBr use on replanted land. 
Stone fruit are most susceptible to orchard problems, and therefore a
larger proportion of land is treated with MB.  In general, the portion
that is being requested for treatment with MeBr for 2008, is for soil
types or terrain that are not amenable to 1,3-D use.  

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?

Depending on the crop and the economic market when new orchards are
established, between 9% and 60% of replanted areas will require MeBr for
2008.  The balance of land planted to each of the five crops of this
sector will use other means of pest management.  Because research
continues to define effective alternatives (e.g., Browne et al., 2004;
Lampinen et al., 2004; Schneider et al., 2004), it may be possible to
adopt some alternatives by improving application technologies in
conjunction with crop rotation, fallow, rootstock, or use of VIF (use is
regulated in California).  MeBr is critical for the 2008 replant season
for the areas not currently amenable to treatment with alternatives to
MB.

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



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

Region 	California Grape and Tree Fruit League—Stone Fruit	California
Grape and Tree Fruit League—Raisin & Table Grapes	Central California
Winegrowers—Wine Grapes	California Walnut Commission	Almond Hullers &
Processors Association

Year of Exemption Request	2008	2008	2008	2008	2008

Kilograms of Methyl Bromide	716,449	309,460	91,988	226,796	206,384

Use: Flat Fumigationa or Strip/Bed Treatment	Many orchards treated by
strip fumigation (65% of area is treated)	Strip or broadcast fumigation
Usually strip fumigation (65% of area is treated)	Many orchards treated
by strip fumigation—75% of replant may be strip fumigated	Many
orchards treated by strip fumigation (65% of area is treated))

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

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (ha)	3,278	809	255	809	567

Application rate (kg/ha) [Active Ingredient]	336	382	360	280	364

Dosage rate* (g/m2) of Active Ingredient on treated land	33.6 (on strip
treated land)	38.2	36.0 (on strip treated land)	28.0 (on strip treated
land)	36.4 (on strip treated land)

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

a Various methods are used depending on the particular location,
fumigation can be flat fumigation, strip, or even “by the hole” (for
individual tree replacement; MeBr is the only product that has
acceptable technology for hole application—approximately 0.5 kg/tree).
 Strip fumigation would comprise approximately 65% of the total area
that is actually fumigated.

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

The amount of MeBr nominated by the U.S. was calculated as follows:

The percent of regional hectares in the applicant’s request was
divided by the total area planted in that crop in the region covered by
the request.  

Hectares counted in more than one application or rotated within one year
of an application to a crop that also uses MeBr were subtracted.  There
was no double counting in this sector. 

Growth or increasing production (the amount of area requested by the
applicant that is greater than that historically treated) was
subtracted.  

Only the area experiencing one or more of the following impacts were
included in the nominated amount: moderate to heavy key pest pressure,
regulatory impacts, and unsuitable soils. 

 California Grape and Tree Fruit League—Stone Fruit - Part B: Crop
Characteristics and Methyl Bromide Use  TC "California Grape and Tree
Fruit League – Stone Fruit - Part B: Crop Characteristics and Methyl
Bromide Use" \f F \l "1"    TC "California Grape and Tree Fruit League
– Stone Fruit - Part B: Crop Characteristics and Methyl Bromide Use"
\f C \l "1"  



California Grape and Tree Fruit League—Stone Fruit 10. Key Diseases
and Weeds for which Methyl Bromide Is Requested and Specific Reasons for
this Request  TC " California Grape and Tree Fruit League – Stone
Fruit - 10. Key Diseases and Weeds for which Methyl Bromide Is Requested
and Specific Reasons for this Request" \f C \l "2"   



California Grape and Tree Fruit League—Stone Fruit. Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request  TC "California
Grape and Tree Fruit League – Stone Fruit - 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 Pests 	Specific reasons
why methyl bromide is needed 



California Grape and Tree Fruit League—Stone Fruit	Replant problem is
a disease complex comprised of interactions between various pathogens
and environmental factors.

Nematodes (Primary pests): Meloidogyne (root knot); Criconemella (ring);
Xiphinema (dagger); Pratylenchus (root lesion); and Tylenchulus (citrus)

Pathogens: Armellaria, Phytophthora, and various fungi, depending on
orchard location and conditions that are thought to contribute to
orchard replant disorder.

Insect: Pollyphylla decemlineata (Tenlined June beetle) 	1,3-D and
chloropicrin are effective in reducing the effects of orchard replant
disorder where there is low disease pressure or where there is light,
sandy loam soils, and where there is acceptable soil moisture. 
Strategies that include multiple components, such as use of fallow and
herbicides and nematicides, have the potential to reduce pest problems
in orchard replant.  Short term fallow along with nematode tolerant
rootstock peach seedlings have looked promising in research trials
(e.g., Browne, 2003b).



California Grape and Tree Fruit League—Stone Fruit. 11. (i)
Characteristics of Cropping System and Climate  TC "California Grape and
Tree Fruit League – Stone Fruit - 11. Characteristics of Cropping
System and Climate" \f C \l "2"  



The typical practice for replanting orchards begins with the removal of
old plantings after the final harvest.  The soil is harrowed and the
remaining roots are pulled.  The soil is fumigated with MeBr in the late
fall and the trees are replanted in the early winter.  Even with MB,
growers may leave a fallow period between tree removal and the
replanting of the new trees, depending on orchard schedule requirements.

The typical practice of replanting orchards with 1,3-D + chloropicrin
(the best alternative where conditions permit), begins with removing the
old trees after harvest and as many of the roots as time and resources
permit.  After the removal of the old trees the soil is ripped and then
irrigated to allow the soil to settle.  Any roots that are pulled to the
surface are removed, and the soil is graded.  Due to the late harvest of
the stone fruit crops there hass not always been a fallow period between
the removal of the old trees and replanting with new trees, but fallow
is becoming a more established tool for pest management.  

California Grape and Tree Fruit League—Stone Fruit. Table 11.1:
Characteristics of Cropping System  TC "California Grape and Tree Fruit
League – Stone Fruit - Table 11.1: Characteristics of Cropping System"
\f F \l "1"  

Characteristics	California Grape and Tree Fruit League—Stone Fruit

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Stone fruit
trees for production

Annual or Perennial Crop: (# of years between replanting) 	Perennial
(20-25 years)

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	None; however, short term fallow along with
nematode tolerant rootstock peach seedlings have looked promising in
research trials (e.g., Browne, 2003b).

Soil Types:  (Sand, loam, clay, etc.)	Varied (light, medium, heavy)

Frequency of methyl bromide Fumigation: 

(e.g. every two years)	Once in life of orchard, until replant with new
orchard

Other relevant factors:	None identified



California Grape and Tree Fruit League—Stone Fruit. Table 11.2
Characteristics of Climate and Crop Schedule  TC "California Grape and
Tree Fruit League – Stone Fruit - 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

	USDA plant hardiness zones 9a, 9b

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

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

Fumigation Schedule	1st year, land preparation and fumigation; no
additional fumigation for life of orchard (~20 years)

Planting 

Schedule	Occurs 2nd year, after fumigation

Key Market Window:	Not applicable

*For Fresno, California.

California Grape and Tree Fruit League—Stone Fruit. 11. (ii) Indicate
if any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?

Orchard replant into previously planted orchard land (the typical
situation in California) requires reducing pathogen populations (mostly
nematodes and fungi) and nutrient sources of previous orchard tree roots
and root remnants.  This requires an effective material that is volatile
and can penetrate into the soil to reach these plant materials.  In
sandy, loam soils, where restrictions do not apply, metam-sodium and
1,3-D may be an acceptable alternative that can penetrate to the target
areas.  In other situations, this compound and other alternatives are
not able to move sufficiently through the soil to remove the problem
pests.  Thus, there is a critical need for MeBr for 2008.  The
infrequent use of MeBr for orchard replant and the positive benefits of
vigorous early tree growth make MeBr a key component of orchard fruit
and nut production in areas where alternative methods are not effective.

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



California Grape and Tree Fruit League—Stone Fruit. Table 12.1
Historic Pattern of Use of Methyl Bromide  TC " California Grape and
Tree Fruit League – Stone Fruit - Table 12.1 Historic Pattern of Use
of Methyl Bromide" \f F \l "1"  

Years	1999	2000	2001	2002	2003	2004

Area Treated (hectares)	3,522	1,723	1,063	1,182	1,619	Not reported

	Hectares and Use Rate presented are for the treated strip.

ratio of Flat Fumigation a methyl bromide use to strip/bed use if strip
treatment is used	strip—65% of area is treated	strip—65% of area is
treated	strip—65% of area is treated	strip—65% of area is treated
strip—65% of area is treated	Not reported

Amount of methyl bromide active ingredient used 

(total kilograms)	1,283,092	627,526	387,354	430,754	589,670	Not reported

formulations of methyl bromide 

(methyl bromide /chloropicrin)	98:2	98:2	98:2	98:2	98:2	Not reported

Method by which methyl bromide applied 

(e.g. injected at 25cm depth, hot gas)	Shank injected	Shank injected
Shank injected	Shank injected	Shank injected	Not reported

Application rate [Active Ingredient] (kg/ha*)	364	364	364	364	364	Not
reported

Actual dosage rate of Active Ingredient (g/m2)*	36.4	36.4	36.4	36.4	36.4
Not reported

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

a Various methods are used depending on the particular location,
fumigation can be Flat Fumigation, strip, or even “by the hole” (for
individual tree replacement; MeBr is the only product that has
acceptable technology for hole application—approximately 0.5 kg/tree).

California Grape and Tree Fruit League—Stone Fruit. Part C: Technical
Validation  TC "California Grape and Tree Fruit League – Stone Fruit 
- Part C: Technical Validation" \f F \l "1"    TC "California Grape and
Tree Fruit League – Stone Fruit - Part C: Technical Validation" \f C
\l "1"  



California Grape and Tree Fruit League—Stone Fruit. 13. Reason for
Alternatives Not Being Feasible  TC "California Grape and Tree Fruit
League – Stone Fruit - 13. Reason for Alternatives Not Being Feasible"
\f C \l "2"   



California Grape and Tree Fruit League—Stone Fruit. Table 13.1: Reason
for Alternatives Not Being Feasible  TC "California Grape and Tree Fruit
League – Stone Fruit – 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

Chloropicrin	Has activity as a fungicide and may be useful if fungi are
significant causal agents of replant disorder (Trout et al., 2002);
generally will not reduce nematodes significantly and they can be major
pests of orchard replant; may have phytotoxicity problems at rates that
are effective against pests (Browne et al., 2002a)	Alone, not effective
for nematode problems

1,3-dichloropropene (1,3-D) 	Some orchards fall in areas with township
cap restrictions on use of 1,3-D.  May be effective where township caps
do not apply and where soil moisture and texture are such that 1,3-D can
penetrate to remnant tree roots of previous orchard.  Comparative yield
with 1,3-D were valued at 5585 kg/ha versus 8903 kg/ha with MeBr (Duncan
et al, 2003).  At US$0.30 per kg peaches, this represents a significant
economic impact.	Can be effective especially with light soils, if no
legal restrictions apply

Metam-sodium	May be effective in killing root tissue near soil surface,
but will not kill roots below 75 cm when metam-sodium is applied at
label rates; not an effective nematicide since it can not reach deep
areas of soil; generally not effective in areas where water percolation
is a problem (e.g., clay soils).  However, in the future, new delivery
systems could increase effectiveness of this compound to make it a more
acceptable alternative to MeBr (where soil conditions are amenable to
its use).  Reducing time in which material can diffuse throughout target
area will improve efficacy (McKenry, 1999); generally not effective in
areas where water percolation is a problem (e.g., clay soils). 
Comparative yield with metam-sodium were valued at 6880 kg/ha versus
8903 kg/ha with MeBr (Duncan et al, 2003).  At US$0.30 per kg peaches,
this represents a significant economic impact.	Possibly, in some
situations

Dazomet	This alternative has been examined by researchers and is
inconsistent in field trials.  This has been deemed not feasible due to
lack of performance in field trials and inability to penetrate and kill
nematodes at depths required for orchard replant acceptability.  This
product requires that there be uniform saturation of the granules to
ensure that the product will perform consistently.  This is not feasible
in a typical orchard situation.  This product “…will not be
successful until more is known about the dissolution rate of the
granules” (McKenry, 1999).  	No

Nematicides	Other nematicides (besides 1,3-D) have limited use due to
their lack of performance or due to regulatory issues.  Therefore, this
product was deemed not feasible	No

Non Chemical Alternatives

Fallow	Generally fallow is not sufficient alone for high pest pressure
areas; frequently done for one year regardless of fumigant that follows;
may require 4-10 year fallow for some crops (McKenry, 1999) and may not
be sufficient even then; may provide partial control in some crops,
however, economically difficult for grower to sustain (Browne et al.,
2002b; Trout et al., 2002).  However, short term fallow along with
nematode tolerant rootstock peach seedlings have looked promising in
research trials (e.g., Browne, 2003b, 2004).	Can reduce nematode
populations—used in conjunction with other treatments in overall IPM
program

Rootstock	Genetic factors are known that confer some tolerance for
orchard replant problems—for example, in one study an orchard with
Marianna 2624 Plum rootstock was not as sensitive as an orchard with
Nemaguard peach rootstock (McKenry, 1999).  This is in spite of the
resistance of Nemaguard to reproduction of root knot
nematodes—however, feeding on Nemaguard roots were aided by
reproduction on remnant roots causing significant replant problem. 
Rootstocks for all of the commodities in this sector are subject to
differential effects from soil and other environmental factors, as well
as the array of pests that comprise individual orchards.  Consequently,
rootstock can only be considered a component of an overall orchard
management plan, and not a solution to the replant problem.  However,
short term fallow along with nematode tolerant rootstock peach seedlings
have looked promising in research trials (e.g., Browne, 2003b, 2004).	No

Biofumigation, solarization, steam, biological control, cover crops and
mulching, Crop rotation / fallow, crop residue and compost,
substrate/plug plants, plowing/tillage, resistant cultivars,
grafting/resistant rootstock, physical removal, organic
amendments/compost, general IPM	Each of the not in kind alternatives
were listed as options for replacement of MB.  Many of these
alternatives are currently being employed with current replant
practices.  Drenovsky et al. (2005) found that black polyethylene
promotes greater growth (trunk diameter) in the year following planting
probably due to increased soil temperature.  This work is continuing. 
Alternatives such as biofumigation, solarization, and steam are not
feasible due to planting times, one time fumigation requirement per
orchard (steam treatment), or inability to attain sufficient biomass of
plant material (biofumigation).  Biological control may have promise but
research has not identified agents that can be used on a commercial
scale or that work consistently well.  The University of California is
investigating biological control of major fungal pathogens, but this
work is still in the early stages of research.  As such, MeBr is
currently considered critical to the industry.	No

Combinations of Alternatives

1,3-D + chloropicrin	Effective against nematodes, fungi, and to kill
remnant roots when 1,3-D is used in orchards with light soils; not
feasible in medium or heavy soils; subject to township caps and specific
moisture requirements.  Promising results from research trials indicated
that efficacy may be improved by refining application protocols and use
rates (see e.g., Browne et al., 2003a, 2004).  Efficacy may be improved
by incorporating fallow if economically feasible.	In some situations,
especially where pathogens and nematodes are key pests, if no legal
restrictions apply and where soil type is amenable

1,3-D + chloropicrin + metam-sodium



1,3-D + metam-sodium





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



California Grape and Tree Fruit League – Stone Fruit. Table 14.1:
Technically Infeasible Alternatives Discussion  TC " California Grape
and Tree Fruit League – Stone Fruit – Table 14.1: Technically
Infeasible Alternatives Discussion" \f F \l "1"  

Name of Alternative	Discussion

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



California Grape and Tree Fruit League—Stone Fruit. 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives  TC " California Grape and Tree Fruit League – Stone
Fruit - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives" \f C \l "2"  



California Grape and Tree Fruit League—Stone Fruit. Table 15.1:
Present Registration Status of Alternatives  TC " California Grape and
Tree Fruit League – Stone Fruit – 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:

Sodium azide	No registration package has been submitted	No	Unknown

Propargyl bromide	No registration package has been submitted	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

Muscadore albus Strain QST 20799 	Registration package has been
received.	Yes	Registered but not yet for sale in the U.S.



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



California Grape and Tree Fruit League—Stone Fruit. Table 16.1:
Effectiveness of Alternatives – Replant Disorder  TC " California
Grape and Tree Fruit League – Stone Fruit – Table 16.1:
Effectiveness of Alternatives – Replant Disorder" \f F \l "1"  

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

Methyl Bromide formulations and Alternatives 

	# of Trials	Disease (% or rating)	# of Trials	Actual Yields (t/ha)
Citation



[1] Untreated

[2] MB (449 kg/ha)

[3] 1,3-D (392 kg/ha)

[4] Metam-sodium (358 kg/ha)

[5] Polyethylene mulch

[6] Sodium tetrathiocarbonate (113 L/ha)

[7] Compost + microbial inoc. (5 appl/season)

[8] Compost + kelp + humic acid (5 appl/season)

[9] Compost + calcium (5 appl/season)	Orchard replant, 4 reps

[1] n/a

[2] preplant

[3] preplant

[4] preplant

[5] postplant

[6] postplant

[7] postplant

[8] postplant

[9] pre- & postplant	Trunk dia. ,1st year (cm)

[1] 11.2b

[2] 15.8a

[3] 12.8ab

[4] 14.0ab

[5] 13ab

[6] 11.4b

[7] 10.8b

[8] 10.8b

[9] 11.8b	4 reps each	Pruning mass, 2nd year (kg/tree)

[1] 1.8b

[2] 6.4a

[3] 3.6b

[4] 3.8b

[5] 2.8b

[6] 1.6b

[7] 1.8b

[8] 1.7b

[9] 2b	Drenovsky et al., 2005

[1] MB (400 kg/ha)

[2] 1,3-D (350 kg/ha) + metam-sodium (125 kg/ha)

[3] 1 year fallow (non-fumigated)

[4] non-fumigated	Peach, fumigation Fall, 1997; Replant, Spring, 1998;

4 reps, research plots	Trunk diameter (mm for MB trt; and % of MB
value); Aug. 2002:

[1] 114a

[2] 92%ab

[3] 86%bc

[4] 81%c	Same	Market Yield (kg/tree MB trt; and % of MB value); Aug.
2002:

[1] 38a

[2] 100%a

[3] 93%a

[4] 86%a	Trout et al., 2002

[1] MB (400 kg/ha)

[2] 1,3-D (260 kg/ha) + chloropicrin (150 kg/ha) + metam-sodium (63
kg/ha)

[3] 1 year fallow (non-fumigated)

[4] non-fumigated	Peach, fumigation Fall, 1998; Replant, Spring, 1999;

4 reps, research plots	Trunk diameter (mm for MB trt; and % of MB
value); Aug. 2002:

[1] 94.1a

[2] 102%a

[3] 89%b

[4] 82%b	Same	Market Yield (kg/tree MB trt; and % of MB value); July,
2002:

[1] 30ab

[2] 109%a

[3] 87%bc

[4] 75%c	Trout et al., 2002



California Grape and Tree Fruit League—Stone Fruit. Table C.1:
Alternatives Yield Loss Data Summary  TC " California Grape and Tree
Fruit League – Stone Fruit – 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-D (385 kg/ha)	Nematodes, roots	0-20% (based on research plots)	10%
(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha)	Nematodes, fungi, roots
0-10% (based on research plots)	5% (based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha) + metam-sodium (65 kg/ha)
Nematodes, fungi, roots	0-10% (based on research plots)	5% (based on
research plots)

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

Overall Loss Estimate for All Alternatives to Pests	See discussion below



Alternatives are used in most replant sites.  MeBr is critical for 2008
for sites where conditions do allow effective use of alternatives (those
with medium to heavy soils, and/or where township cap restrictions
apply).  In these cases losses of trees can be greater than 20%
(McKenry, 1999).  Sites well-suited to 1,3-D should have efficacy
similar to MB.

California Grape and Tree Fruit League—Stone Fruit. 17. Are There Any
Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?  TC "California Grape and Tree
Fruit League – Stone Fruit - 17. Are There Any Other Potential
Alternatives Under Development which Are Being Considered to Replace
Methyl Bromide?" \f C \l "2"  

In situations with light soils, and available water to moisten the top
30 cm of soil, 1,3-D with chloropicrin and/or metam-sodium can be
effective treatments for orchard replant problems.  In medium or heavy
soils, high moisture content below 1 to 1.5 meters usually reduces the
efficacy of 1,3-D and precludes its use.  Fallowing and crop rotation
studies (Browne et al., 2003b, 2004) suggest orchard replant disorder
can be reduced but further studies are needed to test on a commercial
scale.  Nematode control has been short-lived (only up to 6 to 9 months)
in some studies (McKenry, 1999).  In a research trial, establishing
peach and almond orchards on previous vineyard soil appears to improve
orchard establishment regardless of chemical fumigant (Browne et al.,
2004; Lampinen et al., 2004).  Tolerant rootstocks with resistance to
the primary nematode pests are being developed, but orchard replant
disorder is caused by varying factors that vary depending on orchard
location and according to the crop grown (and crop grown prior to the
orchard replant).  

California Grape and Tree Fruit League—Stone Fruit. 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?  TC "California Grape and Tree Fruit League – Stone
Fruit - 18. Are There Technologies Being Used to Produce the Crop which
Avoid the Need for Methyl Bromide?" \f C \l "2"  

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

California Grape and Tree Fruit League—Stone Fruit. Summary of
Technical Feasibility  TC "California Grape and Tree Fruit League –
Stone Fruit - Summary of Technical Feasibility" \f C \l "2"  

For replant situations where alternatives are not effective, MeBr is
considered critical to the healthy establishment of orchards.  In those
stone fruit orchard replant sites with medium to heavy soils and/or
where township cap restrictions apply losses of trees could be greater
than 20% (McKenry, 1999).  Orchard replant problems for all orchard
replant sites are a result of biological and environmental causes, and
interactions of these forces.  Studies of individual pest populations
tell only a portion of the story of replant complex, since individual
pests cause only a portion of the adverse growth effects.  Nevertheless,
Criconemella xenoplax infests at least 60% of hectares planted in cling
peaches (McKenry, 1999).  An additional 35% of fresh peach, plum, and
nectarine plantings are infested with P. vulnus and a somewhat smaller
area is infested with C. xenoplax.  As such, it is clear that the long
life of orchards requires that optimal pest management strategies be
employed to overcome replant disorder during the one opportunity
available—at orchard establishment.  The long history of 1,3-D use in
California suggests that at optimal conditions it (or in combination
with another chemical) is the best alternative to MB.  However, the
reality of California orchard locations precludes some growers from
taking advantage of 1,3-D, since either township caps or soil
texture/moisture issues reduce efficacy or legal availability. 
Therefore, for 2008, for stone fruit replant where alternatives are not
effective, there is a critical need for MeBr for establishment of
commercial operations.  Currently, research is being conducted examining
non-fumigant treatments.  Some non-chemical treatments have shown
promise in small-scale research trials, such as planting cover crops on
previous vineyards (Browne, 2003b, 2004; Lampinen et al., 2004).  Long
term studies will continue to refine these types of treatments for
commercial applications. 

 California Grape and Tree Fruit League—Raisin & Table Grapes. Part
B: Crop Characteristics and Methyl Bromide Use  TC "California Grape and
Tree Fruit League – Raisin & Table Grapes - Part B: Crop
Characteristics and Methyl Bromide Use" \f F \l "1"    TC "California
Grape and Tree Fruit League – Raisin & Table Grapes - Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"  



California Grape and Tree Fruit League—Raisin & Table Grapes. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request  TC "California Grape and Tree Fruit League –
Raisin & Table Grapes - 10. Key Diseases and Weeds for which Methyl
Bromide Is Requested and Specific Reasons for this Request" \f C \l "2" 
 



California Grape and Tree Fruit League—Raisin & Table Grapes. Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request  TC "
California Grape and Tree Fruit League – Raisin & Table Grapes - 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 pests 	Specific reasons
why methyl bromide is needed 

(e.g. Effective herbicide available, but not registered for this crop;
mandatory requirement to meet certification for disease tolerance)

California Grape and Tree Fruit League—Raisin & Table Grapes	Replant
problem is a disease complex comprised of interactions between various
pathogens and environmental factors.

Nematodes (Primary pests): Meloidogyne (root knot); Criconemella (ring);
Xiphinema (dagger); Pratylenchus (root lesion); and Tylenchulus (citrus)

Pathogens: Armellaria, Phytophthora, and various fungi, depending on
orchard location and conditions, that are thought to contribute to
orchard replant disorder.

Insect: At some sites Pollyphylla decemlineata (tenlined June beetle)
Some alternatives, such as 1,3-D and chloropicrin, may be effective in
reducing the effects of orchard replant disorder in vineyards, where
there are no legal restriction, in light, sandy loam soils, and where
there is acceptable soil moisture.  For root knot and citrus nematode
control, Inline and drip applied 1,3-D have showed good efficacy in
research trials (Schneider et al., 2004).  Rootstock “Harmony” has
showed good efficacy against rootknot nematodes after six seasons, but
poor efficacy against citrus nematodes (Schneider et al., 2004). In
situations where soils are medium to heavy, or where township caps are
applicable, MeBr is used to effectively target root remnants from
previous orchard trees.  Strategies that include multiple techniques,
such as use of herbicides and fallow and nematicides, have the potential
to reduce pest problems in replant.  However, these combination
techniques must first be tested and proven so as not to compromise
orchard productivity.  Some research suggests that long term fallow
benefits diminished after four seasons (Schneider et al., 2004).



California Grape and Tree Fruit League—Raisin & Table Grapes.  11. (i)
Characteristics of Cropping System and Climate  TC " California Grape
and Tree Fruit League – Raisin & Table Grapes - 11. Characteristics of
Cropping System and Climate" \f C \l "2"  



As in stone fruit orchards, the typical practice of replanting vineyards
with MeBr is to remove the old plantings after the final harvest.  The
soil is harrowed and the remaining roots are removed.  The soil is
fumigated in the late fall and the trees are replanted in the early
winter.  When using MeBr growers may or may not fallow between tree
removal and the replanting of the new trees.

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

California Grape and Tree Fruit League—Raisin & Table Grapes.  Table
11.1: Characteristics of Cropping System  TC " California Grape and Tree
Fruit League – Raisin & Table Grapes - Table 11.1: Characteristics of
Cropping System" \f F \l "1"  

Characteristics	California Grape and Tree Fruit League – Raisin &
Table Grapes

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Raisins and
table grapes

Annual or Perennial Crop: (# of years between replanting) 	Perennial
(average of 22 year vineyard life)

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	None

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

Frequency of methyl bromide Fumigation: (e.g. every two years)	Once in
22 years

Other relevant factors:	The applicant did not identify any other
relevant factors.



California Grape and Tree Fruit League—Raisin & Table Grapes. Table
11.2 Characteristics of Climate and Crop Schedule  TC " California Grape
and Tree Fruit League – Raisin & Table Grapes - 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

	USDA plant hardiness zones 9a, 9b

Rainfall (mm):30-60 cm/yr	16	72.1	17.3	0	trace	1.0	trace	0	44.7	56.9	9.9
30.5

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

Fumigation Schedule	1st year, land preparation and fumigation; no
additional fumigation for life of vineyard

Planting 

Schedule	Occurs 2nd year, after fumigation

Key Market Window:	Not applicable

*For Fresno, California

California Grape and Tree Fruit League—Raisin & Table Grapes.  11.
(ii) Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?  TC "California Grape and Tree
Fruit League—Raisin & Table Grapes.  11. (ii) Indicate if any of the
above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?" \f C \l "2"  

Replanting vineyards into non-virgin areas (the typical situation in
California) requires removing pathogens (nematodes and fungi) and
nutrient sources of previous orchard tree roots and root remnants.  This
requires an effective material that is volatile and can penetrate into
the soil to reach these plant materials.  In sandy, loam soils, where
restrictions do not apply, 1,3-D may be an acceptable alternative that
can penetrate to the target areas.  However, in vineyard regions of
California, township caps may reduce use of 1,3-D to a fraction of
planted vineyard replant situations.

California Grape and Tree Fruit League—Raisin & Table Grapes. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested  TC "California
Grape and Tree Fruit League – Raisin & Table Grapes - 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested" \f C \l "2"   



California Grape and Tree Fruit League—Raisin & Table Grapes. Table
12.1 Historic Pattern of Use of Methyl Bromide  TC "California Grape and
Tree Fruit League – Raisin & Table Grapes - Table 12.1 Historic
Pattern of Use of Methyl Bromide" \f F \l "1"  

Years	1999	2000	2001	2002	2003	2004

Area Treated (hectares)	251	273	67	97	123	Not available

	Hectares and Use Rate presented are for the treated strip.

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

Amount of methyl bromide active ingredient used 

(total kg)	108,035	70,732	18,248	20,175	34,618	Not available

formulations of methyl bromide (methyl bromide /chloropicrin)	98:2	98:2
98:2	98:2	98:2	Not available

Method by which methyl bromide applied (e.g. injected at 25cm depth, hot
gas)	Shank injected	Shank injected	Shank injected	Shank injected	Shank
injected	Not available

Application rate [Active Ingredient] (kg/ha*)	430	259	271	208	280	Not
available

Actual dosage rate of Active Ingredient (g/m2)*	43.0	25.9	27.1	21.0	28.0
Not available

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

California Grape and Tree Fruit League—Raisin & Table Grapes. Part C:
Technical Validation  TC "California Grape and Tree Fruit League –
Raisin & Table Grapes  - Part C: Technical Validation" \f F \l "1"    TC
"California Grape and Tree Fruit League – Raisin & Table Grapes - Part
C: Technical Validation" \f C \l "1"  



California Grape and Tree Fruit League—Raisin & Table Grapes.  13.
Reason for Alternatives Not Being Feasible  TC "California Grape and
Tree Fruit League – Raisin & Table Grapes - 13. Reason for
Alternatives Not Being Feasible" \f C \l "2"   



California Grape and Tree Fruit League—Raisin & Table Grapes. Table
13.1: Reason for Alternatives Not Being Feasible  TC " California Grape
and Tree Fruit League – Raisin & Table Grapes – 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-D	Where soil moisture is acceptable and township caps are not
instituted, 1,3-D can provide effective management of replant disorder
in vineyards with light soils; usually more effective with chloropicrin.
Usually with light soils, if no legal restrictions apply

Metam-sodium	Not an effective nematicide in replant system since it can
not reach deep areas of soil, which is the primary cause of orchard
replant problems; generally not effective in areas where water
percolation is a problem (e.g., clay soils); nematodes are the primary
pest in the replant disorder complex; generally not effective in areas
where water percolation is a problem (e.g., clay soils).	No

Chloropicrin	Where fungi are primary pest (requires addition of 1,3-D is
nematodes are present)	No—requires complementary chemical

Dazomet	This alternative has not been examined by researchers for
vineyards, however, it is likely that problems with this chemical are
similar to the stone fruit industry—i.e., it is likely similar to
metam-sodium in that it would not penetrate and kill nematodes at depths
required for orchard replant acceptability.  This product requires that
there be uniform saturation of the granules to ensure that the product
will perform consistently.  This likely would not be feasible in a
typical vineyard situation.	No

Nematicides	Some products have been tested (McKenry, appendix to wine
grape growers request for 2008 use season) but have not been
sufficiently studied or effective to be considered alternatives. 
Products tested, or being tested, include: 30 products such as walnut
tea, nicotinamide insecticide (Admire), Integrate (mineral extraction),
Oxycom (peroxyacetic acide).	No

Sodium tetrathiocarbonate	This compound does not penetrate the old roots
of the previous vineyard.  Old roots then can be a source of inoculum
for various fungal and nematodes pests.  Therefore, the use of this
product alone will not provide adequate control of the pest complex in
vineyards.  Generally this product is used in combination with other
practices that will allow for successful replanting.

	No

Non Chemical Alternatives  

Fallow	Not sufficient alone; frequently done for one year regardless of
fumigant that follows; may require 4-10 year fallow for some crops
(Browne, 2002b) and may not be sufficient even then, especially if
vineyard viruses, such as grape fan leaf virus (GFLV) have occurred; may
provide partial control in some crops, however, economically difficult
for grower to sustain (McKenry, 1999; McKenry et al., 1995). 	No

Rootstock	Some rootstocks are available, such as Teleki 5C or Harmony,
which can significantly reduce certain species of nematodes—but no
multiple resistance.  Used in combination with 1,3-D, significant
reductions in rootknot and citrus nematodes have resulted in research
tests (see Schneider et al., 2002, 2003; Ferris and Walker, 2002).	No

Biofumigation, solarization, steam, biological control, cover crops and
mulching, crop rotation / fallow, crop residue and compost,
substrate/plug plants, plowing/tillage, resistant cultivars,
grafting/resistant rootstock, physical removal, organic
amendments/compost, general IPM	Each of the not in kind alternatives
were listed as options for replacement of MB.  Many of these
alternatives are currently being employed with current replant practices
(Schneider et al., 2000).  IPM approaches are being extensively
investigated (Schneider et al., 1999). Alternatives such as
biofumigation, solarization, and steam are not feasible due to planting
times, one time fumigation requirement per orchard (steam treatment), or
inability to attain sufficient biomass of plant material
(biofumigation).  Development of durable resistance to nematodes in
grape rootstock is an ongoing and challenging area of research (Ferris
and Walker, 2002). Biological control may have promise but research has
not identified agents that can be used on a commercial scale or that
work consistently well.  The University of California is investigating
biological control of major fungal pathogens, but this work is still in
the early stages of research.  As such, MeBr is currently considered
critical to the industry.	No

Combinations of Alternatives

1,3-D + chloropicrin	Effective against nematodes, fungi, and to kill
remnant roots when 1,3-D is used in orchards with light soils; not
feasible in medium or heavy soils; subject to township caps and specific
moisture requirements.  Promising results from research trials indicated
that efficacy may be improved by refining application protocols and use
rates (see e.g., Schneider, 2004).	Possibly, after further research that
will optimize application methods, if no legal restrictions apply and
where soil type is amenable

1,3-D + chloropicrin + metam-sodium



1,3-D + metam-sodium



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

California Grape and Tree Fruit League – Raisin & Table Grapes. 14.
List and Discuss Why Registered (and Potential) Pesticides and
Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:  TC " California Grape and Tree Fruit League – Raisin
& Table Grapes - 14. List and Discuss Why Registered (and Potential)
Pesticides and Herbicides Are Considered Not Effective as Technical
Alternatives to Methyl Bromide:" \f C \l "2"  



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

California Grape and Tree Fruit League—Raisin & Table Grapes. 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives  TC "California Grape and Tree Fruit League –
Raisin & Table Grapes - 15. List Present (and Possible Future)
Registration Status of Any Current and Potential Alternatives" \f C \l
"2"  :



California Grape and Tree Fruit League—Raisin & Table Grapes. Table
15.1: Present Registration Status of Alternatives  TC " California Grape
and Tree Fruit League – Raisin & Table Grapes – 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:

Sodium azide	Not registered in U.S., no registration package has been
received	No	Unknown

Propargyl bromide	Not registered in U.S., no registration package has
been received	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

Muscador albus Strain QST 20799 	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



California Grape and Tree Fruit League—Raisin & Table Grapes. 16.
State Relative Effectiveness of Relevant Alternatives Compared to Methyl
Bromide for the Specific Key Target Pests and Weeds for which It Is
Being Requested  TC " California Grape and Tree Fruit League – Raisin
& Table Grapes - 16. State Relative Effectiveness of Relevant
Alternatives Compared to Methyl Bromide for the Specific Key Target
Pests and Weeds for which It Is Being Requested" \f C \l "2"  



California Grape and Tree Fruit League—Raisin & Table Grapes. Table
16.1: Effectiveness of Alternatives – Replant Disorder (nematodes). 
TC " California Grape and Tree Fruit League – Raisin & Table Grapes
– Table 16.1: Effectiveness of Alternatives – Replant Disorder
(Nematodes)" \f F \l "1"  

Key Pest: Replant disorder (Nematodes)

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Trials	Disease (% or
rating)	Citation

[1] not fumigated

[2] MB (455 kg/ha) [shanked, tarp]

[3] metam-sodium (125 kg/ha) [microspray]

[4] InLine + metam-sodium (125 kg/ha) [microspray]

[5] chloropicrin (455 kg/ha) [drip] + metam-sodium (125 kg/ha)
[microspray]	5 reps; grapes	Meloidogyne spp. (#/100 cc soil) (trial
planted and sampled 2001)

[1] 324a

[2] 0c

[3]290a

[4] 0c

[5] 8b	Tylenchulus semipenetrans

(#/100 cc soil)

(trial planted and sampled 2001)

[1] 121a

[2] 0c

[3] 157a

[4] 0c

[5] 2bc	Schneider et al., 2002

[1] not fumigated

[2] 1-year fallow

[3] 1-year fallow + cover crop

[4] MB (455 kg/ha) [shanked, tarp]

[5] 1,3-D (352 kg/ha) [in 60 mm water] + metam-sodium (125 kg/ha)
[microspray]

[6] 1,3-D (352 kg/ha) [in 100 mm water] + metam-sodium (125 kg/ha)
[microspray]	5 reps; grapes	Meloidogyne spp. per 100 cc soil (trial
planted 1998, sampled 2001)	Schneider et al., 2002



Thompson seedless rootstock	Teleki 5C rootstock	Harmony rootstock



	[1] 144ab

[2] 215a

[3] 145ab

[4] 1def

[5] 0.2ef

[6] 6cde	[1] 261a

[2] 49b

[3] 190a

[4] 0.3c

[5] 0.6c

[6] 0.2c	[1] 0.8a

[2] 0.0a

[3] 0.1a

[4] 0.0a

[5] 0.0a

[6] 0.0a

	[1] not fumigated

[2] 1-year fallow

[3] 1-year fallow + cover crop

[4] MB (455 kg/ha) [shanked, tarp]

[5] 1,3-D (352 kg/ha) [in 60 mm water] + metam-sodium (125 kg/ha)
[microspray]

[6] 1,3-D (352 kg/ha) [in 100 mm water] + metam-sodium (125 kg/ha)
[microspray]	5 reps; grapes	Tylenchulus semipenetrans per 100 cc soil
(trial planted 1998, sampled 2001)

	Schneider et al., 2002



Thompson seedless rootstock	Teleki 5C rootstock	Harmony rootstock



	[1] 638a

[2] 352a

[3] 463a

[4] 0.4c

[5] 3c

[6] 6b	[1] 301a

[2] 434a

[3] 342a

[4] 4b

[5] 1b

[6] 3b	[1] 913a

[2] 1123a

[3] 723a

[4] 2b

[5] 6b

[6] 7b

	

California Grape and Tree Fruit League—Raisin & Table Grapes. Table
C.1: Alternatives Yield Loss Data Summary  TC " California Grape and
Tree Fruit League – Raisin & Table Grapes – 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-D (385 kg/ha)	Nematodes, roots	0-20%

 (based on research plots)	10%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha)	Nematodes, fungi, roots
0-10% 

(based on research plots)	5%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha) + metam-sodium (65 kg/ha)
Nematodes, fungi, roots	0-10% 

(based on research plots)	5%

(based on research plots)

1,3-D (350 kg/ha) + metam-sodium (125 kg/ha)	Nematodes, roots	0-10% 

(based on research plots)	5%

(based on research plots)

Overall Loss Estimate for All Alternatives to Pests	See discussion below



No alternatives are currently feasible in some orchard replant sites
(i.e., those with medium to heavy soils) and/or where township cap
restrictions apply.  In these cases losses of vines could be 20%
(McKenry, 1999).  Sites well-suited to 1,3-D should have efficacy
similar to MB.

California Grape and Tree Fruit League—Raisin & Table Grapes. 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?  TC "California Grape and Tree
Fruit League – Raisin & Table Grapes - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?" \f C \l "2"  

For replant sites with light soil, and water available to moisten the
top 30 cm of soil, 1,3-D with chloropicrin or metam-sodium can be
effective treatments for replant problem.  However, in medium or heavy
soils, high moisture content below 1 to 1.5 meters usually reduces the
efficacy of 1,3-D, and precludes its use.  Fallow has potential as a
component of a management strategy and is being investigated especially
when sites are first treated with an herbicide to kill remnant roots
from previous plantings.  Earlier research indicated that nematode
control was short-lived (only up to 6 to 9 months) (McKenry, 1999). 
Rootstocks with resistance to the primary nematode pests are being
investigated.  Current research should help refine strategies for
effective use of MeBr alternatives.

California Grape and Tree Fruit League—Raisin & Table Grapes. 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?  TC "California Grape and Tree Fruit League—Raisin
& Table Grapes. 18. Are There Technologies Being Used to Produce the
Crop which Avoid the Need for Methyl Bromide?" \f C \l "2"  

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

California Grape and Tree Fruit League—Raisin & Table Grapes. Summary
of Technical Feasibility  TC "California Grape and Tree Fruit League –
Raisin & Table Grapes - Summary of Technical Feasibility" \f C \l "2"  

The consortium has requested MeBr for “…pull out programs, age of
vines, pests and new varieties”, thus doubling the area to be
replanted.  The nomination has adjusted the request to account for
growth.  As with all replant sites, orchard replant problems for
vineyards are a result of biological and environmental causes, and
probably interactions of these factors.  In situations with an
identified pest, such as rootknot nematodes, there are promising
resistant (or tolerant) rootstocks that may help alleviate the problem
(e.g., Schneider et al, 2003, 2004); studies are ongoing to determine if
fallow can reduce nematode populations in field trials and if VIF is
useful in reducing emissions and increasing efficacy with lower rates.

Optimal pest management strategies need to be followed at time of
orchard establishment.  The history of 1,3-D use in California suggests
that at optimal conditions it (or in combination with another chemical)
is the best alternative to MB.  However, the reality of California
orchard and vineyard locations precludes some growers taking advantage
of the material since either township caps or soil texture/moisture
issues reduce efficacy or legal availability to 1,3-D.  Therefore, for
2008, for table grape and raisin vineyard replant, where alternatives
are not effective, there is a critical need for MeBr for establishment
of commercial operations.

Central California Winegrowers—Wine Grapes. Part B: Crop
Characteristics and Methyl Bromide Use  TC "Central California
Winegrowers – Wine Grapes - Part B: Crop Characteristics and Methyl
Bromide Use" \f F \l "1"    TC "Central California Winegrowers – Wine
Grapes - Part B: Crop Characteristics and Methyl Bromide Use" \f C \l
"1"  



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



Central California Winegrowers—Wine Grapes. Table 10.1: Key Diseases
and Weeds and Reason for Methyl Bromide Request  TC " Central California
Winegrowers – Wine Grapes - 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 pests 	Specific reasons
why methyl bromide is needed 

Central California Winegrowers—Wine Grapes	Replant problem is a
disease complex comprised of interactions between various pathogens and
environmental factors.

Nematodes (Primary pests): Meloidogyne (root knot); Criconemella (ring);
Xiphinema (dagger); Pratylenchus (root lesion); and Tylenchulus (citrus)

Pathogens: Armellaria, Phytophthora, and various fungi, depending on
orchard location and conditions, that are thought to contribute to
orchard replant disorder.

Insect: At some sites Pollyphylla decemlineata (tenlined June beetle)
Some alternatives, such as 1,3-D and chloropicrin, may be effective in
reducing the effects of orchard replant disorder in vineyards, where
there are no legal restriction, in light, sandy loam soils, and where
there is acceptable soil moisture.  For root knot and citrus nematode
control, Inline and drip applied 1,3-D have showed good efficacy in
research trials (Schneider et al., 2004).  Rootstock “Harmony” has
showed good efficacy against rootknot nematodes after six seasons, but
poor efficacy against citrus nematodes (Schneider et al., 2004). In
situations where soils are medium to heavy, or where township caps are
applicable, MeBr is the only single compound that effectively targets
root remnants from previous orchard trees.  Strategies that include
multiple techniques, such as use of herbicides and fallow and
nematicides, have the potential to reduce pest problems in orchard
replant.  However, these combination techniques must first be tested and
proven so as not to compromise orchard productivity.  Some research
suggests that long term fallow benefits diminished after four seasons
(Schneider et al., 2004).



Central California Winegrowers—Wine Grapes.  11. (i) Characteristics
of Cropping System and Climate  TC " Central California Winegrowers –
Wine Grapes - 11. Characteristics of Cropping System and Climate" \f C
\l "2"  



As in stone fruit orchards, the typical practice of replanting vineyards
with MeBr is to remove the old plantings after the final harvest.  The
soil is harrowed and the remaining roots are removed.  The soil is
fumigated in the late fall and the trees are replanted in the early
winter.  When using MeBr growers may or may not fallow between tree
removal and the replanting of the new trees.

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

Central California Grape Winegrowers—Wine Grapes.  Table 11.1:
Characteristics of Cropping System  TC " Central California Winegrowers
– Wine Grapes - Table 11.1: Characteristics of Cropping System" \f F
\l "1"  

Characteristics	Central California Grape Winegrowers—Wine Grapes

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Raisins and
table grapes

Annual or Perennial Crop: (# of years between replanting) 	Perennial
(average of 22 year vineyard life)

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	None

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

Frequency of methyl bromide Fumigation: (e.g. every two years)	Once in
22 years

Other relevant factors:	The applicant did not identify any other
relevant factors.



Central California Grape Winegrowers—Wine Grapes. Table 11.2
Characteristics of Climate and Crop Schedule  TC " Central California
Winegrowers – Wine Grapes - 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

	USDA plant hardiness zones 9a, 9b (counties include: Merced, San
Joaquin, Madera, Fresno, Kings, Tulare, Kern, Stanislaus)

Rainfall (mm):30-60 cm/yr	16	72.1	17.3	0	trace	1.0	trace	0	44.7	56.9	9.9
30.5

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

Fumigation Schedule	1st year, land preparation and fumigation; no
additional fumigation for life of vineyard

Planting 

Schedule	Planting occurs the year after fumigation

Key Market Window:	Not applicable

*For Fresno, California

Central California Grape Winegrowers—Wine Grapes.  11. (ii) Indicate
if any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?   TC " Central California Winegrowers – Wine
Grapes - 11. Characteristics That Prevent Uptake of Relevant
Alternatives" \f C \l "2"  

Replanting vineyards into non-virgin areas (the typical situation in
California) involves reducing pathogens (particularly nematodes and
fungi) and nutrient sources of previous orchard tree roots and root
remnants.  This requires an effective material that is volatile and can
penetrate into the soil to reach these plant materials.  In sandy, loam
soils, where restrictions do not apply, metam-sodium or 1,3-D may be an
acceptable alternative that can penetrate to the target areas.  However,
in vineyard regions of California, township caps may reduce use of 1,3-D
to a fraction of planted vineyard replant situations.

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



Central California Grape Winegrowers—Wine Grapes. Table 12.1 Historic
Pattern of Use of Methyl Bromide  TC " Central California Winegrowers
–Wine Grapes - Table 12.1 Historic Pattern of Use of Methyl Bromide"
\f F \l "1"  

Years:	1998	1999	2000	2001	2002	2003

Area Treated  all of CALifornia (hectares)	877	1088	429	92	123	42

	Hectares and Use Rate presented are for the treated strip.

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Strip (65% of a hectare is treated)	Strip (65% of a
hectare is treated)	Strip (65% of a hectare is treated)	Strip (65% of a
hectare is treated)	Strip (65% of a hectare is treated)	Strip (65% of a
hectare is treated)

Amount of methyl bromide active ingredient used 

(total kg)	336,867	441,181	164,563	35,687	53,572	14,196

formulations of methyl bromide (methyl bromide /chloropicrin)	98:2	98:2
98:2	98:2	98:2	98:2

Method by which methyl bromide applied)	Shank injected	Shank injected
Shank injected	Shank injected	Shank injected	Shank injected

Application rate [Active Ingredient] (kg/ha*)	384	406	384	387	435	339

Actual dosage rate of Active Ingredient in Treated Zone(g/m2)*	38.4	40.6
38.4	38.7	43.5	33.9

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

Source of CA Usage data was T. Trout, USDA, ARS , CA Fumigant Use 2005. 


Central California Grape Winegrowers—Wine Grapes. Part C: Technical
Validation  TC "Central California Winegrowers – Wine Grapes  - Part
C: Technical Validation" \f F \l "1"    TC "Central California
Winegrowers – Wine Grapes - Part C: Technical Validation" \f C \l "1" 




Central California Grape Winegrowers—Wine Grapes.  13. Reason for
Alternatives Not Being Feasible  TC " Central California Winegrowers
–Wine Grapes 13. Reason for Alternatives Not Being Feasible" \f C \l
"2"   



Central California Grape Winegrowers—Wine Grapes. Table 13.1: Reason
for Alternatives Not Being Feasible  TC " Central California Winegrowers
–Wine Grapes – 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 cost
effective?

Chemical Alternatives

1,3-D	Where soil moisture is acceptable and township caps are not
instituted, 1,3-D may provide effective management of replant disorder
in vineyards with light soils; usually more effective with chloropicrin.
With light soils, if no legal restrictions apply, usually in combination
with chloropicrin

Metam-sodium	With current application technology does not reach deep
areas of soil, which is the primary cause of orchard replant problems;
generally not effective in areas where water percolation is a problem
(e.g., clay soils); nematodes are the primary pest in the replant
disorder complex; generally not effective in areas where water
percolation is a problem (e.g., clay soils).	With light soils, if no
legal restrictions apply; may be in combination with 1,3-D and
chloropicrin

Chloropicrin	Where fungi are primary pest (requires addition of 1,3-D is
nematodes are present)	In amenable soils, usually in combination with
1,3-D and/or metam-sodium

Dazomet	This alternative has not been examined by researchers for
vineyards, however, it is likely that problems with this chemical are
similar to the stone fruit industry—i.e., it is likely similar to
metam-sodium in that it would not penetrate and kill nematodes at depths
required for orchard replant acceptability.  This product requires that
there be uniform saturation of the granules to ensure that the product
will perform consistently.  This likely would not be feasible in a
typical vineyard situation.	No

Nematicides	Some products have been tested (McKenry, appendix to
consortium request for 2008 use season) but have not been sufficiently
studied or effective to be considered alternatives.  Products tested, or
being tested, include: 30 products such as walnut tea, nicotinamide
insecticide (Admire), Integrate (mineral extraction), Oxycom
(peroxyacetic acide).	No

Sodium tetrathiocarbonate	This compound (Enzone) does not penetrate the
old roots of the previous vineyard.  Old roots then can be a source of
inoculum for various fungal and nematodes pests.  Therefore, the use of
this product alone will not provide adequate control of the pest complex
in vineyards.  Generally this product is used in combination with other
practices that will allow for successful replanting.

	No

Non Chemical Alternatives  

Fallow	Not sufficient alone; frequently done for 1 year regardless of
fumigant that follows; may require 4-10 year fallow for some replant
(Browne, 2002b) and may not be sufficient even then, especially if
vineyard viruses, such as grape fan leaf virus (GFLV) have occurred; may
provide partial control in some crops, however, economically difficult
for grower to sustain (McKenry, 1999; McKenry et al., 1995). 	No

Rootstock	Some rootstocks are available, such as Teleki 5C or Harmony,
which can significantly reduce certain species of nematodes—but no
multiple resistance.  Used in combination with 1,3-D, significant
reductions in rootknot and citrus nematodes have resulted in research
tests (see Schneider et al., 2002, 2003; Ferris and Walker, 2002).	No

Biofumigation, solarization, steam, biological control, cover crops and
mulching, crop rotation / fallow, crop residue and compost,
substrate/plug plants, plowing/tillage, resistant cultivars,
grafting/resistant rootstock, physical removal, organic
amendments/compost, general IPM	Each of the not in kind alternatives
were listed as options for replacement of MB.  Many of these
alternatives are currently being employed with current replant practices
(Schneider et al., 2000).  IPM approaches are being extensively
investigated (Schneider et al., 1999). Alternatives such as
biofumigation, solarization, and steam are not feasible due to planting
times, one time fumigation requirement per orchard (steam treatment), or
inability to attain sufficient biomass of plant material
(biofumigation).  Development of durable resistance to nematodes in
grape rootstock is an ongoing and challenging area of research (Ferris
and Walker, 2002). Biological control may have promise but research has
not identified agents that can be used on a commercial scale or that
work consistently well.  The University of California is investigating
biological control of major fungal pathogens, but this work is still in
the early stages of research.  As such, MeBr is currently considered
critical to the industry.	No

Combinations of Alternatives

1,3-D + chloropicrin	Effective against nematodes, fungi, and to kill
remnant roots when 1,3-D is used in orchards with light soils; not
feasible in medium or heavy soils; subject to township caps and specific
moisture requirements.  Promising results from research trials indicated
that efficacy may be improved by refining application protocols and use
rates (see e.g., Schneider, 2004).	Possibly, after further research that
will optimize application methods, if no legal restrictions apply and
where soil type is amenable

1,3-D + chloropicrin + metam-sodium



1,3-D + metam-sodium



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

Central California Grape Winegrowers—Wine Grapes. 14. List and Discuss
Why Registered (and Potential) Pesticides and Herbicides Are Considered
Not Effective as Technical Alternatives to Methyl Bromide:  TC " Central
California Winegrowers –Wine Grapes - 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"  



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

Central California Grape Winegrowers—Wine Grapes. 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives  TC " Central California Winegrowers –Wine Grapes - 15.
List Present (and Possible Future) Registration Status of Any Current
and Potential Alternatives" \f C \l "2"  :



Central California Grape Winegrowers—Wine Grapes. Table 15.1: Present
Registration Status of Alternatives  TC " Central California Winegrowers
–Wine Grapes – 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:

Sodium azide	Not registered in U.S., no registration package has been
received	No	Unknown

Propargyl bromide	Not registered in U.S., no registration package has
been received	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

Muscador albus Strain QST 20799	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



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



Central California Grape Winegrowers—Wine Grapes. Table 16.1:
Effectiveness of Alternatives – Replant Disorder (nematodes).  TC "
Central California Winegrowers –Wine Grapes – Table 16.1:
Effectiveness of Alternatives – Replant Disorder (Nematodes)" \f F \l
"1"  

Key Pest: Replant disorder (Nematodes)

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Trials	Disease (% or
rating)	Citation

[1] not fumigated

[2] MB (455 kg/ha) [shanked, tarp]

[3] metam-sodium (125 kg/ha) [microspray]

[4] InLine + metam-sodium (125 kg/ha) [microspray]

[5] chloropicrin (455 kg/ha) [drip] + metam-sodium (125 kg/ha)
[microspray]	5 reps; grapes	Meloidogyne spp. (#/100 cc soil) (trial
planted and sampled 2001)

[1] 324a

[2] 0c

[3]290a

[4] 0c

[5] 8b	Tylenchulus semipenetrans

(#/100 cc soil)

(trial planted and sampled 2001)

[1] 121a

[2] 0c

[3] 157a

[4] 0c

[5] 2bc	Schneider et al., 2002

[1] not fumigated

[2] 1-year fallow

[3] 1-year fallow + cover crop

[4] MB (455 kg/ha) [shanked, tarp]

[5] 1,3-D (352 kg/ha) [in 60 mm water] + metam-sodium (125 kg/ha)
[microspray]

[6] 1,3-D (352 kg/ha) [in 100 mm water] + metam-sodium (125 kg/ha)
[microspray]	5 reps; grapes	Meloidogyne spp. per 100 cc soil (trial
planted 1998, sampled 2001)	Schneider et al., 2002



Thompson seedless rootstock	Teleki 5C rootstock	Harmony rootstock



	[1] 144ab

[2] 215a

[3] 145ab

[4] 1def

[5] 0.2ef

[6] 6cde	[1] 261a

[2] 49b

[3] 190a

[4] 0.3c

[5] 0.6c

[6] 0.2c	[1] 0.8a

[2] 0.0a

[3] 0.1a

[4] 0.0a

[5] 0.0a

[6] 0.0a

	[1] not fumigated

[2] 1-year fallow

[3] 1-year fallow + cover crop

[4] MB (455 kg/ha) [shanked, tarp]

[5] 1,3-D (352 kg/ha) [in 60 mm water] + metam-sodium (125 kg/ha)
[microspray]

[6] 1,3-D (352 kg/ha) [in 100 mm water] + metam-sodium (125 kg/ha)
[microspray]	5 reps; grapes	Tylenchulus semipenetrans per 100 cc soil
(trial planted 1998, sampled 2001)

	Schneider et al., 2002



Thompson seedless rootstock	Teleki 5C rootstock	Harmony rootstock



	[1] 638a

[2] 352a

[3] 463a

[4] 0.4c

[5] 3c

[6] 6b	[1] 301a

[2] 434a

[3] 342a

[4] 4b

[5] 1b

[6] 3b	[1] 913a

[2] 1123a

[3] 723a

[4] 2b

[5] 6b

[6] 7b

	

Central California Grape Winegrowers—Wine Grapes. Table C.1:
Alternatives Yield Loss Data Summary  TC " Central California
Winegrowers –Wine Grapes – 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-D (385 kg/ha)	Nematodes, roots	0-20%

 (based on research plots)	10%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha)	Nematodes, fungi, roots
0-10% 

(based on research plots)	5%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha) + metam-sodium (65 kg/ha)
Nematodes, fungi, roots	0-10% 

(based on research plots)	5%

(based on research plots)

1,3-D (350 kg/ha) + metam-sodium (125 kg/ha)	Nematodes, roots	0-10% 

(based on research plots)	5%

(based on research plots)

Overall Loss Estimate for All Alternatives to Pests	See discussion below



No alternatives are currently feasible in some orchard replant sites
(i.e., those with medium to heavy soils) and/or where township cap
restrictions apply.  In these cases losses of vines could be 20%
(McKenry, 1999).  Sites well-suited to 1,3-D should have efficacy
similar to MB.

Central California Grape Winegrowers—Wine Grapes. 17. Are There Any
Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?  TC " Central California
Winegrowers –Wine Grapes - 17. Are There Any Other Potential
Alternatives Under Development which Are Being Considered to Replace
Methyl Bromide?" \f C \l "2"  

For replant sites with light soil, and water available to moisten the
top 30 cm of soil, 1,3-D with chloropicrin or metam-sodium can be
effective treatments for replant problem.  However, in medium or heavy
soils, high moisture content below 1 to 1.5 meters usually reduces the
efficacy of 1,3-D, and precludes its use.  Fallow has potential as a
component of a management strategy and is being investigated especially
when sites are first treated with an herbicide to kill remnant roots
from previous plantings.  Earlier research indicated that nematode
control was short-lived (only up to 6 to 9 months) (McKenry, 1999). 
Rootstocks with resistance to the primary nematode pests are being
investigated.  Current research should help refine strategies for
effective use of MeBr alternatives.

Central California Grape Winegrowers—Wine Grapes. 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?  TC "Central California Winegrowers –Wine Grapes - 17.
Are There Technologies Being Used to Produce the Crop Which Avoid the
Need for Methyl Bromide?" \f C \l "2"  

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

Central California Grape Winegrowers—Wine Grapes.  Summary of
Technical Feasibility  TC " Central California Winegrowers –Wine
Grapes - Summary of Technical Feasibility" \f C \l "2"  

Approximately 7% (4656 ha) of the total area (66,800 ha) planted to
central California wine grapes is replanted every year.  Of this,
approximately 15% (700 ha) is fumigated, and 60% of this area (420 ha)
is fumigated with MB.  

Optimal pest management strategies need to be followed at time of
orchard establishment.  The history of 1,3-D use in California suggests
that at optimal conditions it (or in combination with another chemical)
is the best alternative to MB.  However, the reality of California
orchard and vineyard locations precludes some growers taking advantage
of the material since either township caps or soil texture/moisture
issues reduce efficacy or legal availability to 1,3-D.  Therefore, for
2008, for wine grape vineyard replant, where alternatives are not
effective, there is a critical need for MeBr for establishment of
commercial operations.

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



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



California Walnut Commission. Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "California Walnut Commission -
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 pests 	Specific reasons
why methyl bromide is needed 



California Walnut Commission

(Central Valley and coastal valleys)	Replant problem caused by
interactions of pests and environment, primarily Nematodes: (in ~85% of
orchards) Pratylenchus vulnus, Mesocriconema xenoplax, Meloidogyne spp.

	Township caps and unacceptable soil moisture (>12% at over 1 meter
depths in medium and heavy soils) limit 1,3-D use (the best alternative)
to approximately only 30% of orchard land.  

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

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



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



The typical practice of replanting orchards with MeBr is to remove the
old trees after the final harvest.  The soil is harrowed and the
remaining roots are removed.  The soil is fumigated in the late fall and
the trees are replanted in the early winter.  Some growers routinely
fallow land before replant.

When using 1,3-D + chloropicrin (the best alternative where conditions
permit), the old trees are removed with as many of the roots as time and
resources permit.  After the removal of the old trees the soil is ripped
and then irrigated to allow the soil to settle.  Any roots that are
pulled to the surface are removed, and the soil is graded.  

MB is considered critical particularly in situations where walnut
orchards are replanted with walnuts, as trees are more likely to be
exposed to greater pest problems than planting walnuts in areas
previously planted with other crops (McKenry, 1999; and personal
communication, 2005).  Walnuts are planted in rows varying in distance
between rows from six to 12 meters, but fumigation may occur only in
strips of 3 meters.  1,3-D may be strip or broadcast applied instead of
MeBr in areas where there are no restrictions and soil conditions permit
efficacy.  

Market forces drive yearly replant when future demand is predicted to be
high, more land will be planted, or replanted to new walnut orchards. 
New sites, rather than replanted walnut orchards, may comprise up to 75%
of walnut growers new plantings.  These areas generally would not be
considered critical for MeBr use.  Strip applications of 1,3-D, rather
than MB, may comprise 50% of fumigated orchard land.  Approximately 12%
of growers do not fumigate.

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

Characteristics	Region B

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	English walnuts
on black/Paradox rootstocks

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

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	None

Soil Types:  (Sand, loam, clay, etc.)	Light (30%), medium (40%), heavy
(30%)

Frequency of methyl bromide Fumigation: (e.g. every two years)	Once in
orchard life (up to 40 years)

Other relevant factors:	No other relevant factors were identified by the
applicant.



California Walnut Commission. Table 11.2 Characteristics of Climate and
Crop Schedule  TC "California Walnut Commission - 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

	USDA plant hardiness zones 9a, 9b

Rainfall (mm):30-60 cm/yr	16	72.1	17.3	0	trace	1.0	trace	0	44.7	56.9	9.9
30.5

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

Fumigation Schedule	1st year, land preparation and fumigation

Planting 

Schedule	Occurs 2nd year, after fumigation

Key Market Window:	Not applicable

*For Fresno, California

California Walnut Commission.  11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "California Walnut Commission.  11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"   

In approximately 70% of walnut orchard situations (Central Valley and
coastal valleys in California) surface soil moisture and restrictions
due to township caps, make the best alternative, 1,3-D, unlikely to
replace MeBr for the 2008 replant season.

California Walnut Commission. 12. Historic Pattern of Use of Methyl
Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested  TC " California Walnut Commission - 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 Walnut Commission. Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "California Walnut Commission - Table 12.1 Historic
Pattern of Use of Methyl Bromide" \f F \l "1"  

Years:	1999	2000	2001	2002	2003	2004

Area Treated (hectares)	348 	89 	139 	201 	180 	182 

	Hectares and Use Rate presented are for the treated strip. 

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	~75% replant is strip treatment	~75% replant is strip
treatment	~75% replant is strip treatment	~75% replant is strip
treatment	~75% replant is strip treatment	~75% replant is strip
treatment

Amount of methyl bromide active ingredient used 

(total kg)	 156,162 	 39,687 	24,308 	59,589 	33,074 	39,164 

formulations of methyl bromide (methyl bromide /chloropicrin)	98:2	98:2
98:2	98:2	98:2	98:2

Method by which methyl bromide applied)	shank injected	shank injected
shank injected	shank injected	shank injected	shank injected

Application rate [Active Ingredient] (kg/ha)	448 	448 	175 	296 	184 
215 



California Walnut Commission. 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:  TC " California Walnut
Commission - 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 Walnut Commission Region C. Table 14.1: Technically
Infeasible Alternatives Discussion  TC "California Walnut Commission –
Table 14.1: Technically Infeasible Alternatives Discussion" \f F \l "1" 


Name of Alternative	Discussion

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



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



California Walnut Commission. Table 15.1: Present Registration Status of
Alternatives  TC " California Walnut Commission – 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:

Sodium azide	No registration package has been received	No	Unknown

Propargyl bromide	No registration package has been received	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

Muscador albus Strain QST 20799 	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



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



California Walnut Commission. Table 16.1: Effectiveness of Alternatives
– Key Pest 1: nematodes.  TC " California Walnut Commission – Table
16.1: Effectiveness of Alternatives – Key Pest 1" \f F \l "1"  

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

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Trials	Disease (% or
rating)	# of Trials	Actual Yields (t/ha)	Citation

see Table 16.1 for Regions A (Stone Fruit), B (Grapes), & D (Almonds) 



California Walnut Commission. Table C.1: Alternatives Yield Loss Data
Summary  TC " California Walnut Commission – 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-D (385 kg/ha)	Nematodes, roots	0-20%

(based on research plots)	10%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha)	Nematodes, fungi, roots
0-10%

(based on research plots)	5%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha) + metam-sodium (65 kg/ha)
Nematodes, fungi, roots	0-10%

(based on research plots)	5%

(based on research plots)

1,3-D (350 kg/ha) + metam-sodium (125 kg/ha)	Nematodes, roots	0-10%

(based on research plots)	5%

(based on research plots)

Overall Loss Estimate for All Alternatives to Pests	See discussion below



No alternatives are currently feasible in numerous orchard replant sites
(i.e., those with medium to heavy soils) and/or where township cap
restrictions apply.  In these cases losses of trees are likely to be
greater than 20% (McKenry, 1999).  Listed above are alternatives for
sites where soils are amenable to 1,3-D and where township caps are not
applicable.  Sites well-suited to 1,3-D should have efficacy similar to
MB.

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

The use of 1,3-D is limited by township caps in the prime areas of
walnut production in California (Central and Coastal valleys).  In
addition, 1,3-D use may be limited by moisture factors when 1,3-D is not
an effective nematicide in heavy soils of an orchard and soils with
greater than 12% moisture.  In this situation MeBr is critical and its
use is of considerable effectiveness in light of the longevity of walnut
orchards and importance of early tree health to long producing orchards.
 It requires 8-10 years for trees to produce a saleable crop and the
failure to start the orchard with healthy trees or in a pathogen
infested site will reduce production over its 40 year life.  Improper
orchard replant can lead to additional replant within 10 years with no
production in the interim.

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


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

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

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

Where alternatives, such as 1,3-D and chloropicrin ,are not effective
(e.g., sites with medium to heavy soils, and/or where township cap
restrictions apply), MeBr will be critical to the healthy establishment
of walnut orchards in 2008.  However, approximately 75% of growers may
use strip treatment and of those, 25-50% of this area currently may be
treated with 1,3-D and not MeBr (McKenry, 2005, personal communication).
 McKenry (1999) estimated that 85% of land used for California walnuts
was infested with one or more of three important nematode pests
(Pratylenchus vulnus, Criconemella xenoplax, or Meloidogyne spp.). 
Studies of individual pest populations tell only a small portion of the
story of replant complex, since individual pests cause only a portion of
the adverse growth effects.  As with the stone fruit orchards, orchard
replant problems for walnut orchards are a result of biological and
environmental causes, and probably interactions of these forces.  There
are no commercially available resistant rootstocks that can provide
consistent relief from orchard replant problem in walnuts.  It is clear
that the long life of orchards requires that optimal pest management
strategies be employed to overcome replant disorder during the one
opportunity available—at orchard establishment.  The long history of
1,3-D use in California suggests that at optimal conditions it (or in
combination with another chemical) is the best chemical alternative to
MB.  However, the reality of California orchard locations precludes some
growers taking advantage of the material since either township caps or
soil texture/moisture issues reduces efficacy or legal availability to
1,3-D.  Therefore, for 2008, for walnut replant where alternatives are
not effective, there is a critical need for MeBr for establishment of
commercial operations.

Almond Hullers & Processors Association. Part B: Crop Characteristics
and Methyl Bromide Use  TC "Almond Hullers & Processors Association -
Part B: Crop Characteristics and Methyl Bromide Use" \f F \l "1"    TC
"Almond Hullers & Processors Association - Part B: Crop Characteristics
and Methyl Bromide Use" \f C \l "1"  



Almond Hullers & Processors Association. 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request 
TC "Almond Hullers & Processors Association - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request" \f C \l "2"  :



Almond Hullers & Processors Association. Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request  TC " Almond Hullers &
Processors Association - 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 pests 	Specific reasons
why methyl bromide is needed 

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



Almond Hullers & Processors Association.   11. (i) Characteristics of
Cropping System and Climate  TC "Almond Hullers & Processors Association
- 11. Characteristics of Cropping System and Climate" \f C \l "2"  



The demand for almonds in the future is increasing, thus, after 2005, it
is estimated that there will be numerous orchards replanted to almonds
that were originally planted from 1979-1982, in addition to other
orchards that will be replanted to almonds.  

The typical practice of replanting orchards with MeBr is to remove the
old trees after the final harvest.  The soil is harrowed and the
remaining roots are removed.  The soil is fumigated in the late fall and
the trees are replanted in the early winter.  When using fumigants,
growers might fallow after tree removal and before replanting new trees.

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

Almond Hullers & Processors Association. Table 11.1: Characteristics of
Cropping System  TC "Almond Hullers & Processors Association - Table
11.1: Characteristics of Cropping System" \f F \l "1"  

Characteristics	Region D

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

Annual or Perennial Crop: (# of years between replanting) 	perennial
(25-30 years)

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	none

Soil Types:  (Sand, loam, clay, etc.)	light, medium, heavy

Frequency of methyl bromide Fumigation: (e.g. every two years)	once in
25 to 30 years

Other relevant factors:	No other relevant factors were identified by the
applicant.



Almond Hullers & Processors Association. Table 11.2 Characteristics of
Climate and Crop Schedule  TC " Almond Hullers & Processors Association
- 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

	USDA plant hardiness zones 9a, 9b

Rainfall (mm):30-60 cm/yr	16	72.1	17.3	0	trace	1.0	trace	0	44.7	56.9	9.9
30.5

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

Fumigation Schedule	1st year, land preparation and fumigation

Planting 

Schedule	Occurs 2nd year, after fumigation

Key Market Window:	Not applicable

*For Fresno, California

Almond Hullers & Processors Association.  11. (ii) Indicate if any of
the above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Almond Hullers & Processors Association.  11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?" \f C \l "2"  

Orchards replanted into previous orchard land (the typical situation in
California) must reduce pathogen populations (mostly nematodes and
fungi) and nutrient sources of old orchard tree roots and root remnants.
 This requires an effective material that is volatile and can penetrate
into the soil to reach these plant materials.  In sandy, loam soils,
where restrictions do not apply, 1,3-D may be an effective alternative
that can penetrate to the target areas.  In other situations, this
compound and other alternatives are not able to move sufficiently
through the soil to remove the problem pests.  Thus, there is a critical
need for MeBr for almond replant for 2008.  For sites that are not
amenable to alternative chemical fumigants, MeBr is a key component of
almond.

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



Almond Hullers & Processors Association.  Table 12.1 Historic Pattern of
Use of Methyl Bromide  TC " Almond Hullers & Processors Association -
Table 12.1 Historic Pattern of Use of Methyl Bromide" \f F \l "1"  

Years	1999	2000	2001	2002	2003	2004 a

Area Treated (hectares)	2,046	1,430	496	819	278	211

	Hectares and Use Rate presented are for the treated strip.

ratio of Flat Fumigation b methyl bromide use to strip/bed use if strip
treatment is used	Strip treatment (65% of hectare treated)	Strip
treatment (65% of hectare treated)	Strip treatment (65% of hectare
treated)	Strip treatment (65% of hectare treated)	Strip treatment (65%
of hectare treated)	Strip treatment (65% of hectare treated)

Amount of methyl bromide active ingredient used 

(total kg)	703,401	497,810	174,502	217,032	85,375	64,088

formulations of methyl bromide (methyl bromide/chloropicrin)	98:2	98:2
98:2	98:2	98:2	98:2

Method by which methyl bromide applied 	shank injected	shank injected
shank injected	Shank injected	Shank injected	Shank injected

Application rate [Active Ingredient] (kg/ha*)	344	348	352	265	307	304

Actual dosage rate of Active Ingredient (g/m2)*	34.4	34.8	35.2	26.5	30.7
30.4

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

a Data from preliminary estimates by California Department of Pesticide
Regulation.

b Various methods are used depending on the particular situation;
fumigation can be flat fumigation, strip, or even “by the hole” (for
individual tree replacement; MeBr is the only product that has
acceptable technology for hole application—approximately 0.5 kg/tree).

Almond Hullers & Processors Association. Part C: Technical Validation 
TC " Almond Hullers & Processors Association - Part C: Technical
Validation" \f F \l "1"    TC " Almond Hullers & Processors Association
- Part C: Technical Validation" \f C \l "1"  



Almond Hullers & Processors Association. 13. Reason for Alternatives Not
Being Feasible  TC " Almond Hullers & Processors Association - 13.
Reason for Alternatives Not Being Feasible" \f C \l "2"  



Almond Hullers & Processors Association. Table 13.1: Reason for
Alternatives Not Being Feasible  TC " Almond Hullers & Processors
Association – 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-D	Can be effective in orchards with light soils; currently not
feasible in medium or heavy soils; usually more effective when
formulated with chloropicrin; subject to township caps and specific
moisture requirements.  (e.g., Browne et al., 2003a).  Promising results
have been reported with 1,3-D/chloropicrin for treatment of replant
disorder (Browne et al., 2003a, 2004)	Possibly, when able to optimize
application methods

Chloropicrin	May perform acceptably alone when fungi are primary cause
of orchard replant problem; for nematode causation, MeBr or 1,3-D is
preferred.  Promising results have been reported with some rates of
chloropicrin for treatment of replant disorder (Browne et al., 2003a,
2004)	Possibly, when able to optimize application methods

Metam-sodium	Not an effective nematicide since it can not reach deep
areas of soil, which is the primary cause of orchard replant problems;
generally not effective in areas where water percolation is a problem
(e.g., clay soils).	No

Dazomet	This alternative has been examined by researchers and is
inconsistent in field trials.  This has been deemed not feasible due to
lack of performance in field trials and inability to penetrate and kill
nematodes at depths required for orchard replant acceptability.  This
product requires that there be uniform saturation of the granules to
ensure that the product will perform consistently.  This is not feasible
in a typical orchard situation.	No

Nematicides	Other nematicides (besides 1,3-D) have limited use due to
their lack of performance or due to regulatory issues.  Therefore, this
product was deemed not feasible	No

Non Chemical Alternatives  

Fallow, or crop rotation	Not sufficient alone; sometimes done regardless
of fumigant that follows; may require 4-10 year fallow for some crops
(McKenry, 1999) and may not be sufficient even then; may provide partial
control in some crops, however, economically difficult for grower to
sustain (Browne et al., 2002b; Trout et al., 2002).  Some research
suggests that short term rotations of some crops can reduce replant
disorder, but large scale studies need to be completed (Browne et al.,
2004).	No

Rootstock	Similar situation to stone fruit, rootstocks can help reduce
some problem nematodes, but are not tolerant to an array of pests, and
do not address overall replant “complex” (Browne et al., 2003a). 
Initial results of research examining cover crops suggest reduction of
replant disorder when wheat is incorporated into soil prior to planting
nematode tolerant rootstocks (Browne, 2003b).  However, this research
must be continued, and results confirmed, before commercial application
can be accepted. 	No

Biofumigation, solarization, steam, Biological Control, cover crops and
mulching, crop rotation / fallow, crop residue and compost,
substrate/plug plants, plowing/tillage, resistant cultivars,
grafting/resistant rootstock, physical removal, organic
amendments/compost, general IPM	Each of the not-in-kind alternatives
were listed as options for replacement of MB.  Many of these
alternatives are currently being employed with current replant
practices.  Alternatives such as biofumigation, solarization, and steam
are not feasible due to planting times, one time fumigation requirement
per orchard (steam treatment), and inability to attain sufficient
biomass of plant material (biofumigation).  Biological control may have
promise, but research has not identified agents that can be used on a
commercial scale or that work consistently well.  The University of
California is investigating biological control of major fungal
pathogens, but this work is still in the early stages of research.  As
such, MeBr is currently considered critical to the industry	No

Combinations of Alternatives

1,3-D + chloropicrin	Effective against nematodes, fungi, and to kill
remnant roots when 1,3-D is used in orchards with light soils; not
feasible in medium or heavy soils; subject to township caps and specific
moisture requirements.  Promising results from research trials indicated
that efficacy may be improved by refining application protocols and use
rates (see e.g., Browne et al., 2003a, 2004).	Possibly, when able to
optimize application methods, if no legal restrictions apply and where
soil type is amenable

1,3-D + chloropicrin + metam-sodium



1,3-D + metam-sodium



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

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



Almond Hullers & Processors Association. Table 14.1: Technically
Infeasible Alternatives Discussion  TC " Almond Hullers & Processors
Association – Table 14.1: Technically Infeasible Alternatives
Discussion" \f F \l "1"  

Name of Alternative	Discussion

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



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



Almond Hullers & Processors Association. Table 15.1: Present
Registration Status of Alternatives  TC " Almond Hullers & Processors
Association – Table 15.1: Present Registration Status of Alternatives"
\f F \l "1"  

Name of Alternative	Present Registration Status

State if registered for this crop, registered for crop but use
restricted, registered for other crops but not target crop, or not
registered	Registration being considered by national authorities? (Y/N)
Date of possible future registration:

Sodium azide	No registration package has been received	No	Unknown

Propargyl bromide	No registration package has been received	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

Muscador albus Strain QST 20799 	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



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



Almond Hullers & Processors Association. Table 16.1: Effectiveness of
Alternatives – Replant Disorder.  TC " Almond Hullers & Processors
Association – Table 16.1: Effectiveness of Alternatives – Replant
Disorder" \f F \l "1"  

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

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Trials	Disease (% or
rating)	# of Trials	Actual Yields (t/ha)	Citation

fungal pathogens

[1] MB (409 kg/ha)

[2] chloropicrin (425 kg/ha) 

[3] 1,3-D (409 kg/ha)

[4] non-fumigated	Almond (Marianna 2624 rootstock), 2001;

4 reps, research plots (19 m x 22 m), no tarp; 	Trunk diameter (mm)
(increase after 8 months post-fumigation)

[1] 4b

[2] 10c

[3] 2a

[4] 1a	same	Trees (%) w/growth >1.5 m height (in 8 months):

[1] 21%a

[2] 96%b

[3] 1%a

[4] 2%a	Browne et al., 2002b

fungal pathogens

[1] MB (0.34 kg/tree) + chloropicrin (0.11 kg/tree)

[2] chloropicrin (0.45 kg/tree) 

[3] non-fumigated 	Almond (Marianna 2624 rootstock), 2002;

4 reps, research plots (19 m x 22 m), no tarp; 	Trunk diameter (mm)
(increase after 8 months post-fumigation)

[1] 15b

[2] 14b

[3] 4a

	same	Trees (%) w/growth >1.5 m height (in 8 months):

[1] 94%

[2] 83%

[3] 6%

	Browne et al., 2002b



Almond Hullers & Processors Association. Table C.1: Alternatives Yield
Loss Data Summary  TC " Almond Hullers & Processors Association –
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-D (385 kg/ha)	Nematodes, roots	0-20% 

(based on research plots)	10%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha)	Nematodes, fungi, roots
0-10% 

(based on research plots)	5%

(based on research plots)

1,3-D (265 kg/ha) + chloropicrin (150 kg/ha) + metam-sodium (65 kg/ha)
Nematodes, fungi, roots	0-10% 

(based on research plots)	5%

(based on research plots)

1,3-D (350 kg/ha) + metam-sodium (125 kg/ha)	Nematodes, roots	0-10% 

(based on research plots)	5%

(based on research plots)

Overall Loss Estimate for All Alternatives to Pests	See discussion below

*1,3-D is not a feasible alternative where soil moisture is not optimal
or where township caps restrict its use.

Alternatives are used in most replant sites.  MeBr is critical for 2008
for sites where conditions do allow effective use of alternatives (those
with medium to heavy soils, and/or where township cap restrictions
apply).  In these cases losses of trees can be greater than 20%
(McKenry, 1999).  Sites well-suited to 1,3-D should have efficacy
similar to MB.

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

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

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

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

Almond Hullers & Processors Association. Summary of Technical
Feasibility  TC "Almond Hullers & Processors Association - Summary of
Technical Feasibility" \f C \l "2"  

Currently, no alternatives are feasible in approximately 7% of almond
orchard replant sites (567 ha/8540 ha total replant).  In these cases
losses of trees are likely to be greater than 20% (McKenry, 1999).  As
with the other commodities of the orchard replant sector, replant
problems for almonds are a result of biological and environmental
causes, and interactions of these forces.  Studies of individual pest
populations tell only a small portion of the story of replant complex,
since individual pests can cause only a portion of the adverse growth
effects.  Nevertheless, approximately 35% of hectares planted in almonds
have infestations of Criconemella xenoplax and/or Pratylenchus vulnus
(McKenry, 1999).  Nemaguard, the most commonly used almond rootstock,
has resistance only to Meloidogyne spp.  As such, it is clear that the
long life of orchards requires that optimal pest management strategies
be employed to overcome replant disorder during the one opportunity
available—at orchard establishment.  The long history of 1,3-D use in
California suggests that at optimal conditions it (or in combination
with another chemical) is the best alternative to MB.  However, the
reality of California orchards precludes some growers from taking
advantage of the material since either township caps or soil
texture/moisture issues reduce efficacy or legal availability to 1,3-D. 
Therefore, in 2008, for almond replant where alternatives are not
effective, there is a critical need for MeBr for establishment of
commercial operations.  Currently, research is being conducted examining
non-fumigant treatments.  Some non-chemical treatments have shown
promise in small-scale research trials, such as use of crop rotation
(Browne et al., 2003b, 2004).  Continued studies will have to be
conducted before these types of treatments are developed for commercial
application.

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

Research is being conducted among all the orchard replant commodities to
address the orchard replant disorder complex.  Fumigation is only one
means of achieving optimal orchard establishment.  Other practices can
reduce long-term effects of pathogens and biotic and abiotic causes of
this disorder.  Such practices as fallowing land, crop rotation,
strategic fertilization, water management, development of tolerant
rootstocks, deep injection of chemicals—all will reduce the emissions
of MeBr (or other toxic chemicals that might be alternatives).  Current
research also includes studies with soil amendments, such as thiosulfate
fertilizers that may act as barriers or absorbents of MeBr and reduce
emissions.

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?	VIF and high
density tarps being tested (almond) 	Testing reduction from 98:2 to
75:25 (almond)	When fungal pathogens are main concern chloropicrin
percent is increased	Fumigation is applied only once in 20-40 years for
this sector

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Testing	Deep injection; use of
additional herbicides to kill remnant roots to increase efficacy of MeBr
and other fumigants; reduction of MeBr in formulation	Deep injection,
increased chloropicrin in formulation to 50:50 being examined	Fumigation
is applied only once in 20-40 years for this sector

Other measures (please describe)	Unidentified	Combination of chemicals
and cultural practices such as fallow + alternatives or reduced MB
Combination of chemicals and cultural practices such as fallow +
alternatives or reduced MB	Fumigation is applied only once in 20-40
years for this sector



Various techniques are being studied to improve the efficacy of
alternatives.  Primary is the development of application techniques to
improve delivery of the best alternatives, such as 1,3-D and
metam-sodium (e.g., McKenry, 2001).  In situations with no township
caps, and where soil moisture is less than 12% at 1.5 meters, 1,3-D may
be effective—this would occur generally in orchards with light, sandy
soils.  Although the cropping system of these orchards makes the use of
MeBr cost effective, current research (e.g., Browne et al., 2004;
Lampinen et al., 2004; Schneider et al., 2004) is advancing the
understanding of alternatives in orchard replant.  This research will
ultimately result in the development of protocols that will be adapted
for commercial use.

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"    

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

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



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



Table 21.1: Costs of Alternatives Compared to Methyl Bromide Over 3-Year
Period

This table is not included since none of the alternatives are
technically feasible.  See Summary of Economic Feasibility below.

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



Table 22.1: Year 1 Gross and Net Revenue

Table 22.2: Year 2 Gross and Net Revenue

Table 22.3: Year 3 Gross and Net Revenue

These tables are not included since none of the alternatives are
technically feasible.  See Summary of Economic Feasibility below.

Measures of Economic Impacts of Methyl Bromide Alternatives  TC
"Measures of Economic Impacts of Methyl Bromide Alternatives" \f C \l
"2"  



California Grape and Tree Fruit League – Stone Fruit - Table E.1:
Economic Impacts of Methyl Bromide Alternatives

California Grape and Tree Fruit League – Raisin and Table Grapes -
Table E.2: Economic Impacts of Methyl Bromide Alternatives

California Walnut Commission - Table E.3: Economic Impacts of Methyl
Bromide Alternatives

Almond Hullers & Processors Association - Table E.4: Economic Impacts of
Methyl Bromide Alternatives

These tables are not included since none of the alternatives are
technically feasible.  See Summary of Economic Feasibility below.

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

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

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

An economic analysis was not done because most of the losses cannot be
quantified since there are no data to substantiate the magnitude of
these losses.  These losses include: 

Delayed planting

Fallow

Additional use of herbicides

Tree loss

Replant costs to replace tree losses

Loss of trees replanted

Yield loss of fruit or nuts

Delayed achievement of full yield potential

Earlier loss of productivity of whole orchard

A number of soil pathogens and nematodes, many still poorly understood,
occur over the lifespan of an orchard.  It is important that the grower
be able to reduce the amount of inoculum in the soil to ensure that the
young trees have the opportunity to get off to a vigorous start to
ensure survival.  1,3 D, chloropicrin, and metam-sodium have shown
promise on some soil types, but long-term research on tree survival and
on yield impacts is incomplete.  If the alternatives do not work as
effectively as MB, then it is possible that other losses could occur,
such as additional replanting, higher yield losses, and shorter lifespan
of the whole orchard reducing the ability to amortize the initial
investment costs.

Part F. Future Plans  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"    

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

The amount of MeBr requested for research purposes is considered
critical for the development of effective alternatives.  Without MeBr
for use as a standard treatment, the research studies can never address
the comparative performance of alternatives.  This would be a serious
impediment to the development of alternative strategies.  The U.S.
government estimates that orchard replant research will require 1658 kg
per year of MeBr for 2008.  This amount of MeBr is necessary to conduct
research on alternatives and is in addition to the amounts requested in
the submitted CUE applications.

24. Are There Plans 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"   

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

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

The U.S. Nomination for MeBr is for orchard replant areas where
alternatives are not suitable, either because of legal restrictions or
physical features, such as unacceptable soil type.  The critical use
exemption nomination for orchard replant has been reviewed by the U.S.
government and meets the guidelines of The Montreal Protocol on
Substances That Deplete the Ozone Layer.  This use is considered
critical in the designated areas because there are no effective
alternatives or substitutes available.  MeBr is critical in the orchards
where 1,3-D will not be an effective treatment to orchard replant
disorder, such as where orchards have medium to heavy soils, and/or
township cap restrictions for 1,3-D.  Under these circumstances MeBr is
critical for use in 2008, and its absence will result in a significant
burden for the orchard crop growers of California.

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

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

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

Browne, G., Trout, T., Becherer, H., McLaughlin, S., Lee, R., Gartung,
J., Gillis, M., Schneider, S., and Bulluck, R. 2003b. Pre-plant cropping
and fallowing effects on severity of Prunus replant disease. Annual
International Research Conference on Methyl Bromide Alternatives (2003).
  HYPERLINK "http://mbao.org/"  http://mbao.org/ 

Browne, G. T., Connell, J. H., Bulluck, L. R., Trout, T. J., and
Schneider, S. M. 2002a. Management and etiology of replant disorder on
almond and peach. Annual International Research Conference on Methyl
Bromide Alternatives (2002).   HYPERLINK "http://mbao.org/" 
http://mbao.org/ 

Browne, G., Trout, T. and Bulluck, R. 2002b.  Cultural control and
etiology of replant disease of Prunus spp. University of California,
Sustainable Agriculture Research and Education Program.    HYPERLINK
"http://www.sarep.ucdavis.edu/grants/reports/mebr/browne/browne.html" 
http://www.sarep.ucdavis.edu/grants/reports/mebr/browne/browne.html 

Drenovsky, R. E., Duncan, R. A., and Scow, K. M. 2005. Soil
sterilization and organic carbon, but not microbial inoculants, change
microbial communities in replanted peach orchards. California
Agriculture 59 (3):176-181.   HYPERLINK
"http://californiaagriculture.ucop.edu/0503JAS/pdfs/SoilSterilization.pd
f" 
http://californiaagriculture.ucop.edu/0503JAS/pdfs/SoilSterilization.pdf


Duncan, R. A., McKenry, M., and Scow, K. 2003. Evaluation of pre- and
post-plant treatments for replanted peach orchards. Annual International
Research Conference on Methyl Bromide Alternatives (2003).   HYPERLINK
"http://mbao.org/"  http://mbao.org/ 

Ferris, H. and Walker, M. A. 2002. Development of grape rootstocks with
broad and durable nematode resistance. University of California
Sustainable Agriculture Research and Education Program. Final Report
(updated May, 2003).   HYPERLINK
"http://www.sarep.ucdavis.edu/Grants/Reports/MeBr/Ferris/ferris.html" 
http://www.sarep.ucdavis.edu/Grants/Reports/MeBr/Ferris/ferris.html 

Gan, J., Becker, J. O., Ernst, F. F., Hutchinson, C., Knuteson, J. A.,
and Yates, S. R. 2000. Surface application of ammonium thiosulfate to
reduce 1,3-dichloropropene volatilization from soil. Pest Management
Science 56:264-270.

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

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

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

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

McKenry, M., Buzo, T., Kaku, and S. 1995. First-year evaluation of tree
and vine growth and nematode development following 17 pre-plant
treatments. In: University of California Plant Protection Quarterly.
Vol. 5, No. 4.   HYPERLINK "http://www.uckac.edu/ppq/PDF/95oct.pdf" 
http://www.uckac.edu/ppq/PDF/95oct.pdf 

Schneider, S., Trout. T., Browne, G., Ajwa, H., and Sims, J. 2004.
Vineyard replant—performance of methyl bromide alternatives over time.
Annual International Research Conference on Methyl Bromide Alternatives
(2004).   HYPERLINK "http://mbao.org/"  http://mbao.org/ 

Schneider, S., Trout. T., Browne, G., Ajwa, H., and Sims, J. 2003.
Vineyard replant field trials. Annual International Research Conference
on Methyl Bromide Alternatives (2003).   HYPERLINK "http://mbao.org/" 
http://mbao.org/ 

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

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

Schneider, Ajwa, H. Trout, T. and Sims, J. 1999. Grape replant
disorder—an integrated management approach.  USDA, Agricultural
Research Service, Methyl Bromide Alternatives.   HYPERLINK
"http://www.ars.usda.gov/is/np/mba/oct99/grape.htm" 
http://www.ars.usda.gov/is/np/mba/oct99/grape.htm 

Trout. T., Ajwa, H., Schneider, S., Gartung, J. 2002. Fumigation and
fallowing effects on replant problems in California peach. Annual
International Research Conference on Methyl Bromide Alternatives (2002).
  HYPERLINK "http://mbao.org/"  http://mbao.org/ 

APPENDIX A.  2008 Methyl Bromide Usage Newer Numerical Index (BUNNI). 
TC "APPENDIX A.  2008 Methyl Bromide Usage Newer Numerical Index
(BUNNI)." \f C \l "1"  

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

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.

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

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.

Quarantine and Pre-Shipment Removed? – This indicates whether the
Quarantine and pre-shipment (QPS) hectares subject to QPS treatments
were removed from the nomination.

Most Likely Combined Impacts (%) – 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.

Total 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.

Most Likely Baseline Transition – Most Likely Baseline Transition
amount was determined by the DELPHI process and was calculated by
determining the maximum share of industry that can transition to
existing alternatives.

(%) Able to Transition – Maximum share of industry that can transition

Minimum # of Years Required – The minimum number of years required to
achieve maximum transition.

(%) Able to Transition per Year – The Percent Able to Transition per
Year is the percent able to transition divided by the number of years to
achieve maximum transition.

EPA Adjusted Use Rate - Use rate is the lower of requested use rate for
2008 or the historic average use rate or is determined by MBTOC
recommended use rate reductions.

EPA Adjusted Strip Dosage Rate – The dosage rate is the use rate
within the strips for strip / bed fumigation.

2008 Amount of Request – The 2008 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. 

EPA Preliminary Value – The EPA Preliminary Value is the lowest of the
requested amount from 2005 through 2008 with MBTOC accepted adjustments
(where necessary) included in the preliminary value.

EPA Baseline Adjusted Value – The EPA Baseline Adjusted Value has been
adjusted for MBTOC adjustments, QPS, Double Counting, Growth, Use Rate/
Strip Treatment, Miscellaneous adjustments, MBTOC recommended Low
Permeability Film Transition adjustment, and Combined Impacts.

EPA Transition Amount – The EPA Transition Amount is calculated by
removing previous transition amounts since transition was introduced in
2007 and removing the amount of the percent (%) Able to Transition per
Year multiplied by the EPA Baseline Adjusted Value. 

Most Likely Impact Value – The qualified amount of the initial request
after all adjustments have been made given in total kilograms of
nomination, total hectares of nomination, and final use rate of
nomination.

Sector Research Amount – The total U.S. amount of methyl bromide
needed for research purposes in each sector.

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

 PAGE   

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U.S. Orchard Replant

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