United States Response to Questions (received June 2006) for Parties on
the Methyl Bromide CUNs for 2008 Use Season 

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                                   CUN:



Nominating Party:	The United States of America

Brief Descriptive Title of Nomination:	Response to Questions (received
June 2006) for Parties on the Methyl Bromide CUNs for 2008 Use Season
– United States 

 (Submitted in 2006)



Nominating Party Contact Details

Contact Person:	Hodayah Finman

Title:	Foreign Affairs Officer

Address:	Office of Environmental Policy

	US Department of State

	2201 C Street N.W. Room 2658

	Washington, DC 20520

	USA.

Telephone:	(202) 647-1123

Fax:	(202) 647-5947

E-mail:	finmanhh@state.gov



	

Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Division Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	US Environmental Protection Agency

	Mail Code 7503P

	Washington, DC 20460

	USA.

Telephone:	(703) 308-8200

Fax:	(703) 308-8090

E-mail:	  HYPERLINK "mailto:richard.kegwin@epa.gov" 
richard.kegwin@epa.gov 



	

TABLE OF CONTENTS

  TOC \f \h \z    HYPERLINK \l "_Toc143617299"  GENERAL QUESTIONS	 
PAGEREF _Toc143617299 \h  4  

  HYPERLINK \l "_Toc143617300"  PREPLANT SOIL QUESTIONS	  PAGEREF
_Toc143617300 \h  13  

  HYPERLINK \l "_Toc143617301"  US CUCURBITS – FIELD	  PAGEREF
_Toc143617301 \h  13  

  HYPERLINK \l "_Toc143617302"  US PEPPERS – FIELD	  PAGEREF
_Toc143617302 \h  15  

  HYPERLINK \l "_Toc143617303"  US EGGPLANT- FIELD	  PAGEREF
_Toc143617303 \h  19  

  HYPERLINK \l "_Toc143617304"  US NURSERY STOCK - FRUIT TREES, NUT AND
FLOWER NURSERIES	  PAGEREF _Toc143617304 \h  23  

  HYPERLINK \l "_Toc143617305"  US FOREST NURSERIES	  PAGEREF
_Toc143617305 \h  23  

  HYPERLINK \l "_Toc143617306"  US ORCHARD REPLANT	  PAGEREF
_Toc143617306 \h  24  

  HYPERLINK \l "_Toc143617307"  US ORNAMENTALS	  PAGEREF _Toc143617307
\h  26  

  HYPERLINK \l "_Toc143617308"  Additional Comments from MBTOC	  PAGEREF
_Toc143617308 \h  29  

  HYPERLINK \l "_Toc143617309"  US STRAWBERRY FRUIT – FIELD	  PAGEREF
_Toc143617309 \h  30  

  HYPERLINK \l "_Toc143617310"  US STRAWBERRY RUNNERS	  PAGEREF
_Toc143617310 \h  40  

  HYPERLINK \l "_Toc143617311"  US SWEET POTATO TRANSPLANTS	  PAGEREF
_Toc143617311 \h  41  

  HYPERLINK \l "_Toc143617312"  US TOMATOES – FIELD	  PAGEREF
_Toc143617312 \h  41  

  HYPERLINK \l "_Toc143617313"  US TURF / SOD RECONSIDERATION	  PAGEREF
_Toc143617313 \h  45  

  HYPERLINK \l "_Toc143617314"  POST HARVEST QUESTIONS	  PAGEREF
_Toc143617314 \h  48  

  HYPERLINK \l "_Toc143617315"  US COUNTRY HAM	  PAGEREF _Toc143617315
\h  48  

  HYPERLINK \l "_Toc143617316"  Dosage Rate	  PAGEREF _Toc143617316 \h 
50  

  HYPERLINK \l "_Toc143617317"  Frequency of Fumigation	  PAGEREF
_Toc143617317 \h  51  

  HYPERLINK \l "_Toc143617318"  Historical Use	  PAGEREF _Toc143617318
\h  52  

  HYPERLINK \l "_Toc143617319"  US NPMA FOOD PROCESSING STRUCTURES	 
PAGEREF _Toc143617319 \h  52  

  HYPERLINK \l "_Toc143617320"  Questions Pertaining to All Sectors
Included in this CUN	  PAGEREF _Toc143617320 \h  53  

  HYPERLINK \l "_Toc143617321"  Trade Restrictions	  PAGEREF
_Toc143617321 \h  53  

  HYPERLINK \l "_Toc143617322"  Cheese Stores	  PAGEREF _Toc143617322 \h
 54  

  HYPERLINK \l "_Toc143617323"  Herb and Spice Facilities and
Commodities	  PAGEREF _Toc143617323 \h  55  

  HYPERLINK \l "_Toc143617324"  US COMMODITIES	  PAGEREF _Toc143617324
\h  56  

  HYPERLINK \l "_Toc143617325"  US STRUCTURES	  PAGEREF _Toc143617325 \h
 60  

  HYPERLINK \l "_Toc143617326"  Post-harvest Questions from the
TEAP/MBTOC Report May 2006	  PAGEREF _Toc143617326 \h  62  

  HYPERLINK \l "_Toc143617327"  US Commodities	  PAGEREF _Toc143617327
\h  62  

  HYPERLINK \l "_Toc143617328"  US Cocoa Beans	  PAGEREF _Toc143617328
\h  63  

  HYPERLINK \l "_Toc143617329"  US NPMA	  PAGEREF _Toc143617329 \h  64  

  HYPERLINK \l "_Toc143617330"  US Ham	  PAGEREF _Toc143617330 \h  66  

  HYPERLINK \l "_Toc143617331"  ECONOMIC QUESTIONS	  PAGEREF
_Toc143617331 \h  68  

  HYPERLINK \l "_Toc143617332"  REFERENCES	  PAGEREF _Toc143617332 \h 
74  

 

TABLE OF TABLES

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc143617333"  Table I.1
Key Pests for Cucurbits and Grafting Research Status	  PAGEREF
_Toc143617333 \h  14  

  HYPERLINK \l "_Toc143617334"  Table I.2 Resistance to Important Plant
Pathogens and Pests of Tomato in North Carolina and the Mediterranean.	 
PAGEREF _Toc143617334 \h  14  

  HYPERLINK \l "_Toc143617335"  Table I.3  Resistance of Tomato
Rootstocks to the Most Common Soil Borne Pathogens	  PAGEREF
_Toc143617335 \h  14  

  HYPERLINK \l "_Toc143617336"  Table II.1  Key Pests for Peppers and
Grafting Research Status	  PAGEREF _Toc143617336 \h  17  

  HYPERLINK \l "_Toc143617337"  Table II.2 Resistance to Important Plant
Pathogens and Pests in North Carolina and the Mediterranean.	  PAGEREF
_Toc143617337 \h  18  

  HYPERLINK \l "_Toc143617338"  Table III.3 Resistance of Tomato
Rootstocks to the Most Common Soil Borne Pathogens	  PAGEREF
_Toc143617338 \h  18  

  HYPERLINK \l "_Toc143617339"  Table III.1 Key Pests for Eggplants and
Grafting Research Status	  PAGEREF _Toc143617339 \h  21  

  HYPERLINK \l "_Toc143617340"  Table III.2 Resistance to Important
Plant Pathogens and Pests in North Carolina and the Mediterranean.	 
PAGEREF _Toc143617340 \h  22  

  HYPERLINK \l "_Toc143617341"  Table III.3 Resistance of Tomato
Rootstocks to the Most Common Soil Borne Pathogens	  PAGEREF
_Toc143617341 \h  22  

  HYPERLINK \l "_Toc143617342"  Table VII.1: Michigan Herbaceous
Perennials – Hosta –Effectiveness of Alternatives – Inula
brittannica	  PAGEREF _Toc143617342 \h  28  

  HYPERLINK \l "_Toc143617343"  Table VIII.1: Executive Summary	 
PAGEREF _Toc143617343 \h  30  

  HYPERLINK \l "_Toc143617344"  Table VIII.2 Proportion of Crop (Cut
Flowers, Cut Florist Greens, Bulbs, Corms, Rhizomes, and Tubers) Grown
Using Methyl Bromide	  PAGEREF _Toc143617344 \h  30  

  HYPERLINK \l "_Toc143617345"  Table IX.1: Typical Production Cycle for
Day-Neutral Strawberry and Vegetable Rotation Crops, Watsonville /
Salinas CA.	  PAGEREF _Toc143617345 \h  35  

  HYPERLINK \l "_Toc143617346"  Table IX.2: Pesticide Use Records for
Fumigants on Strawberry Fruit from the California Department of
Pesticide Regulation	  PAGEREF _Toc143617346 \h  36  

  HYPERLINK \l "_Toc143617347"  Table IX.3:  Variable Costs of Fumigants
for Strawberries in California	  PAGEREF _Toc143617347 \h  38  

  HYPERLINK \l "_Toc143617348"  Table IX.4:  Variable Costs of Fumigants
for Strawberries in Eastern US	  PAGEREF _Toc143617348 \h  39  

  HYPERLINK \l "_Toc143617349"  Table XII.1: Key Pests for Tomatoes and
Grafting Research Status	  PAGEREF _Toc143617349 \h  43  

  HYPERLINK \l "_Toc143617350"  Table XII.2: Resistance to Important
Plant Pathogens and Pests in North Carolina and the Mediterranean.	 
PAGEREF _Toc143617350 \h  44  

  HYPERLINK \l "_Toc143617351"  Table XII.3: Resistance of Tomato
Rootstocks to the Most Common Soil Borne Pathogens	  PAGEREF
_Toc143617351 \h  44  

  HYPERLINK \l "_Toc143617352"  Table 6.1: Methyl Bromide Consumption
for the Past 5 Years and the Amount Required in the Year(s) Nominated
(American Association of Meat Processors	  PAGEREF _Toc143617352 \h  48 


  HYPERLINK \l "_Toc143617353"  Updated Table 6.2: Methyl Bromide
Consumption for the Past 5 Years and the Amount Required in the Year(s)
Nominated (National Country Ham Association	  PAGEREF _Toc143617353 \h 
49  

  HYPERLINK \l "_Toc143617354"  Table 6.3: Methyl Bromide Consumption
for the Past 5 Years and the Amount Required in the Year(s) Nominated
(Nahunta Pork Center	  PAGEREF _Toc143617354 \h  49  

  HYPERLINK \l "_Toc143617355"  Updated Table 6.4: Methyl Bromide
Consumption for the Past 5 Years and the Amount Required in the Year(s)
Nominated (Gwaltney of Smithfield	  PAGEREF _Toc143617355 \h  50  

  HYPERLINK \l "_Toc143617356"  Updated Michigan Pepper- Table E.3:
Economic Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc143617356
\h  70  

  HYPERLINK \l "_Toc143617357"  Updated Table 21.1: Costs of
Alternatives Compared to Methyl Bromide Over 3-Year Period	  PAGEREF
_Toc143617357 \h  72  

  HYPERLINK \l "_Toc143617358"  Updated Table 22.1: Year 1 Gross and Net
Revenue	  PAGEREF _Toc143617358 \h  72  

  HYPERLINK \l "_Toc143617359"  Updated Michigan - Table E.1: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc143617359 \h  72  

 

GENERAL QUESTIONS  TC "GENERAL QUESTIONS" \f C \l "1"  

MBTOC Question

1. MBTOC has reviewed a number of recent studies in the US which
indicate that alternatives are providing yields similar to those
obtained with methyl bromide, and is unclear why the economic losses
reported in some nominations for infeasibility of alternatives do not
appear to reflect the results from these studies. MBTOC specifically
requests the Party to look through the reference lists provided in the
text boxes of the May TEAP Report 2006 and the Special Report
(Statistical Analysis of International Research) by TEAP published May
2006, and indicate whether the relative yields reported in these
references have been considered in the nomination. Could the Party also
verify how the relative yield loss shown for alternatives in the BUNNl's
across the often large number of studies in the region of the nomination
is calculated? MBTOC also seeks clarification on whether these new
studies above influence the quoted rate of adoption for each crop for
which MB has been sought.

US Response

One of the first activities undertaken by USG scientists in putting
together the US request for methyl bromide is to conduct a literature
review to be certain that all relevant literature is included in the
assessment.  This review is undertaken with certain strict criteria in
mind.  In order for a study to be included the study must meet three
criteria: it must report pest pressure, it must have a methyl bromide
control, and it must be taken to harvest.  These requirements are put
into place not to reduce the number of studies that must be examined,
but to ensure that any conclusions drawn by the study are applicable to
the CUE decision.  Two other considerations are also key; studies that
evaluate the performance of alternatives that are not registered in the
US are not considered relevant to the evaluation and studies that do not
include circumstances of moderate to severe pest pressure are also not
included since the US nomination is only for circumstances with these
levels of pest pressures.

A description of the pest pressure is needed because in some instances,
for example trials to determine pesticide residues, low levels of pest
pressure result in observed performance of all alternatives being equal.
 These trials are not conducted as efficacy evaluations but to determine
residual pesticide levels on foods so that the US can establish maximum
residue levels (MRLs).  This does not provide information that is
relevant to the circumstances of the US nomination- as the US nomination
is for situations of moderate to high pest pressure.  This requirement
is most often met by including an untreated control from which
information on pest pressure can be deduced.

A second requirement is that the study includes a methyl bromide
control.  This is necessary because in order to compare the performance
of the alternative, and thus determine technical feasibility, a
comparison with methyl bromide in the circumstances that the
alternatives are being used provides the only valid comparison.

The third requirement is that the study must be taken to yield.  Many
studies stop short of this point, looking at the root structure or other
measure.  Because USG scientists are not aware of any studies that link
these other measures to yield changes in a predictable way, changes in
yield cannot be inferred from these other measures.

Studies that include chemical alternatives that are not registered in
the US are not included because it would be illegal to use these
combinations even if they were found to be technically and economically
superior to methyl bromide.

The US request for critical use methyl bromide is only for certain
circumstances.  Not only must there be a “key pest”; one that cannot
be adequately controlled by methyl bromide alternatives, but this pest
must be present at levels that are moderate to severe.  Studies that can
be used to assess yield loss of alternatives in the circumstances of the
US nomination must be conducted in circumstances that are relevant to
the circumstances of the US nomination.

The US has a great deal of experience assessing pest pressure and
determining how to ameliorate the condition.  One program that has
served as a training ground for methyl bromide evaluations is the §18
program under the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA).  This program has been carried out by OPP for the last 30
years.  It is a program that allows the emergency use of an unregistered
pesticide when conditions warrant provided that human health and the
environment can be adequately protected.  OPP makes decisions on as many
as-200 of these emergency requests every year.  Despite this extensive
experience, OPP scientists have not been able to determine an
extrapolation procedure that would allow them to extrapolate from low
pest pressure to the moderate to high pest pressures that characterize
the US nomination in a scientifically defensible manner.

To conclude, only studies that meet the above mentioned criteria: 

contain information about the level of pest pressure

include a methyl bromide control

are carried through to yield

does not include (only) treatments using chemicals not registered in the
US

meet the circumstance of the US nomination with respect to key pests and
pest levels (moderate to severe)

are used to determine yield loss.

Some apparent inconsistencies noted by MBTOC between acceptable yields
reported in certain research studies for alternatives and the Party’s
declaration of economic infeasibility are explained by two important
factors.  First, yield variability among treatment replications in field
tests can result in no statistical differences between MB and
alternative treatments in some trials, but significant differences in
others.  If cited studies indicate comparable yields during several
years of field trials with moderate to high pest pressure, there may be
a determination that alternatives are feasible, if comparable conditions
can be transferred to commercial application.  For example, some field
trials have indicated that 1,3-D with chloropicrin results in comparable
strawberry yields to a standard MB treatment when a low permeable film
is used.  Even if several trials have been conducted and comparable
yields have been confirmed in research trials, the economic feasibility
of the alternative may be in question if commercial growers do not have
access to film or application equipment or if large-scale trials have
not been conducted that confirm research-scale trials. 

The Party notes that the nomination is for situations where pest
pressure is known to be moderate to high and that therefore the Party
uses only those studies conducted in areas with moderate to high pest
pressure.  Most production within most sectors does not rely on use of
MB and the nomination does not include these areas.  Even for intensive
production of a high value crop such as California strawberries, the
Party notes that at least 40-50% of production land currently uses
MB-alternatives (Dan Legard, personal communication; July, 2006) This
amount could be even higher except for regulatory factors, such as
county restrictions on use of both chloropicrin and 1,3-D.  

As mentioned above, a second factor of economic infeasibility even where
yields may appear comparable between MB and alternatives is where
treatments used in research trials cannot be replicated in commercial
fields due to scale-up costs of material.  For example, the cost of
purchase and field application of high barrier films and frequently the
lack of availability of large amounts of films in the US can make
alternatives economically infeasible even where yields may be comparable
if alternatives could be employed.  A large forest seedling nursery
attempted to do nursery application with metam-sodium and chloropicrin
under tarps, but equipment adaptations and a four-fold increase in
application time made this treatment economically unacceptable.  The
consortium considers the alternative treatment potentially feasible in
terms of production goals, but only if material and labor costs can be
held to acceptable levels.

MBTOC Question

2. Previous studies and commercial adoption in countries that have
phased out MB indicate that alternatives are adopted relatively quickly
within a 3 to 4 year period. The US has often quoted periods for uptake
of alternatives over much longer periods. Could the Party please show
evidence for these longer adoption schedules and the exact assumptions
used to calculate these rates for all of the key alternatives
(statistically equivalent) shown to be effective in the BUNNl's and the
Special Report published by TEAP.

US Response

In situations where alternatives to methyl bromide have been shown to be
technically and economically feasible, the US has not asked for methyl
bromide.  A critical use request for methyl bromide has only occurred in
those circumstances where it is a critical need, i.e. where there are no
alternatives that are both technically and economically feasible and
where the lack of methyl bromide will result in a significant market
disruption.  

In the vast majority of situations methyl bromide has been replaced. 
The industry is not, however, homogeneous, and in some circumstances
either because of the pest complex, the severity of the pest pressure,
the climate, the terrain, the economics, or, other factors, it has not
been possible to find an alternative to methyl bromide that is both
technically and economically feasible.  These portions of agricultural
production that comprise the nomination are those where finding an
alternative has been both most elusive and most difficult.  Unlike the
situation for the post-harvest uses, where there is a new product that
may easily replace methyl bromide, and indeed where the US has estimated
a transition of less than seven years and where the US is already well
into the transition, the pre-plant uses do not, as yet, have a new
product that can be used in place of methyl bromide.

Because there is no new equivalent or superior product that can be used
to replace methyl bromide in pre-plant uses as yet, further transition,
beyond the 80% already achieved, requires the slow, incremental steps
that come with learning how to use ever more complex combinations of
chemicals and non-chemical processes to achieve outcomes comparable in
efficiency and economics to the outcomes achieved with methyl bromide
for the small , and most difficult, portion of the problem still
remaining.

This question makes reference to a TEAP Special Report and requests
clarification from the Party on how we have incorporated the information
in that document in our nomination.  As a practical matter, even under
the best of circumstances it would be exceedingly difficult for the US
to re-review our entire nomination submitted in January 2006 using the
data from the Special Report provided to Parties in May 2006.  the US is
committed to reviewing the data from the Special Report and has
requested, verbally and in writing, the underlying data used in the
study as well as a more complete description of the methodology used in
the meta analysis.  As we have previously requested, in order to
understand the study we need:

Statistical Analysis - We need a description of the statistical analysis
from the biometrician/statistician that includes a discussion of how the
individual study probabilities were calculated as well as the
statistical programming commands used in with the statistical package.

Starting Points for Models - We would need any derivatives used in
determining starting points for modelled means.

All data (Raw, Transformed, and Discarded) - We need a copy of the raw
and transformed data as well as a description of each category of data. 
In addition we need a description of how data were transformed.  We
would also need any data that was discarded prior to, during, and/or
after the analysis.  Please give a brief accounting for the omission of
this data.+6

Inclusion Criteria - Please provide a complete statement rather than a
flow chart of the inclusion criteria

Reason of Design - Since meta analysis is an umbrella term that can
include a number of statistical methodology's, please provide a
discussion for the analysis chosen for this project.

As we have not yet received this information, it is difficult for us to
evaluate what relevance, if any, the meta meta-analysis as a whole or
the individual studies themselves have to the US nomination.

The US would like to point out, that in contrary to the assertion
implied in the report of the meta-analysis, is not the case that when a
portion of the confidence interval from one chemical complex overlaps
another that the two are indistinguishable (statistically equivalent). 
The best predictor of the dependant variable is its expected value, an
overlap in the confidence interval can occur for several reasons.

There are several reasons why two things may not be distinguishable when
if fact they are distinct.  A critical factor is sample size— a sample
may not be large enough, given the number of independent variables, to
allow expected values to be distinguished from each other even though
they are, in fact distinct.  A second reason may be high variance. 
Other things being equal, when the variance is high the confidence
interval will be large, overlapping with confidence intervals from other
treatments in the study.  This will be true even though the best
predictor of the effect, the expected values, differ from each other. 
Yet another reason could be an artifact of the testing technique which
affects the outcome of specific treatments or otherwise adds a
non-random bias.  Without a better understanding of the study discussed
in the TEAP Special Report it is not possible to determine whether
different treatments are statistically equivalent because, in fact, on
average they produce equivalent yields, or because one or more other
factors are involved and the treatments are not, in reality, equivalent.

The best predictor of the dependant variable is its expected value.  To
make the generalized judgment that two treatments have “identical”
results because expected values differ by “only” five percent, or
because their confidence intervals overlap, without providing details of
the statistical validity or experimental conditions, is inappropriate.

Another element missing from the TEAP Special Report is consideration of
the economics.  In addition to the expected yield differences when using
different treatment regimes, there is the issue of market windows and
timing.  Some of the alternatives cannot be used as early in the season
as methyl bromide, due to cold soil temperatures, for example.  Some
require longer to off-gas.  Still others require multiple passes through
a field.  In all of these cases there is a planting delay.  Even in
cases where a planting delay does not necessarily imply a shorter
growing season and the concomitant reduction in yield, and in most cases
it does, there is still the issue of what prices is received for a
product at what point in a growing season.  In cases where there are
market window price effects, a substantial portion of revenues above
cost will be lost if the market window is missed.  These effects are in
addition to any higher costs of using additional chemicals or requiring
additional passes through a field.  The market window effects are so
important with certain US crops that it accounts for a fifteen percent
revenue decrease in addition to the revenue loss produced by the reduced
yield.  That is, a fifteen percent revenue loss comes from the market
window effect alone.

For all of these reasons described above, it is not appropriate to talk
of treatments that are statistically equivalent to the performance of
methyl bromide using as a reference the TEAP Special Report.

An important additional issue is that, although there is a newly
registered fumigant for post-harvest use, sulfuryl fluoride, there is no
newly registered fumigant for pre-plant uses.  Many, if not most, of the
methyl bromide alternatives for the pre-plant uses are as old, or older,
than methyl bromide.  Metam sodium, for example, was registered in the
US in 1955, methyl bromide in 1962, and 1, 3-D in 1954. Chloropicrin was
first used in commercial US agriculture as a preplant pesticide in 1935.
 (  HYPERLINK "http://flnem.ifas.ufl.edu/HISTORY/nematicide_his.htm" 
http://flnem.ifas.ufl.edu/HISTORY/nematicide_his.htm )  

It is worth noting that there is a reason that methyl bromide has
continued to be the fumigant of choice in certain circumstances—some
combination of higher yields, lower costs, more reliable results
continues to exist for methyl bromide.  From the current perspective,
having reduced methyl bromide use by eighty percent relative to the 1991
baseline despite general growth in the agricultural sector, the uses
which remain are those most difficult to replace in terms of combined
technical and economic feasibility of methyl bromide alternatives. 

The US continues to expend a great deal of both effort and resources to
develop new alternatives to methyl bromide and to try to make existing
alternatives work better in the circumstances of particular crops,
climate, soils, and pest complexes.  For 2008 we have requested just 25%
of our 1991 baseline, so that in the vast majority of cases there has
been a transition to alternatives, more than the apparent 75%, because
the agricultural sector has grown in the subsequent fifteen years.  

MBTOC Question

3. In several of the CUN's, MBTOC based the recommendation on the amount
of MB required to control diseases and weeds using emission control
technologies ie either low permeability barrier films and reduced rates
and formulations of MBIPic (mostly 50:50 or less)? In many cases (see
October 2005 MBTOC report and May 2006 TEAP report) effective dose rates
can often be used which are lower than the standard presumption. For
similar pathogens in other countries, rates less than 10 g MBlm2 have
been shown to be effective when used with mixtures of chloropicrin. The
Party explained that there was no restriction on using reduced dosages
of MB in formulations of MBIPic for diseases and MBTOC requests the
Party to indicate (with data) what is preventing adoption of MBIPic
formulations with very low doses of MB (ie 30:70 and 20:80 or less)?

US Response

Although MBTOC is correct – there is no federal regulatory restriction
that precludes the use of mixtures with higher proportions of
chloropicrin (pic) than the widely used 67:33 (MB:Pic) there are other
reasons why it is not feasible to use higher mixture rates in the
circumstances of the nomination.  States have regulations that can
differ from those at the Federal level.  In California, County
Agricultural Commissioners are allowed to establish local permit
conditions to supplement state and federal fumigant use restrictions. 
Because chloropicrin causes dramatic symptoms similar to tear gas when
people are exposed to relatively minor amounts, any movement of
chloropicrin off the treatment site creates a major political issue both
locally and in the state legislature and in many counties in California
the agricultural commissioners have reduced the maximum amount of
chloropicrin that can be used.  This removes the option of reducing the
amount of methyl bromide needed by increasing the use of chloropicrin,
at least in California.

There were four accidents associated with chloropicrin applications for
strawberry production in 2005.  The local restrictions for chloropicrin
are as follows:  Monterey County (9000 acres of strawberry production)
does not allow broadcast applications.  Maximum rate is 200 lbs/a.  The
only sensitive site application (drip) permitted in 2005 resulted in a
major accident affecting several hundred people, so no sensitive site
applications are likely to be approved in 2006. Santa Barbara County
(6000 acres) does not allow broadcast application of chloropicrin alone
and limits applications to a maximum of 200 lbs/a.  No applications
within ¼ mile of a school while in session.  To minimize bystander
exposure, applications within 500 feet of an occupied structure must be
completed by 2 p.m. and functional sprinklers must be in the field prior
to beginning an application when there are occupied structures within ¼
mile.   Ventura County (11,000 acres) does allow broadcast applications
under tarp but they are limited to 125 lbs/a.  All applications are
limited to 10 acres per day in sensitive sites with buffer zones up to
120-130 ft.  A site is sensitive if an occupied structure is located
within 300 feet (measured from the property line, if the property does
not belong to the property operator, otherwise measured from the
structure) of a chloropicrin buffer zone or within the buffer zone.

The impacts of the above regulations for strawberry fruit production in
California in 2006 are:

27% (9,000 of 34,000 acres) cannot use straight chloropicrin fumigation

44% (15,000 acres) can not apply straight chloropicrin by broadcast
application

32% (11,000 acres) can only apply chloropicrin in broadcast application
at 125 lbs/acre and have larger buffer zones than with Inline or methyl
bromide for drip applications. 

(Personal communication, Dan Legard, Director of Research with the
California Strawberry Commission)	

Growers in California would adopt formulations that reduce the use of
methyl bromide if they were allowed to do so.  It appears to be a useful
tool where diseases are the issue.  The complication occurs in
situations such as Orchard Replant where the etiology of orchard decline
is believed to be different depending on soil type, previous plantings
on the land, location, etc.  What this means is that in orchards with
fungi as key pests, use of high rates of chloropicrin may be acceptable
as a pest control measure, whereas where nematodes appear to be the
major pest, chloropicrin may not be so useful.  If a township cap (or
other regulatory measure) is not an impediment, growers may be able to
use 1,3-D, assuming that the moisture and soil types are appropriate,
but in California this possibility may not be available

MBTOC Question

4. What are the technical and economic barriers to wider adoption of low
permeability films where permitted and also subsequent reduction in MB
doses to levels shown to be effective in other countries ( 4 0 g lm2)?

US Response

The three issues that need to be considered when answering this question
are technical and economic feasibility, and emissions reductions.  Can
we find evidence that lower rates control the key pests and what level
of control will occur during the second crop in a double cropping
system?  Will lower permeability films have an economic impact on the
operation?  And will these lower permeability films reduce emission
under field conditions?  

While many field research studies in the eastern US indicate that use of
LPBF in conjunction with lower rates of methyl bromide can control a
number of pests.  However, we have been unable to find information from
large scale field studies, efficacy data on some of the key pests, and
data on pest control and yield for the second crop on the same plastic
mulch (as part of the double cropping system).  Without this addition
information the technical feasibility is still in question.  The US is
unable to estimate the total economic impact of this type of fumigation
practice without this information.  In terms of field emissions there
are several laboratory and small scale field studies indicates that
fumigant emissions can be substantially reduced with the use of
LPBF’s.  However, the few large scale field studies that are available
do not demonstrate reductions in emissions with the use of LPBF.  

MBTOC Question

5. Are all types of LPBF prohibited in California or only VIF (Could
films with a reduced permeability of MB be used)?

US Response

The standard in California for using tarpaulins in conjunction with
methyl bromide is based on the performance characteristics of the film. 
This regulation was developed to protect worker safety during tarpaulin
removal (broadcast) or hole punching (beds).  The California methyl
bromide regulations are as follows: 

“... Except for experimental research purposes pursuant to a valid
research authorization issued according to section 6260, tarpaulins
shall have a permeability factor between 5 and 8 milliliters methyl
bromide per hour, per square meter, per 1,000 parts per million of
methyl bromide under the tarpaulin at 30 degrees Celsius, and be
approved by the Department.  A list of approved tarpaulins is available
from the Department.”

All films used in conjunction with methyl bromide must meet this
standard regardless of the film type (VIF, metalized, etc.).  For
additional information please consult
http://www.cdpr.ca.gov/docs/dprdocs/methbrom/tarps.pdf

MBTOC Question

6. What steps is the Party undertaking to revise this prohibition?

US Response

This is a regulation promulgated by the State of California.  Any
alteration would require a change in the State regulation. Under the US
Federal system, States are often allowed to promulgate standards which
are more restrictive than those promulgated at the federal level, as
long as the regulations in question do not affect interstate commerce. 
California, therefore, would need to make a decision to change their
regulation; based on the merits of the issue, there is no action that
can be taken at the Federal level.  As we understand it, the regulation
is based on the State of California efforts to reduce worker risk from
methyl bromide exposure.

MBTOC Question

7. MBTOC seeks clarification on how total production areas (and those
using MB) for crops considered in CUN's are calculated, especially for
tomato and pepper CUN's. In these nominations in particular there are
some major differences in the areas requesting MB from one year to the
next? For instance, in Michigan the area using MB for tomatoes was 228
ha in 2006, 86 ha in 2007 and 252 ha in 2008; in SE peppers 660 ha used
MB in 2006, 440ha in 2007 and 733ha in 2008.

US Response

There are several changes between the 2007 and 2008 nominations.  One
change is in the calculation of the BUNNI—as described (above) so that
the number of hectares is a function of the total kilograms requested
and the methyl bromide use rate and no longer an independent number. 
This change, and others like it, will result in minor differences in
BUNNI entries between 2008 and previous years.

This change was instituted precisely because when these figures were
supplied as independent estimates by the applicants there were
inconsistencies.  In Michigan the area under treatment supplied to us
was not calculated as a strip treatment because of confusion on our part
we failed to adjust the figure in 2007.  The correct figure is the 2008
one.

For the southeast, in 2007 the Virginia Tomato growers failed to
resubmit their request in a timely manner and so were not included in
the US request.  They did resubmit in 2005 for both 2007 and 2008. 
Because of the late timing of the request, the potential to utilize
stocks, and other factors we did not request a supplemental but informed
Virginia that to the extent that they had a need for methyl bromide it
would have to come from existing stocks.



PREPLANT SOIL QUESTIONS  TC "PREPLANT SOIL QUESTIONS" \f C \l "1"  

US CUCURBITS – FIELD  TC "US CUCURBITS – FIELD" \f C \l "2"  

MBTOC Question

1. Could the Party please provide technical data to validate the areas
cropped with cucurbits that are affected by Karst topography (buffer
zones around surface features).

US Response

While the exact nature of overlap between the acres farmed to cucurbits
and areas of karst topographical features changes every season, the USG
has evaluated the use of Geographic Information Systems (GIS) to address
this question.   As part of the re-registration of methyl bromide that
is an ongoing project at USG, maps of the distribution of karst
topographical features in Florida that could require buffers have been
generated using GIS technology. These maps could aid MBTOC in
understanding the extent of cucurbit acreage affected by karst
topographical features. They are attached to this document as an
appendix (C). Florida was selected for this approach because the
majority of karst-based calculations for crop acres needing methyl
bromide use in cucurbits (and other crops) are located in this state.

An indirect validation of the cucurbit acreage affected by Karst
topographical features can be obtained from the observation that about
59 % of Florida squash acreage is located in Dade County in Florida
(USDA 2002). Karst topographical features-related label restrictions and
county ordinance disallow use of 1,3-D in the entire county. Therefore,
karst topographical features affect 59 % of Florida’s squash acreage
at a minimum. This is a greater proportion than that used in the USG
calculations of methyl bromide needed (which estimated that 40% of
cucurbit acreage in Florida would be affected by karst topographical
features).

Appendix C contains Florida maps showing both areas of karst
topographical features and the major vegetable and strawberry growing
areas.  Hillsborough County, one of the top three counties (in acreage
planted) for strawberries, tomatoes, squash and cantaloupe has
approximately 50% of the acreage characterized by karst topographical
features.  The current US estimate for proportion of acreage where 1,3-D
cannot be used due to these karst features is 40%.

MBTOC Question

2. Why are grafted plants not being tested for disease infested areas?

US Response

The following table summarizes the current state of research on grafting
in US vegetable production, to the extent that USG has been able to
ascertain. 

Table I.1 Key Pests for Cucurbits and Grafting Research Status  TC
"Table I.1 Key Pests for Cucurbits and Grafting Research Status" \f F \l
"1"   

Key Pest	Grafting Research Status

Nutsedge, Cyperus spp.	No research planned in the US due to lack of
resistant rootstock.

Phytophthora capsici	No research planned in the US due to lack of
resistant rootstock.

Fusarium oxysporum	Research planned and underway in the US.

Nematodes, root knot  Meloidogyne incognita	No research planned in the
US due to lack of resistant rootstock.



Several US seed companies, some in collaboration with the US Department
of Agriculture, are conducting tests of the commercial feasibility of
using grafted, disease-resistant cucurbits, tomatoes and peppers in
greenhouse and open field production (Core, 2005, Kubota, personal
communication, 2006).  Some of these trials are being conducted in the
southeastern US (Core, 2005).  However, these tests are highly
preliminary and there is as yet no assurance that such grafted plants
are commercially acceptable in pest management and economic terms. 
Grafted vegetables are commercially used mostly in greenhouse tomato
production in the US.  However, there is no significant greenhouse
production of cucurbits in the US, as far as USG can ascertain.  Indeed,
more than 90% of grafted vegetable seedlings are tomatoes in North
America (Kubota, personal communication, 2006).  Virtually all these
grafted tomatoes are used in greenhouse production.

Table I.2 Resistance to Important Plant Pathogens and Pests of Tomato in
North Carolina and the Mediterranean.  TC "Table I.2 Resistance to
Important Plant Pathogens and Pests of Tomato in North Carolina and the
Mediterranean." \f F \l "1"  

Pathogen or Pest	Resistant Line Reported by North Carolina (F. Louws)
Resistant Line Reported in Mediterranean (M. Besri)

Verticillium race 1	Yes	Yes 

Verticillium race 2	No	Not listed

Ralstonia solanacearum	Yes	Yes

Fusarium solani race 1& 2	Yes	Yes

Fusarium solani race 3 	Yes	Not listed

Sclerotium rolfsii	No	Not listed

Root knot nematodes Meloidogyne spp.	Yes	Yes

Phytophthora capsici	No	Not listed

Pseudomonas corrugate	No	Yes

Pythium root rot 	No	Not listed

Weed species	Not listed	Not listed

Source:  Louws et al 2002 and Besri, M.  2005.

Table I.3  Resistance of Tomato Rootstocks to the Most Common Soil Borne
Pathogens  TC "Table I.3  Resistance of Tomato Rootstocks to the Most
Common Soil Borne Pathogens" \f F \l "1"   

Rootstock	Pathogens

	K	V (1)	F (1, 2)	N	Fr

L. esculentum x L. hirsutum	+	+	+	+	+

L. esculentum	+	+	+	+	+

Source:  Besri, M.  2005.

K: Pyrenochaeta lycopersici, V (1): Verticillium dahliae (race 1), F
(1,2): F. oxysporum f.sp. lycopersici (races 1 and 2), N: Meloidogyne
spp, Fr: F.oxysporum f.sp. radicis lycopersici   Resistance to
Pseudomonas (Ralstonia) solanacearum is provided by S .torvum and S.
aethiopicum.  In addition, these two rootstocks are resistant to
Meloidogyne spp.  

It is not clear whether grafting is being evaluated for resistance to
Phytophthora spp. pathogens, a critical disease pest of cucurbits
currently targeted by MeBr use in the US.  USG is unaware of any
research conducted on the suitability of grafting as a control option
against this pathogen.

In addition, USG is not aware of any research demonstrating that
grafting offers protection against weeds (such as nutsedge).  A
significant portion of the US nomination for MeBr is for the control of
weeds (in the southeast) as well as soilborne diseases.  In the
protected environment of the greenhouse where some pathogens can be
controlled by using sterilized soil , grafting may offer sufficient
disease protection, but in the open field situation which characterizes
most of the vegetable production in the US, grafting does not offer
protection against the suite of pests faced by growers.  Therefore, even
if resistance to Phytophthora pathogens is identified, several years’
tests of how grafting can be effectively integrated with other pest
management strategies will be necessary before it can find commercial
acceptability in open-field vegetable production in the US.  At present
there are no grafted rootstocks that can deal with the entire US pest
complex.

In addition, cost remains a significant factor inhibiting adoption of
grafted plants in open-field vegetable production.  Grafting is a very
labor-intensive activity, consequently the cost of grafted plants is
highly dependent on labor costs.  In countries as geographically
separated as Morocco and Mexico, the cost of a grafted vegetable plant
is approximately $0.10 each.  In the United States, and countries with
similar labor costs, such as Canada, however, higher labor costs push
the cost of a grafted stem to more than four times that cost.

According to Dr. Chieri Kubota (personal communication), a grafting
expert with the University of Arizona, a grafted plug of two stems, that
is ready for field use, costs $0.90,  The presence of two stems means
that the plant will have twice the yield of a normal, one stemmed,
plant.  The cost increase, however is still significant.  The normal
cost of a non-grafted plug, ready for planting in the field, is
approximately $0.20.  The grafted plant, then, costs 125% more than a
conventional plant per stem.

US PEPPERS – FIELD  TC "US PEPPERS – FIELD" \f C \l "2"  

MBTOC Question

1. In tomato trials, 1,3-D (1,3-dichloropropene) and chloropicrin 65:35
with and without VIF, 1,3-D and chloropicrin 65:35 & metolachlor &
trifloxysulfuron and Metam Sodium and chloropicrin provided similar
yields as MeBr and chloropicrin 67:33 in 3 trials over the spring and
fall of 2003 and spring of 2004. (Santos, et al, Crop Protection, 2006).
 Are the herbicides trialled all registered on pepper? Are there plant
back or market window effects?  Can LPBF films, (VIF or metalised) be
used in this area for pepper in all growing areas?

US Response

rifloxysulfuron sodium (Envoke™) is registered in the US on tomato
transplants, cotton, and sugar cane but not on peppers.  Data from
Florida indicates that Trifloxysulfuron sodium applied preplant
incorporated in Florida resulted in stunting of peppers (From the USDA
IR-4 NEWSLETTER 33:2 07-02.  Available online at   HYPERLINK
"http://ir4.rutgers.edu/newsletter/vol33-2/herbicideperformance.pdf" 
http://ir4.rutgers.edu/newsletter/vol33-2/herbicideperformance.pdf ). 
S-Metolachlor (Dual Magnum™) is not registered on peppers. 
Metam-sodium is registered as a preplant fumigant on peppers

However, USG is not clear on how MBTOC arrived at the conclusion that
all the treatments listed in its question provided similar yields to
MeBr and chloropicrin.  To quote what is arguably the most practically
relevant result of the study, “During two of the [three] seasons,
1,3-D + chloropicrin with VIF, sodium azide at 85 kg/ha, and propylene
oxide were consistently equal to methyl bromide + chloropicrin .”  Of
these materials, only 1, 3 D + chloropicrin is currently registered for
use in US peppers.  In a similar study published in 2006, Gilreath et
al. (in Crop Protection Vol. 25: 79-82) state that “…the combination
of C-35 +chloropicrin + pebulate +trifluralin can provide an effective
wide-spectrum fumigant program to replace methyl bromide + chloropicrin
applications in polyethylene-mulched tomato.”  However, pebulate is
not registered for use on any crop in the US.  Trifluralin is
registered, but since it is the combination with pebulate and 1,3 D+
chloropicrin  that showed promise, trifluralin alone is not a feasible
substitute for MB+ chloropicrin . Also, in both Santos et al. (2006) and
Gilreath et al. (2006), Phytophthora pathogens, major targets of MeBr
use, were not included as test subjects.  Thus it remains unclear
whether even the combinations of unregistered and registered
alternatives that were tested will be as effective as MeBr for control
of this pathogen. 

As regards the results cited for 1,3 D + VIF, the following important
caveats must be resolved before this option can feasibly replace MeBr
use in peppers (or any other open-field vegetable crop) across the
entire US: (1) the effect on Phytophthora pathogens needs to be studied;
(2) results need to be validated on commercial scale fields (as was done
by Gilreath et al. 2006, for other MeBr alternatives discussed above);
(3) 1,3-D + chloropicrin  + VIF needs to be evaluated in areas with
different climatology than the subtropical region where Santos et al.
(2006) conducted their work.

To address the other questions included in this item: there are indeed
plant-back restrictions with all the herbicides mentioned.  For example,
in cucurbits, metolachlor has a 12 month plantback restriction, and
trifloxysulfuron sodium when used on tomato transplants has an 18 month
plantback restriction.  Metolachlor has a preharvest interval of 90
days, which can interfere with harvest timing to coincide with optimum
market windows. 

VIF and metallised films remain under study for commercial feasibility
in US vegetable crop production.  Metallised films are now in tentative
use by vegetable growers in Florida, but use has not yet become
widespread.  Promising results have been observed in recent studies of
new preparations of VIF in Florida (e.g., Gilreath et al. 2005). 
However, VIF cannot be used with MeBr in California due to worker safety
concerns (VIF use is not allowed by state law based on a performance
standard for minimum permeability).  Furthermore, the economic
feasibility of VIF use in other parts of the US remains unclear.

Costs associated with VIF are discussed by Noling (2002, revised 2005),
and this description is summarized in the USG response to a similar
MBTOC question for US strawberry nurseries.  The relevant text is
reproduced below.

According to Noling (2002, revised 2005): “Historically VIF mulches
have suffered from high cost and from other problems involving tensile
strength.  They are typically slow to properly install and are subject
to tearing (zippering) during machine application in the field.  More
efficient containment of gases below the mulch also suggests that
plantings may have to be delayed to insure soil residues have dissipated
and plant injury will not occur.  The average price for LDPE mulch is
approximately $250-300/acre, while HDPE mulch is $400 /acre and VIF
mulch in the range of $400 to 600/acre.  The higher price for VIF is
partially reflective of transportation costs from European
manufacturers.  Compared to LDPE, reduced methyl bromide and
chloropicrin application rates (as much as 50%) and use of the VIF mulch
will result in lower fumigant costs which may be completely offsetting
given the higher pricing for methyl bromide now in reduced supply.”

In addition to the increased direct cost of VIF, increased labor costs
for slower machine installation of the mulch should probably also be
considered.  At present, given the slick, non embossed surfaces of VIF,
machine application of the VIF in the field is typically less than 3
miles per hour.  Manufacturer research programs are continuing to focus
on ways to resolve many of these problems…  In addition to higher
costs per acre, problems of VIF availability also must be considered. 
VIF is currently manufactured near exclusively in Europe and Israel by
various producers.  As a result of overseas production, users in the
United States will likely incur lengthy delays (upwards of 2-3 months)
for delivery of ordered products.  There is also concern that although
the raw materials needed to produce VIF are readily available in the US,
current European production capacity is not high enough to meet US
demand if it were to substantially increase in the future.  To resolve
future demand, if it materializes, production facilities in the US would
have to be established to insure timely supply.”

MBTOC Question

2. Are grafted plants being tested for disease infested areas. If so,
please provide evidence that they are not suitable as an alternative to
MeBr.  If not, why?

US Response

The following table summarizes the current state of research on grafting
in US vegetable production, to the extent that USG has been able to
ascertain.

Table II.1  Key Pests for Peppers and Grafting Research Status  TC
"Table II.1  Key Pests for Peppers and Grafting Research Status" \f F \l
"1"   

Key Pest	Grafting Research Status

Nutsedge , Cyperus spp.	No research planned in the US due to lack of
resistant rootstock.

Phytophthora capsici	No research planned in the US due to lack of
resistant rootstock.

Fusarium  oxysporum	Research planned and underway in the US.

Nematodes, Meloidogyne incognita	No research planned in the US due to
lack of resistant rootstock.



Several US seed companies, some in collaboration with the US Department
of Agriculture, are conducting tests of the commercial feasibility of
using grafted, disease-resistant cucurbits, tomatoes and peppers in
greenhouse and open field production (Core, 2005, Kubota, personal
communication, 2006). Some of these trials are being conducted in the
southeastern US (Core, 2005). However, these tests are highly
preliminary and there is as yet no assurance that such grafted plants
are commercially acceptable in pest management and economic terms.
Grafted vegetables are commercially used mostly in greenhouse tomato
production in the US. However, there is no significant greenhouse
production of peppers in the US, as far as USG can ascertain. Indeed,
more than 90% of grafted vegetable seedlings are tomatoes in North
America (Kubota, personal communication, 2006). Virtually all these
grafted tomatoes are used in greenhouse production.

It is not clear whether grafting is being evaluated for resistance to
Phytophthora spp. pathogens, a critical disease pest of cucurbits
currently targeted by MeBr use in the US. USG is unaware of any research
conducted on the suitability of grafting as a control option against
this pathogen.

Table II.2 Resistance to Important Plant Pathogens and Pests in North
Carolina and the Mediterranean.  TC "Table II.2 Resistance to Important
Plant Pathogens and Pests in North Carolina and the Mediterranean." \f F
\l "1"  

Pathogen or Pest	Resistant Line Reported by North Carolina (F. Louws)
Resistant Lines Reported in Mediterranean (M. Besri)

Verticillium race 1	Yes	Yes 

Verticillium race 2	No	Not listed

Ralstonia solanacearum	Yes	Yes

Fusarium solani race 1& 2	Yes	Yes

Fusarium solani race 3 	Yes	Not listed

Sclerotium rolfsii	No	Not listed

Root knot nematodes Meloidogyne spp.	Yes	Yes

Phytophthora capsici	No	Not listed

Pseudomonas corrugate	No	Yes

Pythium root rot 	No	Not listed

Source:  Louws et al 2002 and Besri, M.  2005.

Table III.3 Resistance of Tomato Rootstocks to the Most Common Soil
Borne Pathogens  TC "Table III.3 Resistance of Tomato Rootstocks to the
Most Common Soil Borne Pathogens" \f F \l "1"   

Rootstock	Pathogens

	K	V (1)	F (1, 2)	N	Fr

L. esculentum x L. hirsutum	+	+	+	+	+

L. esculentum	+	+	+	+	+

Source:  Besri, M.  2005.

K: Pyrenochaeta lycopersici, V (1): Verticillium dahliae (race 1), F
(1,2): F. oxysporum f.sp. lycopersici (races 1 and 2), N: Meloidogyne
spp, Fr: F.oxysporum f.sp. radicis lycopersici   Resistance to
Pseudomonas (Ralstonia) solanacearum is provided by S .torvum and S.
aethiopicum.  In addition, these two rootstocks are resistant to
Meloidogyne spp.  

In addition, USG is not aware of any research demonstrating that
grafting offers protection against weeds (such as nutsedge).  A
significant portion of the US nomination for MeBr is for the control of
weeds (in the southeast) as well as soilborne diseases.  In the
protected environment of the greenhouse, grafting may offer sufficient
disease protection, but in the open field situation which characterizes
most of the vegetable production in the US, grafting does not offer
protection against the suite of pests faced by growers.  Therefore, even
if resistance to Phytophthora pathogens is identified, several years’
tests of how grafting can be effectively integrated with other pest
management strategies will be necessary before it can find commercial
acceptability in open-field vegetable production in the US.  At present
there are no grafted rootstocks that can deal with the entire US pest
complex.

In addition, cost remains a significant factor inhibiting adoption of
grafted plants in open-field vegetable production.  Grafting is a very
labor-intensive activity, consequently the cost of grafted plants is
highly dependent on labor costs.  In countries as geographically
separated as Morocco and Mexico, the cost of a grafted vegetable plant
is approximately $0.10 each.  In the United States, and countries with
similar labor costs, such as Canada, however, higher labor costs push
the cost of a grafted stem to more than four times the cost.

According to Dr. Chieri Kubota (personal communication), a grafting
expert with the University of Arizona, a grafted plug of two stems, that
is ready for field use, costs $0.90,  The presence of two stems means
that the plant will have twice the yield of a normal, one stemmed,
plant.  The cost increase, however is still significant.  The normal
cost of a non-grafted plug, ready for planting in the field, is
approximately $0.20.  The grafted plant, then, costs 125% more than a
conventional plant per stem.

MBTOC Question

3. Please refer particularly to general questions above.

US Response

Please see detailed responses in the separate section addressing the
general questions

US EGGPLANT- FIELD  TC "US EGGPLANT- FIELD" \f C \l "2"  

MBTOC Question

1. In tomato trials, 1,3-D: chloropicrin 65:35 with and without VIF,
1,3-D: chloropicrin 65:35 & metolachlor & trifloxysulfuron and Metam
sodium (MNa) : chloropicrin  provided similar yields as MB: chloropicrin
67:33 in 3 trials over the spring and fall of 2003 and spring of 2004.
(Santos, et al, Crop Protection, 2006). Are the herbicides trialled all
registered on eggplant? Are there plant back or market window effects?
Can VIF be used in this area for eggplant in all growing areas?

US Response

USG assumes that MBTOC is referring to the following citation:
“Comparing methyl bromide alternatives for soilborne disease, nematode
and weed management in fresh market tomato”, Santos et al., Crop
Protection 25: 690-695.  The registration status of the herbicides
mentioned in the question above is as follows: neither s-metolachlor
(Dual Magnum ™) nor trifloxysulfuron sodium (Envoke ™) are
registered in the US on eggplant.  Metam-sodium is registered on
eggplant.

However, USG is not clear on how MBTOC arrived at the conclusion that
all the treatments listed in its question provided similar yields to
MeBr:chloropicrin.  To quote what is arguably the most practically
relevant result of the study, “During two of the [three] seasons,
1,3-D + chloropicrin with VIF, sodium azide at 85 kg/ha, and propylene
oxide were consistently equal to methyl bromide + chloropicrin .”  Of
these materials, only 1, 3 D + chloropicrin is currently registered for
use in US eggplant.  In a similar study published in 2006, Gilreath et
al. (in Crop Protection Vol. 25: 79-82) state that “…the combination
of C-35+ chloropicrin +pebulate +trifluralin can provide an effective
wide-spectrum fumigant program to replace methyl bromide + chloropicrin
applications in polyethylene-mulched tomato.” However, pebulate is not
registered for use in US eggplant.  Triflularin is registered, but since
it is the combination with pebulate and 1,3 D+ chloropicrin  that showed
promise, trifluralin alone is not a feasible substitute for MB+
chloropicrin . Also, in both Santos et al. (2006) and Gilreath et al.
(2006), Phytophthora pathogens, major targets of MeBr use, were not
included as test subjects. Thus it remains unclear whether even the
combinations of unregistered and registered alternatives that were
tested will be as effective as MeBr for control of this pathogen. 

As regards the results cited for 1,3 D + VIF, the following important
caveats must be resolved before this option can feasibly replace MeBr
use in eggplant (or any other open-field vegetable crop) across the
entire US: (1) the effect on Phytophthora pathogens needs to be studied;
(2) results need to be validated on commercial scale fields (as was done
by Gilreath et al. 2006, for other MeBr alternatives discussed above);
(3) 1,3-D + chloropicrin  + VIF needs to be evaluated in areas with
different climatology than the subtropical region where Gilreath et al.
(2006) conducted their work.

To address the other questions included in this item: there are indeed
plant-back restrictions with all the herbicides mentioned.  For example,
in cucurbits, s-metolachlor has a 12 month plantback restriction, and
trifloxysulfuron sodium on transplanted tomatoes has an 18 month
plantback restriction. Metolachlor has a preharvest interval of 90 days,
which can interfere with harvest timing to coincide with optimum market
windows. 

VIF and metallised films remain under study for commercial feasibility
in US vegetable crop production. Metallised films are now in tentative
use by vegetable growers in Florida, but use has not yet become
widespread. Promising results have been observed in recent studies of
new preparations of VIF in Florida (e.g., Gilreath et al. 2005).
However, VIF cannot be used with MeBr in California due to worker safety
concerns (VIF use is banned by state law). Furthermore, the economic
feasibility of VIF use in other parts of the US remains unclear.

Costs associated with VIF are discussed by Noling (2002, revised 2005),
and this description is summarized in the USG response to a similar
MBTOC question for US strawberry nurseries. The relevant text is
reproduced below.

According to Noling (2002, revised 2005): “Historically VIF mulches
have suffered from high cost and from other problems involving tensile
strength.  They are typically slow to properly install and are subject
to tearing (zippering) during machine application in the field.  More
efficient containment of gases below the mulch also suggests that
plantings may have to be delayed to insure soil residues have dissipated
and plant injury will not occur.  The average price for LDPE mulch is
approximately $250-300/acre, while HDPE mulch is $400 /acre and VIF
mulch in the range of $400 to 600/acre.  The higher price for VIF is
partially reflective of transportation costs from European
manufacturers.  Compared to LDPE, reduced methyl bromide and
chloropicrin application rates (as much as 50%) and use of the VIF mulch
will result in lower fumigant costs which may be completely offsetting
given the higher pricing for methyl bromide now in reduced supply.”

In addition to the increased direct cost of VIF, increased labor costs
for slower machine installation of the mulch should probably also be
considered.  At present, given the slick, non embossed surfaces of VIF,
machine application of the VIF in the field is typically less than 3
miles per hour.  Manufacturer research programs are continuing to focus
on ways to resolve many of these problems…  In addition to higher
costs per acre, problems of VIF availability also must be considered. 
VIF is currently manufactured near exclusively in Europe and Israel by
various producers. As a result of overseas production, users in the
United States will likely incur lengthy delays (upwards of 2-3 months)
for delivery of ordered products.  There is also concern that although
the raw materials needed to produce VIF are readily available in the US,
current European production capacity is not high enough to meet US
demand if it were to substantially increase in the future.  To resolve
future demand, if it materializes, production facilities in the US would
have to be established to insure timely supply.”

MBTOC Question

2. Are grafted plants being tested for disease infested areas. If so,
please provide evidence that they are not suitable as an alternative to
MeBr.  If not, why?

US Response

The following table summarizes the current state of research on grafting
in US vegetable production, to the extent that USG has been able to
ascertain.

Table III.1 Key Pests for Eggplants and Grafting Research Status  TC
"Table III.1 Key Pests for Eggplants and Grafting Research Status" \f F
\l "1"   

Key Pest	Grafting Research Status

Nutsedge, Cyperus spp.	No research planned in the US due to lack of
resistant rootstock.

Phytophthora capsici	No research planned in the US due to lack of
resistant rootstock.

Fusarium oxysporum     	Research planned and underway in the US.

Nematodes,  Meloidogyne incognita	No research planned in the US due to
lack of resistant rootstock.



Several US seed companies, some in collaboration with the US Department
of Agriculture, are conducting tests of the commercial feasibility of
using grafted, disease-resistant cucurbits, tomatoes and peppers in
greenhouse and open field production (Core, 2005, Kubota, personal
communication, 2006). Some of these trials are being conducted in the
southeastern US (Core, 2005). However, these tests are highly
preliminary and there is as yet no assurance that such grafted plants
are commercially acceptable in pest management and economic terms.
Grafted vegetables are commercially used mostly in greenhouse tomato
production in the US. However, there is no significant greenhouse
production of eggplants in the US, as far as USG can ascertain. Indeed,
more than 90% of grafted vegetable seedlings are tomatoes in North
America (Kubota, personal communication, 2006). Virtually all these
grafted tomatoes are used in greenhouse production.

It is not clear whether grafting is being evaluated for resistance to
Phytophthora spp. pathogens, a critical disease pest of cucurbits
currently targeted by MeBr use in the US. USG is unaware of any research
conducted on the suitability of grafting as a control option against
this pathogen.

Table III.2 Resistance to Important Plant Pathogens and Pests in North
Carolina and the Mediterranean.  TC "Table III.2 Resistance to Important
Plant Pathogens and Pests in North Carolina and the Mediterranean." \f F
\l "1"  

Pathogen or Pest	Resistant Line Reported by North Carolina (F. Louws)
Resistant Lines Reported in Mediterranean (M. Besri)

Verticillium race 1	Yes	Yes 

Verticillium race 2	No	Not listed

Ralstonia solanacearum	Yes	Yes

Fusarium solani race 1& 2	Yes	Yes

Fusarium solani race 3 	Yes	Not listed

Sclerotium rolfsii	No	Not listed

Root knot nematodes Meloidogyne spp.	Yes	Yes

Phytophthora capsici	No	Not listed

Pseudomonas corrugate	No	Yes

Pythium root rot 	No	Not listed

Source:  Louws et al 2002 and Besri, M.  2005.

Table III.3 Resistance of Tomato Rootstocks to the Most Common Soil
Borne Pathogens  TC "Table III.3 Resistance of Tomato Rootstocks to the
Most Common Soil Borne Pathogens" \f F \l "1"   

Rootstock	Pathogens

	K	V (1)	F (1, 2)	N	Fr

L. esculentum x L. hirsutum	+	+	+	+	+

L. esculentum	+	+	+	+	+

Source:  Besri, M.  2005.

K: Pyrenochaeta lycopersici, V (1): Verticillium dahliae (race 1), F
(1,2): F. oxysporum f.sp. lycopersici (races 1 and 2), N: Meloidogyne
spp, Fr: F.oxysporum f.sp. radicis lycopersici   Resistance to
Pseudomonas (Ralstonia) solanacearum is provided by S .torvum and S.
aethiopicum.  In addition, these two rootstocks are resistant to
Meloidogyne spp.  

In addition, USG is not aware of any research demonstrating that
grafting offers protection against weeds (such as nutsedge).  A
significant portion of the US nomination for MeBr is for the control of
weeds (in the southeast) and nematodes (California), as well as
soilborne diseases.  In the protected environment of the greenhouse,
grafting may offer sufficient disease protection, but in the open field
situation which characterizes most of the vegetable production in the
US, grafting does not offer protection against the suite of pests faced
by growers.  Therefore, even if resistance to Phytophthora pathogens is
identified, several years’ tests of how grafting can be effectively
integrated with other pest management strategies will be necessary
before it can find commercial acceptability in open-field vegetable
production in the US.  At present there are no grafted rootstocks that
can deal with the entire US pest complex.

In addition, cost remains a significant factor inhibiting adoption of
grafted plants in open-field vegetable production.  Grafting is a very
labor-intensive activity, consequently the cost of grafted plants is
highly dependent on labor costs.  In countries as geographically
separated as Morocco and Mexico, the cost of a grafted vegetable plant
is approximately $0.10 each.  In the United States, and countries with
similar labor costs, such as Canada, however, higher labor costs push
the cost of a grafted stem to more than four times the cost.

According to Dr. Chieri Kubota (personal communication), a grafting
expert with the University of Arizona, a grafted plug of two stems, that
is ready for field use, costs $0.90,  The presence of two stems means
that the plant will have twice the yield of a normal, one stemmed,
plant.  The cost increase, however is still significant.  The normal
cost of a non-grafted plug, ready for planting in the field, is
approximately $0.20.  The grafted plant, then, costs 125% more than a
conventional plant per stem.

US NURSERY STOCK - FRUIT TREES, NUT AND FLOWER NURSERIES  TC "US NURSERY
STOCK - FRUIT TREES, NUT AND FLOWER NURSERIES" \f C \l "2"  

MBTOC Question

Questions for Western Raspberrv Nurseries

1. The overall nomination has increased with respect to last years'
nomination.  This is due to the raspberry nominated area going from 47
Ha to 143 Ha. Could Party please provide reasons for this increase? 
What are the transition strategies for this sector?

US Response

MBTOC is correct, for both 2006 and 2007 the request for the Western
Raspberry Association was for a total of 10,952 kg to be used on 47
hectares.  The US apologizes for the error which occurred because the
quarantine (QPS) amount was not correctly deducted from the request. 
The correct request for 2008 should also be for 10,952 kg to be used on
47 hectares.  As described in Section 23 of the nomination document the
transition will depend on the outcome of current research.  Research
plans include developing VIF, deep injection, 1,3-D efficacy, and
reduction of MeBr use rates.  Transferring these technologies to field
situations requires additional time.

MBTOC Question

2. MBTOC standard presumptions call for MeBr rates of 200 kg/ha for
nursery stock.  This CUN however is for higher dosages of 254 to 319
kg/ha MeBr.   Could the Party please provide data to substantiate the
need for these higher rates and also why lower rates of MeBr with
chloropicrin are unsuitable (eg 50:50, 30:70 or lower)?

US Response

According to the CDFA regulations for Approved Treatment and Handling
Procedures to Ensure Against Nematode Pest Infestation of Nursery Stock
the standard MeBr rate for compliance in treating field-grown stock for
nematode control is 336 kg per ha (CDFA, 2003a; see Schedule A, page 5).
 Chloropicrin is not listed as an alternative for this purpose for
nursery stock.  In addition, chloropicrin is a fumigant currently
undergoing reregistration by both EPA and California Department of
Pesticide Regulation.  Until risk assessments have been completed,
County Agricultural Commissioners have been reluctant to allow high
rates of chloropicrin to be used and permits for such are difficult to
obtain by growers of various commodities.

US FOREST NURSERIES  TC "US FOREST NURSERIES" \f C \l "2"  

MBTOC Question

1. An increase of 24 Ha and 9.2 tonnes in the nomination area is
observed with respect to last year's CUN (after discounting Michigan
herbaceous perennials which are now included in the ornamentals CUN). 
Could Party please explain the reasons for this increase?

US Response

The US is puzzled by MBTOC’s assertion that there is an increase in
the request for the forest nursery sector.  In 2007 the total request
for this sector was 152,629 kilograms to be used on a total of seven
seedling groups and on a nursery for herbaceous perennials in Michigan. 
Of the total, the Michigan request comprised 4,246 kilograms.  For 2008
the total request for the forest nursery sector is 133,140 kilograms. 
This represents a reduction of over 19,000 kilograms after accounting
for the transfer of the herbaceous perennials request to the ornamental
sector.  MBTOC is correct that there is a very minor increase in the
requested hectares.  Prior to the 2008 request the requested amount, the
use rate, and the total kilograms requested were all independent. 
Because of rounding errors introduced when calculations are truncated to
two decimal points, further exacerbated when conversion from English
units, used in the US, to metric units, used by MBTOC occurs, the three
numbers were not always consistent.  Starting with the 2008 nomination
the US calculates the number of hectares by dividing the request by the
use rate.  This resulted in some minor differences ion the number of
hectares between the 2007 and 2008 requests.

MBTOC Question

2. Could the Party please provide a description of transition strategies
envisioned for this nomination?

US Response

The Party is attempting to coordinate transition plan commitments from
the requesting consortia and should be able to provide more information
in the coming year regarding a time schedule for transition.  As of this
writing, there appears to be a consensus that additional research must
be completed to further identify appropriate pest management strategies
that could substitute for MeBr.  Some of the larger nursery owners, such
as Weyerhaeuser and International Paper, have invested significant
resources to find alternatives to MeBr.   Currently, there are plans to
test the efficacy of a formulation of 1,3-D, chloropicrin, and
metam-sodium (Weyerhaeuser, personal communication, Aug. 2005). 
However, special equipment to inject the metam-sodium has been a
limiting factor in completing the tests.  Inconsistent availability and
higher costs of equipment and tarps and testing requirements of new
material in the field make it difficult to predict the exact timing of
transition from MeBr.   Fall fumigations in cooler soils were not
problematic for MeBr, but are less effective with the use of MITC
products, such as metam-sodium, which are more sensitive than MeBr to a
narrow window of temperature and soil moisture.  However, completed
tests indicate that some combination of pesticides will be effective in
managing the various pests that occur in nurseries throughout the US. 
Smaller nurseries have fewer resources, and therefore, have concerns
that their ability to maintain production will be compromised if proven
alternative pest management strategies with MeBr are not available.  

US ORCHARD REPLANT  TC "US ORCHARD REPLANT" \f C \l "2"  

MBTOC Question

I. Are MB: chloropicrin  formulations (50:50 or 30:70) and EC
formulations of 1,3-D : chloropicrin  suitable for at least a proportion
of the nomination?  A recent study has demonstrated effective control of
nematodes at 35 gallha with 1,3-D and 1,3-D: chloropicrin EC across a
number of sites and trials as references in the TEAP progress report
(Schneider et al, 2005). 

US Response

In general, yes.  However, higher rates of chloropicrin than the
standard 33% may be problematic for two reasons.  First, until the new
risk assessments for chloropicrin have been completed by California and
EPA, it is the Party’s understanding that California County
Agricultural Commissioners have been hesitant to give unrestricted use
permits to high rates of chloropicrin (California Strawberry Commission,
Dan Legard, personal communication; March, 2006).  Second, chloropicrin
is an effective fungicide, but it is not known as an effective
nematicide.  Where nematodes appear to be the key pest, higher rates of
chloropicrin will not be effective in their management.  However,
replant disorder is many times of an uncertain etiology and chloropicrin
has been found to have a positive effect in some orchard replant
situations (e.g., Trout et al., 2003).  For areas where permits are
available for 50% or 70% chloropicrin, and where fungal pathogens have
been identified as key factors in replant disorder, higher rates of
chloropicrin might be effectively used.  Research for all of the
requested commodities (e.g., grapes, stone fruit, almonds, walnuts,
etc.) has been conducted for several years (see MBAO published reports).
 Depending on variables such as location, soil type, plant type, history
of previous orchard plantings, etc. different management strategies are
emerging, but specific strategies must be tailored to individual orchard
requirements.

As to 1,3-D use, the US nomination has attempted to account for soils
that can, and cannot, use 1,3-D based on soil type.  Therefore, the
Party maintains that the nomination for MeBr for this sector is valid
and pertains to those replant situations where coarse-textured soils do
not occur.  Orchard replant areas with more amenable soils currently use
alternatives to MeBr. 

Schneider et al. (2005) used treatments in vineyard replant experiments,
beginning in 1999, that included 35 gal Telone EC per Acre (370 kg 1,3-D
per Ha) accompanied by metam-sodium (Vapam).  Metam-sodium was applied
through microsprinklers.  Plots treated with 1,3-D were supplied with
either 2.5 inches (6.35 cm) or 4 inches (10 cm) of water through buried
drip tape.  Meloidogyne spp. and Tylenchulus semipenetrans populations
were examined over a six year period, after treatment of three different
grape rootstocks in a replanted vineyard.  Telone-treated plots
generally provided comparable population control to MeBr -treated plots.
 Fallow periods in combination with various chemical treatments were
generally positive treatments.  

It is not surprising that 1,3-D provided effective nematode control in
test plots under generally optimal conditions, since it is an effective
nematicide.  Aside from the possibly significant issue of township
restrictions, the concern by orchard managers is that scaling-up from
test plots to commercial scale orchards and vineyards may be a difficult
step where optimal conditions do not prevail.  McKenry (1999) stated
that the positive effects of 1,3-D are generally limited to coarse
textured soils.  

MBTOC Question

2. MB: chloropicrin 70:30 and 50:50 mixtures were used in replant
industries in other countries before MeBr was phased out for this use. 
These formulations are available for use in California; what prevents
their adoption or can the Party submit evidence showing that they are
ineffective?

US Response

As noted in the previous response, chloropicrin is not generally
regarded as a highly effective nematicide, although it is an effective
fungicide.  For situations where fungal soil pathogens have been
identified as important causes of replant disorder, higher rates of
chloropicrin could satisfy replant requirements (if nematodes can be
controlled as well), and may be used, if permits can be obtained. 
However, also as noted in the previous response, permits for use of high
rates of chloropicrin may be restricted due to California County
Agricultural Commission hesitation to grant use permits as the new risk
assessments for chloropicrin are being finalized.  

MBTOC Question

3. The CUN states that the historical use of MeBr for this sector for
2003 was 796.309 tonnes. However, figures released by Trout (2005) for
the same period indicate that 355.35 t was used. Can the Party provide
an explanation for this difference?

US Response

In determining the amount of methyl bromide historically used in a
sector, the USG relies both on published and proprietary sources of
information.  These sources include not only reports to the California
Department of Pesticide Regulation (Cal DPR) and the National
Agricultural Statistical Service (NASS) database, but also a proprietary
source that tracks pesticide use by crop.  The Trout study relied on Cal
DPR data alone.  USG has reason to believe that the Cal DPR data has
become less complete, and therefore less accurate, in recent years as
budget cutbacks have reduced resources available for data entry.  The
USG continues to believe our estimates are the best available.

US ORNAMENTALS  TC "US ORNAMENTALS" \f C \l "2"  

MBTOC Question

1.  In Florida:  What proportion of the nomination covers muck soils? 
At what depth are caladiums normally planted in the soil?

US Response

It is estimated that approximately 75 to 80% of Florida caladiums are
currently produced in muck soils.  

Caladium tubers are planted at a depth that allows 1 to 1 ½ inches
(2.54 to 3.81 cm) of soil to cover the tuber (Evans, Harbaugh, and
Wilfret, 1993).   

MBTOC Question

2.  In Michigan:  The nomination is for less than 1% of total crop area
for Michigan.  Could Party further elaborate on what is limiting
adoption of alternatives in this area?  Is a certification requirement
associated with this portion of the nomination?  If yes, can Party
please provide details?  Are there reasons why MeBr formulations with
higher chloropicrin content, i.e. 67:33 or 50:50 cannot be used in this
area?

US Response

Michigan Department of Agriculture (MDA) certification is required. The
product must be inspected according to the requirements of the country
to which the product is being shipped.  Growers cannot ship product
without a clean inspection and certification. (Please see   HYPERLINK
"http://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-189-of-1931.pdf
" 
http://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-189-of-1931.pdf
)  Fumigating is not a regulatory requirement nor is fumigating with
methyl bromide mandatory.  However, crops need to grow free from
nematodes and certain diseases in order to meet trade requirements. 
Generally, growers have found that methyl bromide is the best way to
meet these requirements.  The 67:33 and 50:50 formulations cannot be
used because they are ineffective on nematode populations and weed
control and would not be adequate to allow crops to pass MDA inspection
and certification.

MBTOC Question

3.  MBTOC needs clarification on the feasibility of using other
strategies (e.g. herbicides + 1,3-D: chloropicrin  or metham sodium and 
chloropicrin ) for at least part of the nomination.

US Response

The US has described the limitations of these and other strategies in
the CUN (in Tables 13.1 and 14.1).  In addition, growers are currently
using other strategies to the extent feasible (more details included in
US responses to questions 4 and 5).  However, a brief description of the
strategies identified is included below.

The feasibility of herbicides varies by crop, depending on phytotoxicity
issues (including carryover to other crops), registration status, and
efficacy.  The short time interval between crops (a crop cycle may only
last 90 days) often restricts the use of herbicides due to replant
intervals and/or phytotoxicity.  In addition, this industry must respond
to market changes, requiring growers to produce new ornamental crops
and/or varieties to meet consumer demands.  It is difficult to conduct
herbicide phytotoxicity research on all of the new varieties introduced.
   

In California and Florida field grown ornamentals, a major concern is
that phytotoxicity may occur with herbicide use.  Contact herbicides may
damage an emerged crop and soil persistent pre-emergent herbicides may
damage current or subsequent crops, particularly since crop cycles can
be short.  Complicating factors are described in the paragraph above. 
1,3-D + chloropicrin  will not provide adequate weed control.  Metham
sodium + chloropicrin does not adequately control nutsedge or volunteer
ornamental crops and is costly due to the need for two separate
applications.  In Florida, this combination is more effective than
1,3-D: chloropicrin  but weeds are not adequately controlled.  The
limitations associated with herbicide use notwithstanding, the
additional cost of weed control makes this combination not economically
feasible at current prices.  Additional information on other strategies
can be found in the CUN or the Methyl Bromide National Management
Strategy for Field-grown Ornamentals in Florida and California (2005)
(This strategy was developed by the industry and is provided as an
appendix).

In Michigan, growers do not have sufficient data on safe herbicides for
ornamentals.  Of particular concern is carryover action for future
perennials in the treated field.  In addition to providing erratic
control, growers are reluctant to apply metam sodium near residential
areas due to off-gassing.  1,3-D: chloropicrin  provides variable weed
control and there is concern about the potential for groundwater
contamination. 

In one Michigan study submitted with the nomination (Table VIII.1 below)
some herbicides are effective but may cause significant crop injury.  In
addition, these herbicides are currently not registered for control of
this weed.  Use, except in accordance with the label, is not legal. 
Some limitations to this study include no methyl bromide control
treatment and no data from an untreated control.

Table VII.1: Michigan Herbaceous Perennials – Hosta –Effectiveness
of Alternatives – Inula brittannica  TC "Table VII.1: Michigan
Herbaceous Perennials – Hosta –Effectiveness of Alternatives –
Inula brittannica" \f F \l "1"  

Key Pest: Inula Brittannica	Average Percent weed control and Average
Percent Crop Injury

Methyl Bromide formulations and Alternatives 

	# of Reps	October 15, 2001	June 20, 2002



Weed Control (%)	Crop Injury (%)	Weed Control (%)	Crop Injury (%)

Triclopyr + clopyralid (1.68 kg ai/ha)	n/a	100	19	89	89

Dicamba (2.24 kg ai/ha)	n/a	100	41	67	78

Clopyralid (0.28 kg ai/ha)	n/a	100	19	67	26

Clopyralid (0.56 kg ai/ha)	n/a	100	22	81	33

2,4-D + clopyralid (1.5 kg ai/ha)	n/a	100	22	78	37

2,4-D (3.36 kg ai/ha)	n/a	97	37	74	56

Triclopyr (2.24 kg ai/ha)	n/a	89	3	70	81

Glyphosate (4.48 kg ai/ha)	n/a	48	41	26	89

Diquat (1.5 kg ai/ha)	n/a	52	97	26	14

Dicamba + diflufenzopyr (0.196 kg ai/ha)	n/a	89	26	8	78

LSD

10	23	30	16

(Richardson, Zandstra, and Dudek, 2004 CUE Submission)

MBTOC Question

4.  In general:  For what percentage of this nomination could MeBr be
used every other year with an alternative in between?

US Response

The applicants have already accounted for this strategy in the request
for methyl bromide.  Their request is based on recorded or estimated
actual amounts of methyl bromide used.  Methyl bromide use has been
reduced using a number of strategies, including using MeBr every other
year. 

There are a couple of ways this strategy can be used.  Some California
growers rotate into fields after strawberry production in which the
fields were fumigated with methyl bromide.  This strategy may not be
possible every year and depends on the availability of methyl bromide
for the other crop.  Growers can also rotate fumigants.  An example is
rotating use of methyl bromide and metam sodium so that methyl bromide
is not applied every time fumigation is needed.  This does not eliminate
the need for methyl bromide but reduces its use.  

In California and Florida, an estimate of the percentage using this
strategy could not be determined.  In Michigan, it is estimated that 25
percent of the nomination could use MeBr every other year with an
alternative in between.  However, since the parties to the protocol have
not allowed multiple year nominations the growers cannot design a long
term strategy to treat with methyl bromide on an alternating year basis.

The nomination will be further reduced as it is determined that the
necessary application frequency allows such reductions.  However,
currently growers have already used the viable strategies to reduce
methyl bromide use.  As research demonstrates ways to reduce methyl
bromide use and/or new alternatives become available, it is expected
that growers will transition to the methods and/or alternatives.

MBTOC Question

5.  Could the Party please provide an explanation as to why no
transition strategies have been included with this nomination?

US Response

In California and Florida, a Methyl Bromide National Management Strategy
has been developed.  Growers have already transitioned away from methyl
bromide or reduced use to the extent possible using practices such as
formulation changes, tarping after application and the use of
alternatives.  Research is focusing on using existing chemical and
non-chemical methods, such as application techniques and barrier films,
in order to reduce methyl bromide rates, gas emissions and/or switch to
alternatives.  Non-registered products, such as iodomethane, are also
being researched.  As feasible alternatives are found, growers will
transition to these alternatives.  Once a new alternative is found
and/or registered, growers will need three to five years to evaluate and
transition to the alternative.

In Michigan, the transition strategy involves continued research on
alternatives.  Growers are starting to evaluate the use of more
herbicides, hand weeding, reducing depth of tillage following the
harvest of the first crop, planting crops not as susceptible to
nematodes after the first crop is harvested, and exploring use of
Basamid, Telone, and Metham sodium.

Additional Comments from MBTOC  TC "Additional Comments from MBTOC" \f C
\l "2"  

MBTOC Comment

This nomination is for over 98% for field grown flowers in California
and 100% field flowers in Florida, and one of the key issues is cleaning
fields of bulbs and tubers left from previous crops.

US Response

This nomination is for less acreage and a lower percentage of acres
planted than indicated by MBTOC in the comment.  First, as shown in
Table IX.1, the nomination amount (kilograms) is less than the applicant
request.  Although the applicants may have requested MeBr for more area,
the US nomination is for 33 percent, 10 percent, and 69 percent of the
amounts requested by California, Florida, and Michigan, respectively.  

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

Region	California	Florida	Michigan

Amount of Applicant Request

2008  Kilograms	204,116	622,328	4,763

Amount of Nomination*

2008  Kilograms	67,946	63,232	3,300

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

Further, MeBr was not requested for all acreage grown in California and
Florida (see Table IX.2).  Please note that the table includes general
categories.  The proportion of area treated with methyl bromide for a
specific species may vary.  

 

Table VIII.2 Proportion of Crop (Cut Flowers, Cut Florist Greens, Bulbs,
Corms, Rhizomes, and Tubers) Grown Using Methyl Bromide  TC "Table
VIII.2 Proportion of Crop (Cut Flowers, Cut Florist Greens, Bulbs,
Corms, Rhizomes, and Tubers) Grown Using Methyl Bromide" \f F \l "1"  

Region where Methyl Bromide use is requested

Total crop area (ha)*

Proportion of total crop area treated with methyl bromide (%)**

California

5,795

6%

Florida

5,402

26%

National Total:

15,542

11%



* 2002 USDA Census of Agriculture for cut flowers and cut florist
greens, and bulbs, corms, rhizomes and tubers – dry

** For proportion of total crop area treated, included historical methyl
bromide data from 2002 and 2003.  For national total, included data from
California and Florida only. 

It is correct that one of the key issues is cleaning fields of bulbs and
tubers left from previous crops.  

MBTOC Comment

Versions of metalized films are being widely tested by several
researchers and growers and show promise; it should be possible to apply
these in all areas excluding California.

US Response

Metallic films, as described in the Methyl Bromide National Management
Strategy for Field Grown Ornamentals in Florida and California (2005),
show promise for allowing good pest control and reducing gas emissions. 
One concern that needs to be addressed is whether the air temperatures
above the film will be too hot for ornamental species.  The US expects
that metallic films will be adopted if research and experience
determines that it is feasible for this industry.

US STRAWBERRY FRUIT – FIELD  TC "US STRAWBERRY FRUIT – FIELD" \f C
\l "2"  

MBTOC Question

1. The BUNNl estimates that 33% of the CUN in Florida and Eastern states
would be able to transition to alternatives over 7 years, and that the
annual rate is 5%.  The Party kindly noted in its responses earlier this
year that a DELPHI process was used to make this estimate. MBTOC
requests the Party to provide more detailed information about the
technical grounds on which such rates can be calculated, and feasible
rates of adoption.

US Response

The Rand Corporation developed the forecasting studies that led to the
first Delphi method starting in 1944 for military uses, specifically to
estimate the probable effects of an atomic bomb attack on the United
States.   In general, the Delphi provides a practical approach to
collection of data that are currently unavailable and cannot be
efficiently generated by more traditional, precise analytical methods. 
This methodology is particularly useful for examination of issues that
may be too complex for conventional analysis.  

As a result, over the past four decades, this procedure has become a
popular tool in technological forecasting, and a single definition is no
longer appropriate for its numerous applications.  Basically, the Delphi
may be described as: a method for developing an effective group
communication process for dealing with a complex problem; a technique
used to elicit opinions with the goal of obtaining a group response from
a panel of experts; and as being characterized by three distinguishing
features.  These features are: anonymity for all respondents with
respect to their responses; iteration with controlled feedback; and
statistically interpretable group response.

At least part of the Delphi’s appeal is attributable to the
flexibility of the methodology; the process is adaptable to a wide range
of investigations.  Despite this malleability, experts maintain that
four elements are critical to the process.  These elements include:
feedback in the form of individual contributions or responses;
assessment of the group opinion; opportunity for individuals to revise
their original responses following the initial assessment of group
opinion; and guaranteed anonymity for the individuals who participate in
the process.

Human judgment is a useful (and legitimate) tool to use in forecasting. 
But using expert judgment can lead to problems.  Single experts may be
biased; open discussions with multiples experts can lead to “following
the leader’ or bullying behavior.  Once persons have made public
pronouncements there may be a reluctance to revise one’s opinion.  Use
of Delphi techniques removes the problems that other methods of
collecting and using expert judgments poses. 

When Delphi methods have been used well the forecasts have performed
significantly better than have other measures for predicting the future.
 A 1977 study compares five year sales forecasts derived from Delphi
methods (errors of 3-4% compared with actual performance) with estimates
from quantitative methods (10-15% errors compared with actual
performance) and results from unstructured, subjective forecasts where
the results deviated by 20% from actual performance. 

The Delphi method is most useful in answering one, specific, single
dimension question, exactly the kind of question one must address in
attempting to determine the future rate of transition away from methyl
bromide.

As has been pointed out elsewhere, see question number two of the
general questions, above, the alternatives for methyl bromide in
pre-plant uses are not new chemicals--  this is not a superior
technology replacing something old and dated.  Many if not most of the
chemicals pre-date methyl bromide and methyl bromide has been used in
preference to these chemicals.  Finding the techniques and chemical
combinations necessary to develop a fumigation system whose efficacy and
costs are comparable to methyl bromide is an arduous process that,
although it has allowed replacement of methyl bromide in the vast
majority of pre-1991 uses, has not yet allowed full replacement of all
uses in all regions of the country

Given the above, the issue is not the speed with which a new chemical or
new process can spread among growers, so that existing studies of the
rate of knowledge diffusion or the speed with which new products are
adopted are not relevant, but rather predicting how rapidly transition
away from methyl bromide can occur given how much has already occurred
and given the complex factors that must be considered.  Some examples of
these complex factors are when/how well can these (older) alternatives
be made to work with costs and efficacies that are more similar to
methyl bromide, for what portions of which crops can methyl bromide be
applied at lower rates, less frequency, etc

The variant of the Delphi process that was used to determine transition
rates by sector is derived from work by Barry Boehm and John A. Farquhar
from the 1970s known as “wideband”   They called it "wideband"
because, compared to the existing Delphi method, the new method involved
greater interaction and more communication between those participating.
The method was popularized by Boehm's book "Software Engineering
Economics" (1981). Boehm's original steps from this book were:

Coordinator presents each expert with a specification and an estimation
form. 

Coordinator calls a group meeting in which the experts discuss
estimation issues with the coordinator and each other. 

Experts fill out forms anonymously. 

Coordinator prepares and distributes a summary of the estimates 

Coordinator calls a group meeting, specifically focusing on having the
experts discuss points where their estimates varies widely 

Experts fill out forms, again anonymously, and steps 4 to 6 are iterated
for as many rounds as appropriate. 

A variant of Wideband Delphi was developed by Neil Potter and Mary Sakry
of The Process Group.  The original use of this variant was to forecast
the time needed to design software, but the variant has other
applications as well.

In the process as originally used, a project manager selects a moderator
and an estimation team with three to seven members. The Delphi process
consists of two meetings run by the moderator. The first meeting is the
kickoff meeting, during which the estimation team creates a work
breakdown structure (WBS) and discusses assumptions. After the meeting,
each team member creates an effort estimate for each task. The second
meeting is the estimation session, in which the team revises the
estimates as a group and achieves consensus. After the estimation
session, the project manager summarizes the results and reviews them
with the team, at which point they are ready to be used as the basis for
planning the software project.

The process to determine the time to transition was similar.  Dr.
Augustyniak of the US Environmental Protection Agency served as the
moderator for the Delphi estimation process.  The team consisted of the
senior biologists and economists whose work includes preparation of the
US request for methyl bromide under the critical use exemption (CUE)
provision of the Montreal Protocol, approximately ten scientists in all.

Choose the team. The project manager selects the estimation team and a
moderator. The team consisted of senior biologists and economists whose
portfolios include work in the US CUEs.

Kickoff meeting. Dr. Augustyniak held an initial meeting to prepare the
team.  She led a discussion to lay out the factual matters, to
brainstorm assumptions, and to agree on the elements and units of
estimation which were 1.) what proportion of each sector can transition,
and, 2.) how long will it take in years.. 

Individual preparation. After the kickoff meeting, each team member
individually generated the initial estimates for each sector,
documenting any missing assumptions. 

Estimation session. Dr. Augustyniak led the team through a series of
iterative steps to gain consensus on the estimates. At the start of the
iteration, Dr. Augustyniak charted the estimates on flip charts so the
team members could see the range of estimates. The team resolved issues
and revised estimates without revealing specific numbers. This cycle was
repeated several times until no team members wanted to change their
estimates..

Assemble estimates, review results. Dr. Augustyniak collected the
estimates from the team members at the end of the meeting and compiled
the estimates and assumptions.  At that time the team members agreed
that the estimates were acceptable 

The results of the process were then incorporated into the numerical
estimates of critically needed methyl bromide (the BUNNI).

To re-iterate the discussion from the general questions, because there
is no new (superior) product that can be used to replace methyl bromide
in pre-plant uses, further transition requires the slow, incremental
steps that come with learning how to use ever more complex combinations
of chemicals and processes to achieve outcomes comparable in efficiency
to the outcomes achieved with methyl bromide.

This process is judged to be more complicated and time consuming in
terms of transition than the situation where there is a “drop-in”
replacement.

MBTOC Question

2. The California Strawberry Commission has indicated that MeBr can be
used as a "clean up" treatment once every 3 years or so. The previous
and current CUN states that "the US anticipates that the decreasing
supply of MeBr will motivate grower to try less frequent applications
..." (Table 19.1). Has this been considered by the Party, and if not
what are the reasons? Do any US growers currently rotate MeBr with
alternatives? Please provide information.

US Response

According to the California Strawberry Commission (CSC) (personal
communication, Dan Legard; July, 2006): “There are two types of issues
relating to ground clean up.  The first involves the use of “new
ground” for production.  New ground is farmland that has not been used
recently for conventional strawberry production and the grower is
concerned that it may have serious disease or pest issues as a result. 
All growers will preferentially broadcast fumigate this ground with
methyl bromide to insure that any existing pest problem is cleaned up. 
Because a majority of growers lease their land, and with the size of the
industry growing by an average of 5% per year, there is always a
significant amount of new ground used each year (no estimate currently
available).  There is also an irrigation setup issue for growers farming
“new” ground.  The main valves and pipes for the irrigation system
need to be setup for strawberry, something that can’t be done while
the previous crop is in the ground.  This makes it extremely difficult
to properly setup the equipment for drip applied fumigants.  Growers in
this situation will have to use broadcast fumigation for the first year
on new non-strawberry ground.”

“The second category of clean up involves growers who have bed
fumigated with alternatives for several years.  Many of these growers
have experienced increasing plant health problems with each successive
year of alternative use.  Typically, after 2 to 3 years of drip
fumigation with Inline (telone + chloropicrin) they need to return to
broadcast fumigation with methyl bromide to “clean up” the field to
restore its full productivity.  We are currently unsure how many acres
are rotated back to methyl bromide to address these clean up issues, but
it has become a significant transitional issue.”

According to the CSC (personal communication, Dan Legard; July, 2006),
40-50% of the strawberry fruit production areas in California are
fumigated with MeBr alternatives.  Chloropicrin has been used in greater
amounts than MeBr in strawberry production in California, due to its
effective disease control properties.  Now, however, public health
concerns may affect the use of chloropicrin for strawberry growers
trying to transition from MeBr.   Consequently, periodic use of MeBr
only as a “clean up” treatment may be in jeopardy if regulatory
constraints are instituted reducing the ability of growers to use
alternatives such as chloropicrin or 1,3-D.  

Also, according to the CSC (personal communication, Dan Legard; July,
2006), many County Agricultural Commissioners have prohibited
applications of chloropicrin at rates greater than 200 lb per acre (225
kg per ha).  In addition, in major strawberry-growing counties of
Monterey and Santa Cruz, commissioners have told CSC that drip
fumigation with 1,3-D may require more restrictions if accidents
continue to be reported.  If this occurs, broadcast treatments, which
are more expensive and use more material (thus impacting township caps),
would have to be replacements.  Because of the regulatory complexities
of the use of alternative pesticides that could replace MB, there is
still a critical need in the future for MeBr for strawberry production. 

MBTOC Question

3. MeBr is presumably shank-injected at present on hilly terrain.  What
is the preparation time and treatment time for alternatives when using
injection equipment on hilly terrain?

US Response

According to the California Strawberry Commission (CSC) (personal
communication, Dan Legard; July, 2006):  “This issue is important
primarily in the northern districts of Watsonville/Salinas and Santa
Maria.  One of the significant differences between broadcast and drip
fumigation is that drip fumigation requires that the entire field and
irrigation set up be in place before the ground is fumigated.  This
typically requires 2-3 weeks longer than the prep time for broadcast
fumigation.  The longer turn around (or set up) time is not as serious
an issue for fields of Camarosa since this cultivar (variety) is  short
day and has a relatively short production season compared to day-neutral
(long day) cultivars like Diamonte that represent a majority of the
acreage in the Watsonville/Salinas district (90%) and half the acreage
in Santa Maria.  For ground planted with Camarosa, most growers do not
rotate the ground every year and can pull out the crop out early enough
to use drip applied fumigants without significant economic loss.”

“For ground with day-neutral cultivars, the production season overlaps
with the next strawberry crop’s planting season, so fields of
day-neutral cultivars are typically rotated with vegetable crops (i.e.
half the ranch is planted in strawberry and the other half is rotated
out and planted with vegetables each year).  The normal production cycle
is strawberry (September, year 1 – November, year 2) followed by two
vegetable crops (December, year 2 – September, year 3) then back to
strawberry (September, year 3 – November, year 4) (see Table 1).  The
value of the October / November fruit harvested from day-neutral
cultivars is relatively high and growers cannot remain profitable
shifting more of their production to short day cultivars like Camarosa. 
The need for an additional 2 to 4 weeks to prepare a field for drip
fumigation forces strawberry growers to take back rotation land from
vegetable growers up to a month earlier.  Normally, vegetable growers
can produce two crops between the strawberry rotations.  However, the
shortening of the season by 2 to 4 weeks would result in only one
vegetable crop being produced on most of the rotation ground.  Land
sublease rates to vegetable growers are approximately $1000 for one crop
and $1800 for two (the land leases for $2200 for full year).  Therefore,
strawberry growers would lose $800 in rent for a significant portion of
their acreage.”

“A second issue facing growers trying to transition to drip applied
fumigants is the need to setup the entire irrigation system before they
fumigate.  In the traditional production system (i.e. broadcast
fumigation), growers migrate most of their irrigation headers and other
main line pipes over from the previous season’s crop to the new after
the end of that season (in December/January).  However, for drip applied
fumigation, growers will need two sets of irrigation equipment, an
increased cost that is difficult for many growers to absorb.  We
estimate that this equipment has a one time additional cost of $400 to
$500 per acre.”

Table IX.1: Typical Production Cycle for Day-Neutral Strawberry and
Vegetable Rotation Crops, Watsonville / Salinas CA.  TC "Table IX.1:
Typical Production Cycle for Day-Neutral Strawberry and Vegetable
Rotation Crops, Watsonville / Salinas CA." \f F \l "1"  

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

Year 1	 -	  -	  -	  -	  -	  -	  -	  -	St1*	St1	St1	St1

Year 2	St1	St1	St1	St1	St1	St1	St1	St1	St1	St1	St1	Veg1

Year 3	Veg1	Veg1	Veg1	Veg1	Veg2	Veg2	Veg2	Veg2	St2	St2	St2	St2

Year 4	St2	St2	St2	St2	St2	St2	St2	St2	St2	St2	St2	Veg3

*St1,2 – strawberry crops 1 and 2;  Veg1,2,3 – vegetable crops 1, 2
and 3.

MBTOC Question

4. Earlier this year the USG reported that it had requested from the CA
Strawberry Commission an updated version of the table on MeBr use data
that was presented by CSC in the bilaterals in December 2005. At that
time a CSC representative kindly agreed to provide an updated version of
that table, with additional columns for total crop area and total
fumigated area (all fumigants).  We would be grateful to receive this
information at the earliest opportunity.  Please provide MeBr use
estimates for 2005 if possible, and the percentage of fumigated crop
that does or does not use MeBr. 

US Response

From the California Strawberry Commission

Table IX.2: Pesticide Use Records for Fumigants on Strawberry Fruit from
the California Department of Pesticide Regulation  TC "Table IX.2:
Pesticide Use Records for Fumigants on Strawberry Fruit from the
California Department of Pesticide Regulation" \f F \l "1"  

Year	Planted	Methyl bromide 	Chloropicrin	1,3-D 	Metam Sodium

	acres*	lbs	acres	lbs	acres	lbs	acres	lbs	Acres

2004	31,639 	3,186,693	18,467	3,258,348	28,241	1,522,286	9,108	274,472
1,741

2003	28,230 	3,671,414	20,593	3,282,716	27,015	884,325	4,997	237,943
1,126

2002	26,829 	3,701,642	20,500	2,910,004	24,187	440,338	2,472	238,030
1,370

2001	25,143 	3,765,630	22,241	3,004,794	24,314	146,349	1,044	85,757	605

2000	26,340 	4,226,039	22,579	2,357,795	22,854	12,988	143	63,107	313

1999	24,603 	5,171,765	25,492	2,392,491	25,317	528	2	132,552	936

metric









	Year	Planted	Methyl bromide 	Chloropicrin	1,3-D 	Metam Sodium

	ha	kg	ha	kg	ha	kg	ha	kg	ha

2004	12,804 	1,445,460	7,473 	1,477,962	11,429 	690,497	3,686 	124,498	
705 

2003	11,424 	1,665,325	8,334 	1,489,015	10,933 	401,123	2,022 	107,929
456 

2002	10,857 	1,679,037	8,296 	1,319,956	9,788 	199,734	1,000 	107,969
554 

2001	10,175 	1,708,061	9,001 	1,362,952	9,840 	66,383	  422 	38,899	245 

2000	10,659 	1,916,899	9,137 	1,069,478	9,249 	5,891	58 	28,625	127 

1999	9,956 	2,345,873	10,316 	1,085,216	10,245 	239	1 	60,125	379 

* From annual California Strawberry Commission survey. 

Conversion factors = acres to ha = 0.40468564.  lbs to kg = 0.45359237

MBTOC Question

5. The Party is requested to clarify why the key pest impact in
California was 0% in the BUN1 for 2007 and 100% in the BUNNl for 2008.

US Response

There are several changes between the 2007 and 2008 nominations.  One
change is in the calculation of the BUNNI—as described (above) so that
the number of hectares is a function of the total kilograms requested
and the methyl bromide use rate and no longer an independent number. 
This change, and others like it, will result in minor differences in
BUNNI entries between 2008 and previous years.

The reason for the change in the California strawberry entry is that the
California Strawberry Commission reduced its request for methyl bromide
using the same kind of assessments that the USG uses in determining
which situations (soil, terrain, level of pest, etc) can use
alternatives and for which situations methyl bromide is a critical need.
 California also included a factor for transition to alternatives.

In the past both the USG and MBTOC had reduced the California request by
cutting (erroneously) for situations that California had already removed
from its application, resulting in excessive reductions.  Because
California had demonstrated in their application that they were using
the same criteria in applying for methyl bromide that we use in
determining the amount, so that their request should not be reduced, we
placed a “100%” in key pests to assure that further cuts would not
be made.  An alternative would have been to indicate 100% in the other
factors such as “terrain”, “township cap” etc.

MBTOC Question

6. As noted previously, the revised label for 1,3-D states "Do not apply
this product within 100 feet of karst topographical features."  The EPA
stated that "Surface features that are associated with karst topography
include sinkholes, caverns, springs, and sinking or disappearing
streams." The US indicated earlier this year that it believes this
revised labeling does not change the areas where the use of 1,3-D
products is  permissible.  However the BUNNls suggest that very large
areas are limited by surface karst topography, such as 40% of the CUN
area for Florida strawberry fruit.  MBTOC respectfully requests
technical data and calculations to substantiate the percentage of CUN
area that is unable to use 1,3-D due to surface karst topography.

US Response

The US estimates of areas impacted by karst topographical features were
developed in conjunction with officials from the State of Florida at the
inception of the critical use evaluation (CUE) program.  At that time,
the manufacturer of 1,3-D had already requested a label change,
requesting that the label be changed from karst topography, which
underlies virtually all of Florida, to karst topographical features. 
The purpose of the label restriction had been to prevent 1,3-D from
entering groundwater, given Florida’s shallow aquifers and the
sinkholes etc that would allow its easy introduction.

The information available at the time indicated that the label change
would be approved in the near future (as it was) and that in the interim
enforcement discretion was being granted, i.e. individuals who used
1,3-D in conformance with the forthcoming label, rather than the then
current label, would not be at risk of a violation.  Given this
information, the USG decided to develop karst estimates, and
consequently estimates of methyl bromide need, based on the forthcoming
label.  

Appendix C contains maps showing both areas of karst topological
features and major growing areas of strawberry and vegetable production.
 Hillsborough County, one of the top three Florida counties in terms of
acreage planted for strawberries, cantaloupe, squash and tomatoes, is
approximately 50% karst featured.  Alachua County, third most important
for cantaloupe is over 60% karst featured.  When this information is
considered in conjunction with the complete ban on the use of 1,3-D in
Dade County (treated as karst featured by the USG for the purposes of
calculation), it is clear that for some important crops the 40% estimate
understates the need.

MBTOC Question

7. In order to assess the economic issues, MBTOC kindly requests the
Party to provide an Excel sheet showing itemized variable costs for
1,3-D: chloropicrin,  chloropicrin  EC, and chloropicrin + metham
sodium, showing the applied quantity of MeBr and current MeBr prices.

US Response

Table IX.3:  Variable Costs of Fumigants for Strawberries in California 
TC "Table IX.3:  Variable Costs of Fumigants for Strawberries in
California" \f F \l "1"  

Table IX.4:  Variable Costs of Fumigants for Strawberries in Eastern US 
TC "Table IX.4:  Variable Costs of Fumigants for Strawberries in Eastern
US" \f F \l "1"  

US STRAWBERRY RUNNERS  TC "US STRAWBERRY RUNNERS" \f C \l "2"  

MBTOC Comment

California certification requirements mandate MeBr and specify the
rates. CDPR regulations prohibit the use of LPBF. Neither is true for
the SE strawberry runners.

MBTOC Question

1. Reduced dosages of MB: chloropicrin  have been shown to be effective
for production of 'certified' strawberry runners ie. 20 glm2 (P13, UNE/
TEAP October 2005). Could these rates be applicable to SE?

US Response

Possibly.  However, the rates cited above were shown to be effective
only with use of LPBF.  In addition there are several key pests that
must be controlled with these reduced rates.  The TEAP report referenced
does not provide efficacy data for the key pests for strawberry nursery
production in the US (Black root rot Rhizoctonia and Pythium spp., Crown
rot Phytophthora cactorum ; root-knot nematodes Meloidogyne spp. And
weeds such as last years crop and nutsedge Cyperus spp.).  

In the US, marketing by LPBF industries is relatively new, as
traditionally these products have been made overseas and costs have been
high to US consumers (Noling, 2002, revised 2005).  These costs will
continue to impact growers.  However, research studies with LPBF have
indicated that reduced rates of MeBr can be effective, and reduced
fumigant use might offset some of the cost of low permeability films. 
Transition to lower rates of MeBr with LPBF will require a steady supply
of the films. 

According to Noling (2002, revised 2005): “Historically VIF mulches
have suffered from high cost and from other problems involving tensile
strength.  They are typically slow to properly install and are subject
to tearing (zippering) during machine application in the field.  More
efficient containment of gases below the mulch also suggests that
plantings may have to be delayed to insure soil residues have dissipated
and plant injury will not occur.  The average price for LDPE mulch is
approximately $250-300/acre, while HDPE mulch is $400 /acre and VIF
mulch in the range of $400 to 600/acre.  The higher price for VIF is
partially reflective of transportation costs from European
manufacturers.  Compared to LDPE, reduced methyl bromide and
chloropicrin application rates (as much as 50%) and use of the VIF mulch
will result in lower fumigant costs which may be completely offsetting
given the higher pricing for methyl bromide now in reduced supply.”

“In addition to the increased direct cost of the VIF mulch, increased
labor costs for slower machine installation of the mulch should probably
also be considered.  At present, given the slick, non embossed surfaces
of the VIF mulch, machine application of the mulch in the field is
typically less than 3 miles per hour.  Manufacturer research programs
are continuing to focus on ways to resolve many of these problems.  In
addition to higher costs per acre, problems of VIF availability also
must be considered.  VIF mulches are currently manufactured near
exclusively in Europe and Israel by various producers…As a result of
overseas production, users in the United States will likely incur
lengthy delays (upwards of 2-3 months) for delivery of ordered products.
 There is also concern that although the raw materials needed to produce
VIF mulches are readily available in the US, current European production
capacity is not high enough to meet US demands if it were to
substantially increase in the future.  To resolve future demand, if it
materializes, production facilities in the US would have to be
established to insure timely supply.”

MBTOC Question

2. MBTOC has assumed there is an error in the 2008 BUNNl which shows
strip treatments instead of broadacre treatments for MBl chloropicrin 
formulations in the SE. Is this correct?

US Response

MBTOC is correct.  Fumigation treatment for strawberry runners in the
southeast is broadacre rather than strip.  USG apologizes for the error.

US SWEET POTATO TRANSPLANTS  TC "US SWEET POTATO TRANSPLANTS" \f C \l
"2"  

MBTOC Question

1.  The nomination is based on the lack of Telone being available for
use due to township caps. MBTOC seeks clarification on the proportion of
the nomination that is known to consistently be unavailable due to
township caps and what portion is a contingency in case amounts are used
more quickly than in previous years.  The Party has identified 1,3-D as
a technically and economically feasible alternative, which is in fact
preferable to MeBr for this industry.

US Response

This request represents the USG’s best estimate of the amount of
methyl bromide that will be needed by this sector.  As MBTOC points out,
1,3-D is the preferred fumigant for this use.  In the past township caps
in the townships where sweet potato slips are grown have been met and
1,3-D has not been available for this purpose.  As MBTOC is aware, this
is a fluid rather than static situation and the availability of 1,3-D is
contingent on other fumigation decisions made in these townships.  Given
the preference of producers of sweet potato slips for 1,3-D, if it is
available, any methyl bromide will go unused if possible.  In Merced
County California, there is an especially high concentration of crops
that require fumigation, particularly almonds, nectarines, peaches, and
grapes.  All of which makes predicting the availability of 1,3-D for
sweet potato transplant production very difficult.

US TOMATOES – FIELD  TC "US TOMATOES – FIELD" \f C \l "2"  

MBTOC Question

1. In tomato trials, 1,3-Dlpic 65:35 with and without VlF, 1,3-Dlpic
65/35 & metolachlor & trifloxysulfuron and MNaI chloropicrin  provided
similar yields as MBIpic 67:33 in 3 trials over the spring and fall of
2003 and spring of 2004. (Santos, et al, Crop Protection, 2006). Are the
herbicides trialled all registered on pepper? Are there plant back or
market window effects?

US Response

USG assumes that MBTOC is referring to the following citation:
“Comparing methyl bromide alternatives for soilborne disease, nematode
and weed management in fresh market tomato”, Santos et al., Crop
Protection 25: 690-695.The registration status of the herbicides
mentioned in the question above is as follows: both s-metolachlor (Dual
Magnum™), trifloxysulfuron sodium (Envoke™ ) and metam-sodium are
registered in the US on transplanted tomatoes.

However, USG is not clear on how MBTOC arrived at the conclusion that
all the treatments listed in its question provided similar yields to
MeBr: chloropicrin.  To quote what is arguably the most practically
relevant result of the study, “During two of the [three] seasons,
1,3-D + chloropicrin with VIF, sodium azide at 85 kg/ha, and propylene
oxide were consistently equal to methyl bromide + chloropicrin .”  Of
these materials, only 1, 3 D + chloropicrin is currently registered for
use in US tomatoes.  In a similar study published in 2006, Gilreath et
al. (in Crop Protection Vol. 25: 79-82) state that “…the combination
of C-35+ chloropicrin +pebulate+trifluralin can provide an effective
wide-spectrum fumigant program to replace methyl bromide + chloropicrin
applications in polyethylene-mulched tomato.”

However, pebulate is not registered for use on any crop in the US.
Trifluralin is registered, but since it is the combination with pebulate
and 1,3 D+ chloropicrin  that showed promise, trifluralin alone is not a
feasible substitute for MB+ chloropicrin .  Also, in both Santos et al.
(2006) and Gilreath et al. (2006), Phytophthora pathogens, major targets
of MeBr use, were not included as test subjects.  Thus it remains
unclear whether even the combinations of unregistered and registered
alternatives that were tested will be as effective as MeBr for control
of this pathogen. 

As regards the results cited for 1,3 D + VIF, the following important
caveats must be resolved before this option can feasibly replace MeBr
use in tomatoes (or any other open-field vegetable crop) across the
entire US: (1) the effect on Phytophthora pathogens needs to be studied;
(2) results need to be validated on commercial scale fields (as was done
by Gilreath et al. 2006, for other MeBr alternatives discussed above);
(3) 1,3-D + chloropicrin  + VIF needs to be evaluated in areas with
different climatology than the subtropical region where Gilreath et al.
(2006) conducted their work.

To address the other questions included in this item: there are indeed
plant-back restrictions with all the herbicides mentioned. For example,
in cucurbits, metolachlor has a 12 month plantback restriction, and
trifloxysulfuron has an 18 month plantback restriction. S-Metolachlor
has a preharvest interval of 90 days, which can interfere with harvest
timing to coincide with optimum market windows. 

VIF and metallised films remain under study for commercial feasibility
in US vegetable crop production. Metallised films are now in tentative
use by vegetable growers in Florida, but use has not yet become
widespread. Promising results have been observed in recent studies of
new preparations of VIF in Florida (e.g., Gilreath et al. 2005). 
However, VIF cannot be used with MeBr in California due to worker safety
concerns (VIF use is banned by state law based on a performance
standard).  Furthermore, the economic feasibility of VIF use in other
parts of the US remains unclear.

Costs associated with VIF are discussed by Noling (2002, revised 2005),
and this description is summarized in the USG response to a similar
MBTOC question for US strawberry nurseries. The relevant text is
reproduced below.

According to Noling (2002, revised 2005): “Historically VIF mulches
have suffered from high cost and from other problems involving tensile
strength.  They are typically slow to properly install and are subject
to tearing (zippering) during machine application in the field.  More
efficient containment of gases below the mulch also suggests that
plantings may have to be delayed to insure soil residues have dissipated
and plant injury will not occur.  The average price for LDPE mulch is
approximately $250-300/acre, while HDPE mulch is $400 /acre and VIF
mulch in the range of $400 to 600/acre.  The higher price for VIF is
partially reflective of transportation costs from European
manufacturers.  Compared to LDPE, reduced methyl bromide and
chloropicrin application rates (as much as 50%) and use of the VIF mulch
will result in lower fumigant costs which may be completely offsetting
given the higher pricing for methyl bromide now in reduced supply.”

“In addition to the increased direct cost of VIF, increased labor
costs for slower machine installation of the mulch should probably also
be considered.  At present, given the slick, non embossed surfaces of
VIF, machine application of the VIF in the field is typically less than
3 miles per hour.  Manufacturer research programs are continuing to
focus on ways to resolve many of these problems…  In addition to
higher costs per acre, problems of VIF availability also must be
considered.  VIF is currently manufactured near exclusively in Europe
and Israel by various producers. As a result of overseas production,
users in the United States will likely incur lengthy delays (upwards of
2-3 months) for delivery of ordered products.  There is also concern
that although the raw materials needed to produce VIF are readily
available in the US, current European production capacity is not high
enough to meet US demand if it were to substantially increase in the
future.  To resolve future demand, if it materializes, production
facilities in the US would have to be established to insure timely
supply.”

MBTOC Question

2. Are grafted plants being tested for disease infested areas.  If so,
please provide evidence that they are not suitable as an alternative to
MeBr.  If not, why?

US Response

The following table summarizes the current state of research on grafting
in US vegetable production, to the extent that USG has been able to
ascertain.

Table XII.1: Key Pests for Tomatoes and Grafting Research Status  TC
"Table XII.1: Key Pests for Tomatoes and Grafting Research Status" \f F
\l "1"   

Key Pest	Grafting Research Status

Nutsedge, Cyperus spp.	No research planned in the US due to lack of
resistant rootstock.

Phytophthora capsici	No research planned in the US due to lack of
resistant rootstock.

Fusarium oxysporum     	Research planned and underway in the US.

Nematodes,  Meloidogyne incognita	No research planned in the US due to
lack of resistant rootstock.



Several US seed companies, some in collaboration with the US Department
of Agriculture, are conducting tests of the commercial feasibility of
using grafted, disease-resistant cucurbits, tomatoes and peppers in
greenhouse and open field production (Core, 2005, Kubota, personal
communication, 2006). Some of these trials are being conducted in the
southeastern US (Core, 2005). However, these tests are highly
preliminary and there is as yet no assurance that such grafted plants
are commercially acceptable in pest management and economic terms.
Grafted vegetables are commercially used mostly in greenhouse tomato
production in the US. Indeed, more than 90% of grafted vegetable
seedlings are tomatoes in North America (Kubota, personal communication,
2006). Virtually all these grafted tomatoes are used in greenhouse
production.

It is not clear whether grafting is being evaluated for resistance to
Phytophthora spp. pathogens, a critical disease pest of cucurbits
currently targeted by MeBr use in the US. USG is unaware of any research
conducted on the suitability of grafting as a control option against
this pathogen.

Table XII.2: Resistance to Important Plant Pathogens and Pests in North
Carolina and the Mediterranean.  TC "Table XII.2: Resistance to
Important Plant Pathogens and Pests in North Carolina and the
Mediterranean." \f F \l "1"  

Pathogen or Pest	Resistant Line Reported by North Carolina (F. Louws)
Resistant Lines Reported in Mediterranean (M. Besri)

Verticillium race 1	Yes	Yes 

Verticillium race 2	No	Not listed

Ralstonia solanacearum	Yes	Yes

Fusarium solani race 1& 2	Yes	Yes

Fusarium solani race 3 	Yes	Not listed

Sclerotium rolfsii	No	Not listed

Root knot nematodes Meloidogyne spp.	Yes	Yes

Phytophthora capsici	No	Not listed

Pseudomonas corrugate	No	Yes

Pythium root rot 	No	Not listed

Source:  Louws et al 2002 and Besri, M.  2005.

Table XII.3: Resistance of Tomato Rootstocks to the Most Common Soil
Borne Pathogens  TC "Table XII.3: Resistance of Tomato Rootstocks to the
Most Common Soil Borne Pathogens" \f F \l "1"   

Rootstock	Pathogens

	K	V (1)	F (1, 2)	N	Fr

L. esculentum x L. hirsutum	+	+	+	+	+

L. esculentum	+	+	+	+	+

Source:  Besri, M.  2005.

K: Pyrenochaeta lycopersici, V (1): Verticillium dahliae (race 1), F
(1,2): F. oxysporum f.sp. lycopersici (races 1 and 2), N: Meloidogyne
spp, Fr: F.oxysporum f.sp. radicis lycopersici  Resistance to
Pseudomonas (Ralstonia) solanacearum is provided by S .torvum and S.
aethiopicum.  In addition, these two rootstocks are resistant to
Meloidogyne spp.  

In addition, USG is not aware of any research demonstrating that
grafting offers protection against weeds (such as nutsedge). A
significant portion of the US nomination for MeBr is for the control of
weeds (in the southeast) and nematodes (California), as well as
soilborne diseases.  In the protected environment of the greenhouse,
grafting may offer sufficient disease protection, but in the open field
situation which characterizes most of the vegetable production in the
US, grafting does not offer protection against the suite of pests faced
by growers.  Therefore, even if resistance to Phytophthora pathogens is
identified, several years’ tests of how grafting can be effectively
integrated with other pest management strategies will be necessary
before it can find commercial acceptability in open-field vegetable
production in the US. At present there are no grafted rootstocks that
can deal with the entire US pest complex.

In addition, cost remains a significant factor inhibiting adoption of
grafted plants in open-field vegetable production.  Grafting is a very
labor-intensive activity, consequently the cost of grafted plants is
highly dependent on labor costs.  In countries as geographically
separated as Morocco and Mexico, the cost of a grafted vegetable plant
is approximately $0.10 each.  In the United States, and countries with
similar labor costs, such as Canada, however, higher labor costs push
the cost of a grafted stem to more than four times the cost.

According to Dr. Chieri Kubota (personal communication), a grafting
expert with the University of Arizona, a grafted plug of two stems, that
is ready for field use, costs $0.90,  The presence of two stems means
that the plant will have twice the yield of a normal, one stemmed,
plant.  The cost increase, however is still significant.  The normal
cost of a non-grafted plug, ready for planting in the field, is
approximately $0.20.  The grafted plant, then, costs 125% more than a
conventional plant per stem.

MBTOC Question

Please refer particularly to general questions above.

US Response

Please see detailed responses in the separate section addressing the
general questions.

US TURF / SOD RECONSIDERATION  TC "US TURF / SOD RECONSIDERATION" \f C
\l "2"  

MBTOC Comment 

MBTOC does not recommend MB for use in USA sod production. Effective
alternatives have been found for 99% of all turf production and the
party has significantly reduced the nomination requests for this use
from 2007 t in 2005 to 78 t in 2007.  Alternatives such as dazomet
provide equal control of weedy grasses and slightly better control of
broadleaf weeds when compared to MB (Unruh et al., 2002).  1,3-D and
1,3-D + Chloropicrin can be used if nematodes are the primary pest, or
possibly in conjunction with dazomet or metam-sodium. 
Metam-Sodium/Chloropicrin provided comparable control (vs. MB) of weedy
grasses and nutsedge (eg., Unruh and Brecke, 2001; Unruh et al., 2002)

US Response

The US requests that MBTOC reconsider the CUN for the nomination of the
sod production sector.  The milestones achieved in this sector include
the reduction of total tonnage requested since 2002, a significant
reduction in rates, and a vigilant ongoing research programs.  Taken
together, these milestones indicate a significant achievement in
reducing the US sod producing industry’s reliance on MeBr combined
with the strong, demonstrated commitment of those involved with this
sector to continued research onto alternatives, argues strongly that
critical use methyl bromide should be approved for this sector to allow
time for alternatives that are both technically and economically
feasible for the very small remaining specialty uses to be developed.

Since 2002 the US nomination has reduced the total amount of methyl
bromide for sod production from 352,194 kg to 52,199 kg.  This 85%
reduction in total tonnage requested for this sector came from efforts
undertaken in two areas.  First, there was an overall significant
reduction in use made by the elimination of the golf course industry
from this sector, and second, significant reductions in rate structure
were achieved which resulted in application rates being decreased from
>450 kg ha-1 to 300 kg ha-1.  Overall reductions in this sector have
been dramatic and eclipse those of many other sectors. 

The US has shown in the CUN that only 1% of the turf industry is unable
to switch to the alternatives.  This one percent is primarily the
certified sod production industry.  This part of the industry grows a
sod crop that is highly specialized and is regulated to exclude the
presence of off-type turfgrasses as well as any weeds.  There is no
threshold for weeds, especially any of the nutsedge species. As is the
case in the ornamental flower industry the stands of certified sod must
be a monoculture of a particular type of turfgrass or penalties are
plausible.  As a result of these restrictions certified sod commands a
premium price 

While one percent of the turfgrass industry may seem very small, in this
case, this one percent has a disproportionately large part of the
economic share of the industry.  The cost of certified sod is 75% higher
than standard sod, providing a significant source of profits for the
sector.  In addition to the monetary returns, the purchasers of
certified sod rely on this product to build brand equity with their
customers which also aids their non certified sod production.

The information presented above serves to demonstrate, on an applied
level, the importance of maintaining a monoculture in certified sod
production.  This means following best management and cultural
maintenance practices.  However, these are not enough and often the use
of MeBr fumigant is needed.  Current research projects focusing on
alternative fumigants “…confirm that no EPA-registered fumigant
alternatives to MeBr, applied alone or in combination for preplant turf
soil fumigation, exists.” (Unruh et al., 2002)  In fact, research
conducted to evaluate the soil applied herbicide dazomet, alone or in
combination, demonstrated inconsistencies in weed control at the state
level;  while “dazomet (and combination) treatments provided good
control of weedy grasses at the western Florida site, control was not
consistent at the southern Florida site.” (Unruh et al., 2001)  These
types of inconsistencies and lack of control are not acceptable for the
certified sod industry as this is a perennial crop that must begin with
a weed free soil.

There is active and wide-ranging research currently underway to find
alternatives.  At Auburn University in Alabama researchers are
evaluating dithiocarbamate, but have encountered development of
resistant weeds.  A more promising line involves sodium azide in
combination with herbicides (particularly EPTC, chemical name: S-ethyl
dipropylthiocarbamate).  However neither sodium nor potassium azides are
currently registered for pesticide use in the US.  There is an
additional problem that continued use of EPTC results in enhanced
biodegradation of this chemical and reduced efficacy.  Some work is also
ongoing using 1,3-D at rates higher than those currently on the label. 
Should this research prove fruitful, it would still require a label
change in order to be used for other than research.  (personal
communication, Robert H. Walker, PhD, Auburn University).  

At the University of Florida the research includes blending dazomet with
the soil of putting greens, and testing high rates of 1,3-D.  The
research team is waiting to hear on the funding of several grant
proposals including one evaluating sheet steaming, dazomet, and “hot
gas”.  (personal communication, J. Bryan Unruh, PhD, University of
Florida)

The milestones that have been achieved to date have drastically reduced
the amount of MeBr requested and used by this sector.  The importance of
MeBr to a very small part of this sector is disproportionate to the
overall economic picture.   As indicated by the current research, the
lack of efficacy for soil fumigants and fumigant combinations, along
with the inconsistent efficacy of dazomet and dazomet combinations
demonstrate that at this time there are no viable alternatives to MeBr
for certified sod production.  

In 2003 the TEAP found that there were no feasible alternatives for
golfcourses.  Please see Appendix B for more detail.

POST HARVEST QUESTIONS  TC "POST HARVEST QUESTIONS" \f C \l "1"  

US COUNTRY HAM  TC "US COUNTRY HAM" \f C \l "2"  

MBTOC General Comment

We acknowledge that these applicants do not currently have a registered
effective alternative, but we also have concerns about the amount of MB
that will be used. Our questions concern two factors that contribute to
an appropriate minimal use of methyl bromide: dosage rate and frequency
of fumigation. Our questions may result from our inability to understand
the new BUNNI because we could not determine if USG had reduced the
amount requested by some applicants to account for a standard dosage
rate that the USG will allow. And, if so, we could not determine the
standard dosage rate that the USG intended to use.

US Response

The standard dosage rate intended by the USG is 18-20 kg/1000 m3 for
this sector.  The applicants requested these rates to control mites, ham
skippers and ham borers in their cured pork products.  These pests bore
deeply into the meat, so the fumigant must penetrate to reach the pests.
 Pests flare up very quickly.  The slight variation in the dosage rate
occurs because a critical concentration by time (CT) is necessary in
order to kill the pests. The CT is determined by the species of pests
present, temperature, and humidity.  Typically if there is a flare up of
pests just prior to a shipment of hams then the producer will try to
fumigate in a shorter time frame to meet his market demands, and need
the slightly higher rate.  In addition, methyl bromide needs to
penetrate the ham, a relatively dense structure, in order to kill the
pests that have penetrated the meat.  Cured meat has fat which also
adsorbs methyl bromide.   

The hams in the ‘summer’ or ‘aging’ room are the ones that
typically get infested with mites, skippers, and borers.  These rooms
are necessary for the proper curing of the meat products.  These rooms
are maintained at 80-90° F and 55% relative humidity for 90 to 120
days.  These conditions are necessary for the meat to develop the full
compliment of flavors necessary.  Unfortunately, these conditions are
also ideal for the pests.  

Ham processors usually apply methyl bromide to a cured meat product only
once, to control the mites, skippers and borers.  Occasionally a meat
product will be fumigated a second time, if it is aged for an extended
period of time.  However, since processing of these meat products is
year round, we don’t think that the number of fumigations will
decrease until more is known about the pests and viable alternatives are
identified.  The frequency of fumigations is also discussed in below, in
response to a MBTOC question subtitled ‘Frequency of fumigation’.

MBTOC Question

1. Also, although the executive summary indicates this application is
for 2008, Tables 6.1 -6.4 indicate the request is for 2007. Please
confirm date of this request.

US Response

The tables should be for 2008. Please see below.

Table 6.1: Methyl Bromide Consumption for the Past 5 Years and the
Amount Required in the Year(s) Nominated (American Association of Meat
Processors  TC "Table 6.1: Methyl Bromide Consumption for the Past 5
Years and the Amount Required in the Year(s) Nominated (American
Association of Meat Processors" \f F \l "1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	Information not provided	168,283

Volume Treated 1000 m³	Information not provided	7,004

Formulation of MB	Information not provided

	Dosage Rate (kg/1000 m³)	Information not provided	24.03

Actual (A) or Estimate (E)	Information not provided

	1 American Association of Meat Processors did not provide historical
data.  

Updated Table 6.2: Methyl Bromide Consumption for the Past 5 Years and
the Amount Required in the Year(s) Nominated (National Country Ham
Association  TC "Updated Table 6.2: Methyl Bromide Consumption for the
Past 5 Years and the Amount Required in the Year(s) Nominated (National
Country Ham Association" \f F \l "1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	749	694	802	791	791	791	1,242

Volume Treated 1000 m³	38	33	45	43	43	43	67

Formulation of MB	Information not provided

Dosage Rate (kg/1000 m³)	19.68	21.03	18.01	18.60	18.60	18.60	18.60

Actual (A) or Estimate (E)	Information not provided



Table 6.3: Methyl Bromide Consumption for the Past 5 Years and the
Amount Required in the Year(s) Nominated (Nahunta Pork Center  TC "Table
6.3: Methyl Bromide Consumption for the Past 5 Years and the Amount
Required in the Year(s) Nominated (Nahunta Pork Center" \f F \l "1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	363	109	218	109	109	109	91

Volume Treated 1000 m³	16	5	9	5	5	5	4

Formulation of MB	Information not provided

Dosage Rate (kg/1000 m³)	23.3	23.3	23.3	23.3	23.3	23.3	23.3

Actual (A) or Estimate (E)	Actual



Updated Table 6.4: Methyl Bromide Consumption for the Past 5 Years and
the Amount Required in the Year(s) Nominated (Gwaltney of Smithfield  TC
"Updated Table 6.4: Methyl Bromide Consumption for the Past 5 Years and
the Amount Required in the Year(s) Nominated (Gwaltney of Smithfield" \f
F \l "1"  

	Historical Use1	Requested Use

For each year specify: 	1999	2000	2001	2002	2003	2004	2008

Amount of MB (kg)	363	1,361	907	2,177	1,361	3,266	1,905

Volume Treated 1000 m³	21	21	21	177	177	177	177

Formulation of MB





	Information not provided

Dosage Rate (kg/1000 m³)	17.09	64.07	42.72	12.32	7.70	18.48	10.78

Actual (A) or Estimate (E)





	Information not provided



Dosage Rate  TC "Dosage Rate" \f C \l "3"  

MBTOC Question

2. Please clarify the dosage rate that will be used for the treatment of
country ham by the four applicants. If the four applicants intend to use
different dosage rates please supply information to justify a technical
need for the higher rates.

US Response

The standard dosage rate intended by the USG is 16-24 kg/1000 m3 for
this sector, and all of the ham nominations fall within these standard
dosages.  The applicants requested these rates to control mites, ham
skippers and ham borers in their cured pork products.  The slight
variation in dosage rates is due to the location of the pest being
targeted by the fumigation.  When the pests infest the pork products
they will burrow deep into the meat.  If these pests have begun to
burrow into the meat a higher rate is required so that the fumigant can
penetrate the meat to effectively control the embedded pests.  

The industry is trying to hire researchers to investigate how to detect
the key pests early (especially the mites), and to treat these pests
before they become a major problem.  However, there are few scientists
who are willing to work on the mites, as they very difficult to confine
in laboratory conditions. The control of mites is critical to get a
better handle of this problem.   Consequently, no work on mites has yet
been started, but the industry is still hopeful that studies will be
conducted soon.  

MBTOC Question

3. Tables 6.1 to 6.4 and the BUNNI indicate intended dosage rates that
vary between 10.78 and 73.10 kg/1000M3. We had thought the 73.10 was a
typo except it is also repeated in the BUNNI. If it is a typo please let
us know the actual number. If it is the actual intended dosage rate,
please provide a technical justification for this use rate. Lack of
gastight fumigation chambers or inadequately controlled fumigation is
not usually considered adequate technical justification.

US Response

Please see answer to question above.  MBTOC is correct in that this is a
typo in the volume treated.  The previous volume was 17 which should
have been 67.  Therefore, the dosage rate of 73.10 should be 18.60.  The
table above has been updated to reflect these changes.

The USG is not using gastightness of the chambers as a technical
justification, but rather the susceptibility and location of the pests,
the maintenance of Concentration x Time to kill the pests, and time
frame required by the producers to get their product shipped when
necessary.  

Frequency of Fumigation  TC "Frequency of Fumigation" \f C \l "3"  

MBTOC Question

4. We understand that two of the four applicants (Gwaltney and Nahunta)
have improved gas tightness to reduce frequency of fumigation. These
questions pertain to the other two applicants.  Has the BUNNI reduced
applicants request to take into consideration planned improvements in
gastightness that will be achieved by 2008 so that frequency of
fumigation will be reduced to <3 per year.

US Response

The frequency of fumigation will probably never reach less than <3 per
year.  The hams in the summer or aging room are the ones that get
infested with mites, skippers, and borers.  These rooms are necessary
for the proper curing of the meat products.  These rooms are maintained
at 80-90° F and 55% relative humidity for 90 to 120 days.  These
conditions are necessary for the meat to develop the full compliment of
flavors necessary.  Unfortunately, these conditions are also ideal for
the pests.  

The processors usually apply methyl bromide to a cured meat product only
once, to control the mites, skippers and borers.  Occasionally a meat
product will be fumigated a second time, if it is aged for an extended
period of time.  However, since processing of these meat products is
year round, we don’t think that the number of fumigations will
decrease until more is known about the pests and viable alternatives are
identified.   

MBTOC Question

5. USG reports that gastightness is poor in some of these facilities and
this is further substantiated in the CUN when it indicates that
frequency of fumigation can vary between 2-8 times per year although
usually 3-5 time a year. For two years now MBTOC has asked that
facilities requiring methyl bromide treatment meet standards of 'good'
gastightness (as defined in the Handbook). Using MB in facilities of
poor gastightness increases MB use and is not in keeping with Decision
IX/6. The CUN reports that State university researchers will conduct a
survey of country ham producers and determine gastightness. This is
excellent, but MBTOC needs to know that country ham facilities will then
be improved to 'good' gastightness by 2008 or if other means will be
employed to reduce frequency of fumigation to <3 per year or some other
technically justified frequency.

US Response

As MBTOC notes, gastightness is one area that is being surveyed by
researchers.  The goal is to improve gastightness in all the older
facilities.  However, advances in gastightness will only help retain
gas, and may not necessarily affect pest pressure.  The researchers in
this area also want to study the biology of the pests in relation to
gastightness in order to enhance pest control as well  For instance, one
of the new, gastight, facilities was infested with mites after 9 months
of operation.  After all the hams were sold, the summer room was
scrubbed and sanitized.  Yet, within one month of moving new hams into
the room for curing, mites began infesting the meat, resulting in methyl
bromide fumigation.  While the gastightness improves the fumigation and
reduces methyl bromide emissions, until more biological information is
known about the pests, it will probably not decrease the number of times
fumigation is needed.  

The frequency of fumigation will probably never reach less than <3 per
year.  The hams in the summer or aging room are the ones that get
infested with mites, skippers, and borers.  These rooms are necessary
for the proper curing of the meat products.  These rooms are maintained
at 80-90° F and 55% relative humidity for 90 to 120 days.  These
conditions are necessary for the meat to develop the full compliment of
flavors necessary.  Unfortunately, these conditions are also ideal for
the pests.  

The processors usually apply methyl bromide to a cured meat product only
once, to control the mites, skippers and borers.  Occasionally a meat
product will be fumigated a second time, if it is aged for an extended
period of time.  However, since processing of these meat products is
year round, USG does not think that the number of fumigations will
decrease until more is known about the pests.  

Historical Use  TC "Historical Use" \f C \l "3"  

MBTOC Question

6. Since use of MB in 2005 will be controlled, please report actual use
of MB by members of American Meat Producers in 2005.

US Response

The US regulatory framework for MB critical use exemptions is designed
to track the sales of critical use methyl bromide to sectors of approved
critical users.  For the 2005 control period, the dry cured pork
products sector was grouped in the larger commodities sector.  Thus,
2005 sales of critical use MB to the dry cured pork products sector
cannot be segregated from sales to other commodity sectors, such as
dried fruit, walnuts, and beans.  However, for the 2006 calendar year
the regulation was slightly changed and we expect to be able to account
for sales of critical use MB to the dry cured pork products sector
separately.  Please note that we do not track sales of critical use MB
to individual end-users through the regulatory framework for MB critical
uses.  We also do not track actual use of methyl bromide by sector or by
individual end-user.

US NPMA FOOD PROCESSING STRUCTURES  TC "US NPMA FOOD PROCESSING
STRUCTURES" \f C \l "2"  

Questions Pertaining to All Sectors Included in this CUN  TC "Questions
Pertaining to All Sectors Included in this CUN" \f C \l "3"  

MBTOC Question

1. Please update the registration status of sulfuryl fluoride in
California for the types of food processing facilities and commodities
included in this CUN.

US Response

The registration status of sulfuryl fluoride has not undergone any
further changes in California.  

On January 23, 2004, the U. S. EPA registered sulfuryl fluoride as a
post-harvest fumigant for cereal grains, dried fruit and tree nuts. 
Sulfuryl fluoride was registered for these uses in California in May,
2005.  Sulfuryl fluoride received a U. S. registration July 15th, 2005
for these food processing facilities.  All states, except California,
have also registered these use sites.  

The industry will need time to incorporate this new alternative into
their management plan.  In addition, label language only allows for
“incidental fumigation” for processed foods.  Subsequently only
minimal amounts of ingredients and products should be left in a facility
during sulfuryl fluoride fumigations.  Since many of these buildings
have no way to separate products and ingredients from the equipment,
this label restriction may be problematic.  

Trade Restrictions  TC "Trade Restrictions" \f C \l "3"  

MBTOC Question

2. If our understanding is correct, the CUN indicates the applicant is
concerned that if their structure is fumigated with sulfuryl fluoride,
then exports of their commodities may not be accepted by an importing
country which does not have SF registered for structures. However many
countries have registered SF for structural use. Therefore MBTOC does
not understand if this problem is a major factor or not. Please submit
the list of countries that the applicants export to which would not
accept commodities coming from a structure that had been treated with
SF, and indicate the percentage of the export volume this would pertain
to. It is also possible that MBTOC has misunderstood this issue and its
impact on the use of alternatives to MB. If so, please correct our
misunderstanding.

US Response

The Codex Alimentarius Commission was created in 1963 by the Food and
Agriculture Organization (FAO) and World Health Organization (WHO) to
develop food standards, guidelines and related texts such as codes of
practice under the Joint FAO/WHO Food Standards Programme.  This
commission has encouraged food-related scientific and technological
research as well as lifting the world community’s awareness of food
safety and related. The Codex Alimentarius Commission has become the
single most important international reference point for developments
associated with food standards.  The purposes of this group are
protecting health of the consumers and ensuring fair trade practices in
the food trade, and promoting coordination of all food standards work
undertaken by international governmental and non-governmental
organizations (  HYPERLINK
"http://www.fao.org/docrep/008/y7867e/y7867e02.htm#bm02" 
http://www.fao.org/docrep/008/y7867e/y7867e02.htm#bm02 ).  

Sulfuryl fluoride is currently undergoing review by the Codex
Alimentarius Commission to establish maximum residue levels (MRL) from
the use of quarantine fumigations and by the Committee for the Agreement
on the Application of Sanitary and Phytosanitary Measures to set
standards for its use.  If approved by Codex MRLs would be established
for foods such as: dried fruits and tree nuts, bran, cereal grains, and
flour (e.g. maize, rye, and wheat).  However, MRLs need to be
established by Codex on all the products imported.  If residues of
fluoride should be found on products for which there is no tolerance,
the goods could be rejected, and trade disrupted. USG also notes here
that even after an MRL is established by the Codex, individual countries
may have to establish their own specific MRL (depending on their own
internal policies and laws). This means that global acceptance of
sulfuryl fluoride in terms of MRLs will take time beyond that required
for a Codex decision. This time needs to be considered for when
considering the practical availability of this methyl bromide
alternative.

Cheese Stores  TC "Cheese Stores" \f C \l "3"  

MBTOC Question

3. Provide research plan for control of pests in cheese stores.

Although USG indicates transition plans for other food processing uses,
there is no transition or research plan for cheese storages. While we
acknowledge there is currently no alternative registered for this use,
there is also no research program to find alternatives or minimize use
in this sector as required in Decision IX/6. 

Please describe the research plan intended to reduce the need for methyl
bromide in this sector.

US Response

Although cheese production is a major industry in the US, the fumigation
of cheese processing facilities is actually small.  A methyl bromide
fumigation is only done if USDA inspectors request it.  Consequently, it
is not always the same facility nor the same location.  While there are
usually a few fumigations done each year in cheese processing plants, it
is difficult to coordinate a research plan.  

The pests in cheese (mites, skippers, and borers) are the same pests
that infest the processed meats.  So the research done on country hams
will be applicable to cheese facilities.  The primary difference between
the two production practices is that ham is cured at 80-90° F and 55%
relative humidity; whereas cheese is cured at 35° F from milk that has
been pasteurized.  The conditions under which cheese is processed reduce
the pest pressure.

MBTOC Question

4. Provide volume of cheese store to be fumiqated.

Provide volume of each cheese store to be fumigated, with a gastightness
evaluation (as described in the Handbook for Critical Use Nominations).
How will methyl bromide use be minimized through sealing and other good
fumigation practices?

US Response

As mentioned in the previous answer, there is no specific cheese
facility that is being fumigated, therefore to specify a volume is very
difficult.  The range of volumes can be from 5,000 cubic feet to 250,000
cubic feet.  However, since cheese is cured at fairly low temperatures,
to keep those temperatures, and maintain sanitation, the facilities are
very gastight.  

As with any facility undergoing fumigation, the building is examined and
sealed according to the US methyl bromide label and fumigation guide.  

MBTOC Question

5. Describe MB use minimizing procedures

Is the methyl bromide only used when cheese is present in the cheese
storage? When the cheese is removed from the storage room, other
sanitizing or fumigation agents can be used.

US Response

Fumigations occur when an USDA inspector deems that the product is
infested and must be fumigated. Therefore the cheese is present in the
storage and both are fumigated.  However, the cheese industry is
diligent about maintaining micro-sanitation and employs other sanitizing
methods to clean the storages when the cheese is not there.  The
facilities are often emptied and sanitized between batches.  In
addition, cheese is produced under very cool conditions which reduces
insect and mite pest pressure, but does not always eliminate pests.  

Herb and Spice Facilities and Commodities  TC "Herb and Spice Facilities
and Commodities" \f C \l "3"  

MBTOC Question

6. QPS Use

Page 16 of the CUN says that small amounts of herbs and spices included
in the application were for quarantine and pre-shipment uses. Products
treated as for quarantine or pre-shipment purposes are not included in
the phase out of methyl bromide and can not be included in critical use
nomination. If we have understood the CUN correctly, please indicate the
amount of methyl bromide that was intended for this purpose, recalculate
and send us the revised request for this sector, minus the QPS use.

US Response

The 2008 nomination for methyl bromide is for the domestic uses of dried
herbs and spices at blending facilities.  These facilities produce
packages (i.e. pizza mixes, chili mixes, etc.) that are then added to
pre-packaged goods.  These facilities are similar to grain mills in that
there are silos, mixing areas, packaging areas, etc.  Infestation in
herb and spice blending facilities is not localized to machinery that
can be spot heat treated.  These facilities utilize methyl bromide to
target pests present in inaccessible areas of the structure, not the
ingredients or finished products that may be stored on-site.  

The information regarding the export of dried herbs and spices was only
intended for comparison information, and was not part of the methyl
bromide nominated in this CUN.  Therefore, the nominated amount of
methyl bromide for this use remains: 4,046 kg for 203,000 m3, at a rate
of 20kg/1000 m3.  

MBTOC Question

7. Commodity Use

Alternatives to methyl bromide for herbs and spices are in widespread
commercial use in all regions of the United States. These include
ethylene oxide, irradiation and steam treatment. These treatments
control pests and microbial pathogens. Some spice packers have in-house
facilities to conduct these treatments and some spice packers use
contract treatment facilities. Please indicate the amount of methyl
bromide intended for herb and spice commodity included in this CUN.

US Response

The 2008 nomination for methyl bromide is for the domestic uses of dried
herbs and spices at blending facilities.  These facilities produce
packages (i.e. pizza mixes, chili mixes, etc.) that are then added to
pre-packaged goods.  These facilities are similar to grain mills in that
there are silos, mixing areas, packaging areas, etc.  Infestation in
herb and spice blending facilities is not localized to machinery that
can be spot heat treated.  These facilities utilize methyl bromide to
target pests present in inaccessible areas of the structure, not the
ingredients or finished products that may be stored on-site.  The
industry does do a draw-down before fumigating; however, there will be
small amounts of dried herbs and spices within the machinery that would
be exposed.  Sulfuryl fluoride was registered for this use a year ago,
but as these are very small operations, it will take some
experimentation to determine how best to use this alternative and to
determine if it is economically feasible.  

This nomination is only for a few facilities that are quite small and
target the domestic market.  Because these are very small operations,
they have little profit to invest in the capital costs required to
utilize the alternatives that the larger manufacturers have been able to
employ.  Therefore, the nominated amount of methyl bromide for this use
is:  4,046 kg for 203,000 m3, at a rate of 20kg/1000 m3.  

US COMMODITIES  TC "US COMMODITIES" \f C \l "2"  

MBTOC Question

1. General Questions for this CUN

Clarify the requested amount

The total amount requested for all sectors is 67,678 kg but the amount
requested in the CUN is 67,699 kg. Is the difference (21 kg) the amount
USG intends to designate for research or is there a discrepancy in the
amount of methyl bromide requested?

US Response

The nominated amount for the commodity sector is 67,679 kg, with 20 kg
for research for a total of 67,699 kg.  

MBTOC Question

2. Emissions Control and Recapture

Provide information on the gas tightness of the chambers used to
fumigate commodities with methyl bromide. Have any of the fumigation
chambers been fitted with methyl bromide recapture technologies?

US Response

The USG is confident that the majority of these chambers used to
fumigate commodities are very gas-tight. These fumigations are conducted
in California, and the state has many restrictions already in place.  In
addition, the state of California has County Agriculture Commissioners
that monitor these situations.  To reduce buffer zones during
fumigations, the chambers must be very gas-tight, according to
California regulations.

The USG is aware that many of the quarantine chambers have
capture-destruction technologies.  However, it is unknown at this time
how many, if any of the commodity chambers are also fitted with these
new technologies.  

MBTOC Question

3. Methyl Bromide Fumigation Outside of Autumn Harvest Time

TABLE B.2 (Page 10 CUN) (Fumigation Schedule MB) indicates year round
fumigation of commodities, although increased fumigation during autumn
months. If fast treatments are needed only for the holiday target market
window (October to January), indicate what amount of each commodity is
fumigated outside these months. Does the amount of methyl bromide
requested in the CUN include the fumigations conducted outside the
months of October -January and if so why?

US Response

The walnuts and dried fruit are fumigated August through November, the
dates are fumigated September through January, and the dried beans,
garbanzos are fumigated in June and black-eyed are fumigated July and
September through November.  

Although fumigations of commodities may occur through out the year (as
indicated by the small x) most of these fumigations will be done with
phosphine.  The only methyl bromide outside of the peak harvest is for
the export market (which are not part of this CUN because it meets the
requirements of the QPS exemption), or an order that must be filled
quickly (which is part of this CUN) to meet the demands of a client. 
Dates, however, must be fumigated with methyl bromide as phosphine
changes the flavor, and there are as yet, no technically feasible
alternatives.  

MBTOC Question

4. Dried Fruit (Dried Plums)

Clarify the products to be treated

Although the heading for the request is dried plums, the CUN also says
this category includes raisins and figs. Are raisins and figs included
in this CUN, and if so please provide volumes of each commodity.

US Response

Yes, raisins and figs are included along with dried plums as part of
this nomination for 2008 as they were in previous years.  The California
Dried Plum Board takes the lead in submitting documentation for the
critical use exemption on behalf of the dried fruit producers in
California.  Therefore, this nomination includes raisins, figs as well
as the dried plums.  

Average amount of commodity treated in 2003 through 2005 is about
101,000 tons of prunes, about 13,767 tons of figs, and about 298,233
tons of raisins.

MBTOC Question

5. Adoption of Alternatives by Dried Plums

This year the CUN requests an amount for 2008 that is only approximately
5% less methyl bromide for dried fruit than was granted by the Parties
in 2007. Yet the previous amount granted included several dried fruit
commodities. Does this mean that the amount of methyl bromide used for
dried plums has increased? Please show methyl bromide history of use for
dried plums. The bulk of dried fruits in California are now treated with
phosphine instead of methyl bromide. Please provide the technical or
economic supporting data for not using phosphine to fumigate dried
plums, when it is technically effective and economic to use by other US
dried fruit sectors.

US Response

The dried fruit nomination is for dried plums, raisins and figs.  The
amount nominated does not reflect an increase for dried plums.  The
nomination is strictly for use during the peak harvest period when the
timing of fumigation is critical.  MBTOC is correct that the bulk of
dried fruits in California are treated with phosphine.  However, the US
nomination is intended to ensure that the produce may be processed
quickly during the peak harvest, when a short fumigation is required to
handle the amount harvested. Fumigation must occur in a timely manner in
order to be technically and economically feasible.

MBTOC Question

6. Conditions of Dried Plum Fumigation

Describe the conditions and method of fumigating dried plums. Are they
fumigated in chamber, or is the dried plum storage facility fumigated as
a structural treatment? Describe gastightness of dried plum fumigation
chamber or facility.

US Response 

Dried plums, as well as raisins and figs, are typically fumigated in
chambers, bins or containers.  For the purpose of this US methyl bromide
nomination, the fumigations are for the peak harvest time when timing is
critical to the production and to meet market demands.  

Virtually all production of the dried fruits involved, as well as the
fumigation chambers, is located in California.  As mentioned above, the
USG is confident that the majority of these chambers used to fumigate
commodities are very gas-tight.  These fumigations are conducted in
California, and the state has many fumigation restrictions already in
place.  In addition, the state of California has County Agriculture
Commissioners that monitor these situations.  To reduce buffer zones
during fumigations, the chambers must be very gas-tight.  For more
information on California regulations in this regard, please see the
following website: (  HYPERLINK
"http://www.cdpr.ca.gov/docs/enfcmpli/manuals/mbcomfum.pdf" 
http://www.cdpr.ca.gov/docs/enfcmpli/manuals/mbcomfum.pdf ).

MBTOC Question

7. Timing of Dried Plums Fumigation

When are dried plums fumigated with methyl bromide? Are they fumigated
with methyl bromide more than once a year?

US Response 

The nomination for dried plums, raisins and figs is strictly for use
during the peak harvest period when the timing of fumigation is
critical.  MBTOC is correct that the bulk of dried fruits in California
are treated with phosphine.  However, the US nomination is to ensure
that the produce may be processed quickly during the peak harvest, when
a short fumigation is required to handle the amount harvested.  In
addition, this nomination includes incidental methyl bromide fumigations
to account for the need to process an order quickly. This is often
necessary because buyers (grocery supermarkets, for example) demand
shipments quickly (a 2-3 day notice and turnaround is typical).  Methyl
bromide fumigations for the export market are not included in this CUN.

MBTOC Question

8. Walnuts

The current CUN requests an amount for 2008 that is only approximately
5% less methyl bromide for walnuts than was granted by the Parties in
2007. Table 12.1 page 16 CUN indicates that 50% of shelled walnuts are
stored in facilities that can not be sealed for the 5 days required for
phosphine fumigation. The citation for this is California Walnut
Commission 2003. The current CUN requests methyl bromide for 2008. This
information seems out of step with the current situation. How do you
plan to minimize the use of MB for the critical use in the future?

US Response 

The conditions that are described are still accurate, although the
reference to the California Walnut Commission is from information that
the Commission provided to EPA in 2003.  Primarily the phosphine and
Eco2fume labels have not changed in the last 3 years.  

In general, phosphine alone or in combination is not suitable to replace
methyl bromide when rapid fumigations are needed to meet customer
timelines.  The delay would disrupt processing of dried fruit and nuts,
increasing production costs and interfering with access to the holiday
market.  Furthermore, phosphine is corrosive to some metals in electric
and electronic equipment in processing plants.   

Phosphine fumigation takes 3-10 days, depending on temperature, compared
to 1 day for MB (phosphine labels).  An additional 2 days are needed for
outgassing phosphine.  Phosphine fumigation is least feasible during the
colder winter months when, according to label directions, the minimum
exposure periods increases to 8-10 days (plus two days for aeration)
when commodity temperature decreases to 5oC - 12 oC.  Phosphine is not
used when commodity temperature drops below 5oC (Phosphine and
Eco2fume® labels). 

For walnuts sold as in-shell (approximately 25% of the California
production) phosphine fumigation takes too long during the peak
production period, when large volumes of walnuts are processed and
shipped rapidly.  In some cases, however, phosphine has already replaced
MB fumigation whenever feasible.  For walnuts sold as shelled product,
phosphine combined with carbon dioxide (Eco2fume®) is being used for
in-storage fumigation by approximately 50% of the industry since 2001. 
The remaining 50% lack large storage facilities that can be sealed and
left for at least five days, the time required to fully disinfest the
commodity (California Walnut Commission & Walnut Marketing Board, 2003).

MBTOC Question

9. Dried Beans

Please provide technical or economic reason why phosphine can not be
used to fumigate dried beans. Is the entire dried bean harvest included
in the amount of product that will be treated with methyl bromide?
Please provide an economic impact evaluation for the use of phosphine
for dried beans. How do you plan to minimize the use of MB for the
critical use in the future?

US Response 

This nomination is only for the peak harvest season for garbanzo and
black-eyed beans.  All other dried beans, as well as the early and late
season garbanzo and black-eyed beans are fumigated with phosphine. 
During the peak harvest so many dried beans must be processed that
phosphine takes too long resulting in a backlog of beans.  Essentially,
if the beans remain in the fumigation chambers for 3 days, then the
trucks cannot unload the beans, which then become unavailable to
transport beans from the fields, and harvesters will have to stop
harvesting, resulting in a loss of yield.   

An economic analysis was not done for dried beans because there are no
technically feasible alternatives for dried beans.  

The industry is hopeful that the state of California will register
sulfuryl fluoride for this use in the future.  In addition, sulfuryl
fluoride is currently undergoing review by the Codex Alimentarius
Commission to establish maximum residue levels (MRL) from the use of
quarantine fumigations and by the Committee for the Agreement on the
Application of Sanitary and Phytosanitary Measures to set standards for
its use.  If approved by Codex MRLs would be established for foods such
as: dried fruits and tree nuts, bran, cereal grains, and flour (e.g.
maize, rye, and wheat).  However, dried beans are not yet on the current
list. USG hopes that they would be added in the future.  

US STRUCTURES  TC "US STRUCTURES" \f C \l "2"  

MBTOC Question

1. Re-examine Table 14.1

This table may have been submitted in error because the costs indicate
no change in cost of alternatives over the past three years. Could the
Party re-examine this table and send corrections that might be available
to MBTOC?

US Response 

The cost estimates are averaged over three years due to fluctuations in
revenues and costs each year.  Therefore the cost estimates appear
unchanged each year. We are investigating to determine whether this
assumption is accurate.  

MBTOC Question

2. Increase in MB Requested for Rice Milling

Looking at the amount of MB granted by the Parties for rice milling for
2007, the request for 2008 represents a considerable increase. (Parties
granted 64.150 kg for 2007 but the 2008 CUN requests 81,258 kg.) Yet
alternatives such as sulfuryl fluoride will have been registered for
rice milling for a few years by 2008. The CUN includes the following
paragraph on page 13, "This year rice millers decreased their request
because the number of fumigations they typically have conducted declined
due to two good crop years, increased use of existing mill and storage
space, use of a newly registered alternative, and some mills made
capital investments on construction for better sealing and sanitation.
However, some mills had increase in use due to high humidity, high
temperatures, and excessive storms blowing in pests". Please provide a
full discussion explaining why this sector requests a large increase in
MB for 2008, when alternatives are registered and in partial use for
this sector in the US.

US Response 

The 2008 CUN is nominating 81,258 kg for the US rice mills because USG
accidentally took out too much of their request believing it would
qualify for QPS in the 2007 nomination.  The increase of 17,108 kg
essentially represents the amount that was accidentally removed from
last year’s nomination.  The US Rice Federation had been requesting
USG for 200,000 kg (202,756 kg for use in 2006; 200,488 kg for use in
2007), but they requested 145,603 kg for use in 2008, because they have
been able to use alternatives, had two good years of crops, and made
some improvements in their mills.  Although, they have asked for more
than what MBTOC granted for use in 2007, USG feels that to hold the rice
millers to that amount is continuing to penalize the millers for a
mistake that was made in the previous nomination.  

Post-harvest Questions from the TEAP/MBTOC Report May 2006  TC
"Post-harvest Questions from the TEAP/MBTOC Report May 2006" \f C \l "1"
 

US Commodities  TC "US Commodities" \f C \l "2"  

MBTOC Comment

1. This CUN includes walnuts, dried fruit, beans and dates. MBTOC
recommends the 0.021 tonnes planned to support alternatives research for
these commodities. MBTOC is unable to assess the amount of methyl
bromide required by walnut sector pending the Party’s reassessment of
MB needs as circumstances are in flux. 

MBTOC awaits results of trials with the newly registered alternative
propylene oxide (PPO), a potentially useful method if the sector’s
currently used vacuum chambers can be switched to PPO instead of MB. 

US Response 

Dr. James Leesch, research entomologist with USDA, is currently
conducting research on PPO in walnuts.  His experiments are on-going and
results are inconclusive at this time.  

MBTOC Comment 

2. Two EU countries have adopted maximum residue levels (MRL) for
fluoride that may facilitate the adoption of sulfuryl fluoride by this
sector. 

US Response 

The US exports walnuts to several nations, including Japan, Spain,
Canada, Germany, and Italy.  The US also exports a small percentage of
walnuts to South American nations.  It would be impossible to determine
at harvest what nuts are going to which country.  So at this time the US
is nominating 43,888 kg of methyl bromide to treat its walnuts at peak
harvest.  

However, sulfuryl fluoride is apparently currently undergoing review by
the Codex Alimentarius Commission to establish maximum residue levels
(MRL) from the use of quarantine fumigations and by the Committee for
the Agreement on the Application of Sanitary and Phytosanitary Measures
to set standards for its use.  If approved by Codex, MRLs would be
established for foods such as: dried fruits and tree nuts, bran, cereal
grains, and flour (e.g. maize, rye, and wheat).  If this occurs, it
would remove this obstacle and allow for investigation and potentially
future transition.  

MBTOC Comment 

3. MBTOC also requests information on the potential for decreased MB
requirement by walnut sector if vacuum treatment time was increased by
one hour, with the resulting 20% decrease in required dosage rate. 

US Response 

The US nomination is for walnuts during the peak harvest when timing is
very critical to production.  Typically, three (3) truckloads of walnuts
are fumigated sequentially during a 24 hour period.  This is necessary
to eliminate the pests and to handle the load of the harvest peak. 
Therefore, this nomination is for the time constraints of the industry
during peak harvest.  In addition, there are no data to support the
lower rate and increased time of exposure, but the fact is that the
delay of time would cause a backlog of nuts leaving the field and before
processing.  

MBTOC Comment 

4. Bean sector has investigated using cylinderized phosphine finding it
useful for product in storage but too time consuming for the immediate
post-harvest treatment before holiday marketing. The Party has indicated
it will review transition rates for this sector when more is known about
adoption of sulfuryl fluoride, which may depend on adoption of MRLs by
importers.

US Response 

This is correct.  This sector will be re-evaluated as sulfuryl fluoride
continues to undergo review by the Codex Alimentarius Commission to
establish maximum residue levels (MRL) from the use of quarantine
fumigations and by the Committee for the Agreement on the Application of
Sanitary and Phytosanitary Measures to set standards for its use. 
Currently it appears that if sulfuryl fluoride is approved by Codex,
MRLs would be established for foods such as: dried fruits and tree nuts,
bran, cereal grains, and flour (e.g. maize, rye, and wheat).  The
current list of foods does not yet include beans, but USG is continuing
to monitor the situation.  

US Cocoa Beans  TC "US Cocoa Beans" \f C \l "2"  

MBTOC Comment 

5. Currently the Party indicates a need for two fumigations per year of
the cocoa beans: the first fumigation upon import and a second
fumigation immediately before shipment to the chocolate manufacturers.
However, MBTOC requests the Party to recalculate the impact on MB volume
required for this CUN if alternatives were used, especially to replace
the second fumigation before shipment to chocolate manufacturers, to the
extent that this could be achieved by 2008.  

US Response 

The second fumigation of cocoa beans, just prior to shipping to
manufacturers, is often in warehouses under tarpaulins.  The warehouse
would need to be evacuated for 2-8 days (this is more than is needed
under methyl bromide fumigation) depending on amount of phosphine
necessary; otherwise this would violate the US phosphine pesticide
label.  Since more than one commodity is stored at these port
facilities, this is not practical.  

MBTOC Comment 

6. For the first fumigation, changed logistics that may allow increased
use of phosphine including in-transit treatments conducted at time of
export from producing countries may be useful in reducing the need for
the first fumigation (Watson et al, 2000)  

US Response 

We are still investigating whether or not it is feasible.  According to
the US phosphine pesticide label, in-transit fumigation of transport
containers aboard ships are governed by D.O.T. RSPA 49 CFR 176.76(i) and
International Maritime Dangerous Goods Code P9025-1 Amdt. 27-94. These
standards include the gastightness of the ship, notification of crew,
among other regulations.  To have cocoa beans fumigated at the port of
origin would place these burdens, including the safety of the crew on
other nations.  The USG is still seeking information regarding this
option.  

MBTOC Comment 

7. For the second fumigation, the Party may wish to base its
determination on further research of techniques that allow weekend
fumigation using treatments that only target post-embryonic stages,
since egg kill should not be a requirement if the chocolate
manufacturers quickly use the cocoa beans shipped to them. Avenues of
investigation for cocoa might include furthering the applicant’s
current work with the recently registered sulfuryl fluoride. 

US Response 

Sulfuryl fluoride was registered for this use in May of 2005 by USEPA. 
The industry is working with the registrant to determine how to
implement this new chemical into the current pest control strategies. 
However, to only target post-embryonic stages would require a change in
the mind-set of industry, and this requires testing of the new chemical
in a commercial setting, and education of users (all of which, in turn,
requires time).  The feasibility of this approach requires that cocoa
beans be used in a fairly short window after fumigation or the remaining
viable eggs will result in a high and increasing level of insect
infestation.  This approach may not, therefore, be feasible

MBTOC Comment 

8. Propylene oxide is also registered for use in cocoa beans, although
suitable chambers would have to be installed. IPM approach improvements
such as enhanced cocoa inspection programs and methods could be
investigated to determine if the fumigation before shipment to chocolate
manufacturers could be avoided during winter or in other circumstances.

US Response 

The Port Authorities own the ports at which cocoa beans, as well as
other commodities, arrive and the warehouses were cocoa beans are
stored.  The installation of new chambers to utilize propylene oxide
would be cost prohibitive.  The importers of cocoa beans are encouraged
to monitor and inspect the bags of cocoa beans while they are in
storage.  However, the manufacturers want clean cocoa beans delivered in
a timely fashion.  

US NPMA  TC "US NPMA" \f C \l "2"  

MBTOC Comment 

9. Although MBTOC recommends 4.059 tonnes for herb and spice facilities,
MBTOC does not find that the use of MB for herb and spice commodity to
be consistent with Decision IX/6 since several alternatives are
available and in widespread commercial use. The Party is requested to
ensure herb and spice commodity are not included in facility fumigations
using MB. 

US Response 

The 2008 nomination for methyl bromide is for the domestic uses of dried
herbs and spices at blending facilities.  These facilities produce
packages (i.e. pizza mixes, chili mixes, etc.) that are then added to
pre-packaged goods.  These facilities are similar to grain mills in that
there are silos, mixing areas, packaging areas, etc.  Infestation in
herb and spice blending facilities is not localized to machinery that
can be spot heat treated.  These facilities utilize methyl bromide to
target pests present in inaccessible areas of the structure, not the
ingredients or finished products that may be stored on-site.  The
industry does do a draw-down before fumigating; however, there will be
small amounts of dried herbs and spices within the machinery that would
be exposed.  Sulfuryl fluoride was registered for this use a year ago,
but as these are very small operations, it will take some
experimentation to determine how best to use this alternative and to
determine if it is economically feasible.  

This nomination is only for a few facilities that are quite small and
target the domestic market.  Because these are very small operations,
they have little profit to invest in the capital costs required to
utilize the alternatives that the larger manufacturers have been able to
employ.  Therefore, the nominated amount of methyl bromide for this use
is:  4,046 kg for 203,000 m3, at a rate of 20kg/1000 m3.  

MBTOC Comment 

10. Cheese stores are only treated with MB upon requirement of
inspectors from United States Department of Agriculture in response to
pest infestation. To ensure the requirements of Decision IX/6 are met,
the Party should conduct research to find alternatives and/or methods to
reduce infestation and the requirement to use MB. Further avenues of
investigation for cheese stores might include peer-industry information
exchange, reviews of pertinent literature, pest control through
temperature manipulation and improvements in IPM approach and sanitation
that will reduce infestation until the cheese can be removed from the
store. Since there may be a lengthy requirement for the use of MB in
cheese stores and since the stores are fairly gastight, the Party is
encouraged to consider the use of recapture equipment to reduce
emissions from this continued use.  

US Response 

Although cheese production is a major industry in the US, the fumigation
of cheese processing facilities is actually quite small.  A methyl
bromide fumigation is only done if USDA inspectors request it. 
Consequently, it is not always the same facility nor the same location. 
While there are usually a few fumigations done each year in cheese
processing plants, it is difficult to coordinate a research plan. 
However, the cheese industry is diligent about maintaining
micro-sanitation.  The facilities are often emptied and sanitized
between batches.  

The pests in cheese (mites, skippers, and borers) are the same pests
that infest the processed meats.  So the research done on country hams
will be applicable to cheese facilities.  The primary difference between
the two production practices is that ham is cured at 80-90° F and 55%
relative humidity; whereas cheese is cured at 35° F from milk that has
been pasteurized.  The conditions under which cheese are processed
reduce the pest pressure of insects and mites.  In order for these
facilities to maintain these conditions, their facilities are very
gastight.  

All alternatives to methyl bromide are re-evaluated each year, including
recapture technology in the post-harvest sector.  The technical and
economic feasibilities are investigated as new information becomes
available.  

MBTOC Comment 

NPMA Economics:

11. CUN states that the economic impacts cannot be assessed since the
applicant is not the end-user. Economic impacts arise from three
contributing factors: direct pest control costs increase because of
increased labor time required for longer treatment time and increased
number of treatments; capital expenditures may be required to adopt
phosphine for accelerated replacement of plant and equipment due to its
corrosive nature; and additional production downtimes for the use of
alternatives are unavoidable

US Response 

The USG is pointing out that it is not able to access firm-level data. 
This does not differ between the NPMA sector and other post-harvest
sectors.  MBTOC is correct in its discussion of the elements of cost
change.  The USG case for NPMA is based on the lack of technical
feasibility of all other alternatives in the circumstances of the
nomination.

MBTOC Comment 

12. Sulfuryl fluoride was registered last year, and adoption of heat and
phosphine treatments increased, which resulted in a decrease in MB
requested by the Party.  The Party is encouraged to conduct and
strengthen its research program and assist commercial adaptation of
alternatives to ensure the requirements of Decision IX/6 are fully met
for all sectors included in this CUN and to avoid these future
requirements for MB. The Party has indicated it will reassess the
quantity of MB to be permitted through domestic regulation if the
circumstances of the nomination change. For example, as more experience
is gained with sulfuryl fluoride and heat by 2008, it should be possible
to decrease the need for MB in flour and rice milling to allow these
sectors to more closely mirror decreases made in pet foods and bakeries.

US Response 

The USG is committed to meeting the criteria under Decision IX/6.  Not
only are the milling and food processing industries committed to
continuing research into alternatives on their own, but the USG has
promoted research on new and existing pesticidal active ingredients to
determine their potential as methyl bromide alternatives.  Ongoing
research supported by the USG is being conducted by the Agricultural
Research Service (ARS) and the Cooperative State Research, Education,
and Extension Service (CSREES).  One of the programs funded by CSREES is
the IR-4 Program, which is conducting methyl bromide alternatives
research in conjunction with alternatives manufacturers.  

US Ham  TC "US Ham" \f C \l "2"  

MBTOC Comment 

13. MBTOC recommends 18.998 tonnes for this use in 2008. Although the
Party requested an increase for 2008, it did not justify the use of an
amount greater than granted by the Parties in 2007. Although
alternatives for this use are unknown to MBTOC, the onus rests on the
Party to ensure use of methyl bromide is minimized as much as possible. 

US Response 

USG realized that 671 kg more than what was granted by MBTOC for 2007
was nominated; however, it was 21,185 kg less than nominated for use in
2007.  The nomination was based on information obtained from the
manufacturers of methyl bromide and the fumigators of dry cured pork
products.  The USG believes that this nomination more accurately
reflects usage in an industry that does not yet have an identified
alternative.  

MBTOC Comment 

14. The Party has begun a survey of facility gastightness in this
sector; low facility gastightness is a major contributing factor to MB
use by two of the applicants included in the CUN. However, two other
applicants, Nahunta Pork and Gwaltney of Smithfield have already
invested in improved facilities that reduce MB use. MBTOC expects that
facilities operated by members of American Meat Association and National
Country Ham Association will be required to improve gastightness as a
condition of MB use by 2008.  The Party is encouraged to conduct
research and reduce emissions by improving gastightness to ensure the
requirements of Decision IX/6 are fully met for this sector and to
minimize use of methyl bromide. Research on the effectiveness of
sulfuryl fluoride alone or in combination with other processes, on other
treatments such as cold, to improve IPM tools to avoid infestation, and
on changing processing logistics to allow treatment by phosphine might
be helpful in finding avenues to reduce MB use.  

US Response 

By conducting research on the major pests of dry cured pork products, to
improve gastightness and identify other IPM strategies, this small
industry is making progress and fulfilling its requirements of Decision
IX/6.  In addition, several producers are cooperating with the
registrant of sulfuryl fluoride to determine if this alternative will
control the primary pests, as efficacy data are unavailable at this
time.  Cold treatments could not be used in the Summer (or Aging) Room
where the temperature (80-90° F) and relative humidity (55%) must be
maintained to cure the product.  Phosphine does not control the mites,
and is illegal to use in North Carolina except for rodent control.  

ECONOMIC QUESTIONS  TC "ECONOMIC QUESTIONS" \f C \l "1"  

MBTOC Question

Post-harvest – Economic Assessment

1. Please elaborate on how days of lost production were estimated in the
post-harvest nominations.  In particular, how was 84 days estimated as
shown in Table E.3 for Dried Fruit.

Refer to Tables E.1 and E.2, page 20 of the Post Harvest use for
Commodities CUN.  The total commodity treated of walnuts is the same for
methyl bromide and phosphine.  However, the total commodity treated of
dried fruit is reduced from 88,235 for methyl bromide to 63,529 for
phosphine.  Please explain this apparent inconsistency and the steps
used to derive the smaller value for phosphine.

Table E.1: Annual Economic Impacts of Methyl Bromide Alternatives

Loss Measure	Methyl Bromide	Phosphine

Total Commodity Treated (kg/1000 m³)	320,455	320,455

Average Market Price (US$/kg)	$           1.08	$         0.886

Gross Revenue (US$/1000 m³)	$     346,091	$     283,795

Operating Cost (a+b) per 1000 m³	$     328,087	$     328,149

a) Cost of MB or Alternative	$            612	$            459

b) Other Operating Costs	$     327,475	$     327,690

Net Revenue (US$/ha) (net of operating costs)	$       18,005	$     
(44,354)

Loss measures



Time Lost (days)	0	84

Loss per 1000 m³ (US$/1000 m³)	$                 -	$       62,358

Loss per Kilogram MB (US$/kg)	$                 -	$         1,299

Loss as a % of Gross Revenue (%)	0%	18%

Loss as a % of Net Revenue (%)	0%	346%

Time lost with phosphine is assumed to result in a lower average market
price for walnuts because less would be treated during peak prices, and
increased supply at other times would depress off-peak prices.

Table E.3: Annual Economic Impacts of Methyl Bromide Alternatives

Loss Measure	Methyl Bromide	Phosphine

Total Commodity Treated (kg/1000 m³)	88,235	63,529

Average Market Price (US$/kg)	$           0.75	$           0.75

Gross Revenue (US$/1000 m³)	$       66,176	$       47,647

Operating Cost (a+b) per 1000 m³	$       61,741	$       57,889

	a) Cost of MB or Alternative	$            413	$            310

	b) Other Operating Costs	$       61,328	$       57,579

Net Revenue (US$/ha) (net of operating costs)	$         4,435	 $     
(10,242)

Loss measures



Time Lost (days)	0	84

Loss per 1000 m³ (US$/1000 m³)	$                 -	$       14,677

Loss per Kilogram MB (US$/kg)	$                 -	$            612

Loss as a % of Gross Revenue (%)	0%	22%

Loss as a % of Net Revenue (%)	0%	331%

Time lost with phosphine is assumed to reduce the total commodity that
could be treated.

US Response

The calculation and assumptions regarding the 84 days of downtime using
phosphine are as follows:

For the four commodities, walnuts, pistachios, dried fruit, and dates, a
major impediment to phosphine adoption is the several-fold increase in
fumigation time during the period when the commodities must be processed
quickly.  Two other major limitations to the further adoption of
phosphine are its corrosiveness to electronic sorting and processing
control equipment and its loss of effectiveness as temperature
decreases.    

Considering the following:

*  The walnut co-op represents about 50% of the walnut industry. 

*  The walnut co-op processes 3 million lb (1,500 tons)/day during the
peak season (several weeks).  700 tons (1.4 million lb) are processed in
the walnut facilities each day.  The remaining 800 tons per day are
processed in offsite facilities.

*  The walnut co-op has 8 vacuum fumigation chambers.  Each chamber has
a 2,500 cubic feet capacity and holds 25 tons (1 truckload) of walnuts. 
  

*  1 ton of walnuts in shell occupies a volume of 100 cubic feet.

*  About 3.5 truckloads (175,000 lb or 87.5 tons) are put through each
fumigation chamber per day.  During peak periods, plants operate 24
hours per day.

* Conventional MeBr fumigation takes 24 hr + 4 hr for aeration.

* MeBr vacuum fumigation takes about 7 hr.  Plants operating 24 hr/day
complete 3.5 fumigations/day.   

* Phosphine fumigation takes 3-4 days + 2 days for aeration, for a total
of 5-6 days.  

*  Since 2001, Ecofume has replaced MeBr in the walnut co-op’s 21
storage buildings, where the walnuts that are not shipped immediately
are stored.

Even if we allow the minimum of 5 days for phosphine fumigation and one
full day for MeBr fumigation under vacuum, even though it actually takes
about 7 hours, the difference would be 4 days per fumigation.  If we
assume a peak production/processing season of only two weeks, the
downtime would be 4 x 14 = 56 days.  However, the peak season is
actually 3-4 weeks, which would translate to a downtime of 84-112 days. 
We would have to multiply these figures by 3.4 to compare to the actual
fumigation rate, but that would be overkill.

Even when MeBr fumigation is not done under vacuum, such as seems to be
the case for dates, the difference is still about 4 days.

In the case of the walnut industry, we assume that because of time lost,
the average market price is reduced because not enough walnuts can be
treated during peak market pricing season using phosphine.  We also
assumed that lost days can be made up, but at a lower market price.  

In the case of the dried fruit industry, we assume that because of time
lost, the industry cannot treat the same volume of commodity using
phosphine which leads to production loss.  Therefore the lost days
cannot be made up (loss in downtime) and is reflected in a reduction in
gross revenue.  

MBTOC Question

2.

Michigan Pepper- Table E.3: Economic Impacts of Methyl Bromide
Alternatives

michigan pepper	Methyl Bromide	1, 3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	4,530	4,258

* Price per Unit (us$)	$5	$5

= Gross Revenue per Hectare (us$)	$24,056	$20,916

- Operating Costs per Hectare (us$)	$23,938	$25,607

= Net Revenue per Hectare (us$)	$118	$(4,690)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$4,808

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$40

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

4. Loss as a Percentage of Net Revenue (%)	0%	100%

5. Profit Margin (%)	0%	-22%



In the above example, could you please report the price to two decimals
so that the impact of the missed market window is more visible?

US Response

The table below has been updated with the price per unit reported to two
decimal places.

Updated Michigan Pepper- Table E.3: Economic Impacts of Methyl Bromide
Alternatives  TC " Updated Michigan Pepper- Table E.3: Economic Impacts
of Methyl Bromide Alternatives" \f F \l "1"  

michigan pepper	Methyl Bromide	1, 3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	4,530	4,258

* Price per Unit (us$)	$5.31	$4.91

= Gross Revenue per Hectare (us$)	$24,056	$20,916

- Operating Costs per Hectare (us$)	$23,938	$25,607

= Net Revenue per Hectare (us$)	$118	$(4,690)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$4,808

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$40

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

4. Loss as a Percentage of Net Revenue (%)	0%	100%

5. Profit Margin (%)	0%	-22%



MBTOC Question.

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

Michigan	Methyl Bromide	100	$    30,559	$    30,559	$    30,559

	1,3–D + Chloropicrin	78	 $    29,555 	$    29,555 	$    29,555

	Metam Sodium	78	 $    29,739 	$    29,739	$    29,739

	Chloropicrin	78	$    29,555	$    29,555	$    29,555

Southeastern US	Methyl Bromide	100	$     26,380	$     26,380	$    
26,380

	1,3–D + Chloropicrin	83	$    24,946	$    24,946	$    24,946

* As percentage of typical or 3-year average yield, compared to methyl
bromide e.g. 10% more yield, write 110. 

Year 1

Region	Alternatives 

(as shown in question 21)	Gross revenue for last reported year (US$/ha)
Net Revenue for last reported year  (US$/ha)

Michigan	Methyl Bromide	$    39,996	$      9,438

	1,3–D + Chloropicrin	 $    32,880 	 $      3,325 

	Metam Sodium	 $    34,931 	 $      5,192 

	Chloropicrin	$    32,880	 $      3,325 

Southeastern US	Methyl Bromide	$     40,914	$     14,533

	1,3–D + Chloropicrin 	$    33,772	$      8,825



Michigan - Table E.1: Economic Impacts of Methyl Bromide Alternatives 

Michigan	Methyl Bromide	1,3-D + Pic	Metam Sodium	Chloropicrin

Production Loss (%) 	0%	6%	13%	6%

   Production per Hectare 	4,414	         4,132 	3,845 	4,132 

* Price per Unit (us$)	$            9.44	 $           9.44 	 $          
9.44 	 $            9.448 

= Gross Revenue per Hectare (us$)	$    41,652	 $    38986 	 $    36,279 
 $      38986 

- Operating Costs per Hectare (us$)**	$    37,055	 $    32453 	 $   
31,170 	 $      32,453 

= Net Revenue per Hectare (us$)	$      4596	 $      6,533 	 $      5,109
	 $        6,533

Five Loss Measures *

1. Loss per Hectare (us$)	$           -	$      1,937	$      512	$       
1,937

2. Loss per Kilogram of Methyl Bromide (us$)	$           -	$         16
$          4	$           16

3. Loss as a Percentage of Gross Revenue (%)	0%	5%	1%	5%

4. Loss as a Percentage of Net Operating Revenue (%)	0%	42%	11%	42%

5. Operating Profit Margin (%)	11%	17%	14%	17%

**Note that the measures in the tables below must be interpreted
carefully.  Operating costs do not include fixed costs and net revenue
equals gross revenue minus operating costs.

3. Explain the inconsistency in Yields and gross and net revenue between
the Tables.

US Response

The tables below are updated with the corrected yields and gross and net
revenues.  

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

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

Michigan	Methyl Bromide	100	$    37,056	$    37,056	$    37,056

	1,3–D + Chloropicrin	94	 $    32,453 	 $    32,453 	 $    32,453 

	Metam Sodium	87	 $    31,170 	 $    31,170 	 $    31,170 

	Chloropicrin	94	$    32,453	$    32,453	$    32,453

Southeastern US	Methyl Bromide	100	$     26,380	$     26,380	$    
26,380

	1,3–D + Chloropicrin	83	$    24,946	$    24,946	$    24,946

* As percentage of typical or 3-year average yield, compared to methyl
bromide e.g. 10% more yield, write 110. 

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

Year 1

Region	Alternatives 

(as shown in question 21)	Gross revenue for last reported year (US$/ha)
Net Revenue for last reported year  (US$/ha)

Michigan	Methyl Bromide	$    41,652	$      4,597

	1,3–D + Chloropicrin	 $    38,987 	 $      6,534 

	Metam Sodium	 $    36,279 	 $      5,109 

	Chloropicrin	$    38,987	 $      6,534

Southeastern US	Methyl Bromide	$     40,914	$     14,533

	1,3–D + Chloropicrin 	$    33,772	$      8,825



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

Michigan	Methyl Bromide	1,3-D + Pic	Metam Sodium	Chloropicrin

Production Loss (%) 	0%	6%	13%	6%

   Production per Hectare 	4,414	         4,132 	3,845 	4,132 

* Price per Unit (us$)	$            9.44	$           9.44	$          
9.44	$            9.44

= Gross Revenue per Hectare (us$)	$    41,652	 $    38,987 	 $    36,279
	 $      38,987 

- Operating Costs per Hectare (us$)**	$    37,056	 $    32,453 	 $   
31,170 	 $      32,453 

= Net Revenue per Hectare (us$)	$      4,597	 $      6,534 	 $     
5,109 	 $        6,534

Five Loss Measures *

1. Loss per Hectare (us$)	$           -	$      1,937	$      512	$       
1,937

2. Loss per Kilogram of Methyl Bromide (us$)	$           -	$         16
$          4	$           16

3. Loss as a Percentage of Gross Revenue (%)	0%	5%	1%	5%

4. Loss as a Percentage of Net Operating Revenue (%)	0%	42%	11%	42%

5. Operating Profit Margin (%)	11%	17%	14%	17%

**Note that the measures in the tables below must be interpreted
carefully.  Operating costs do not include fixed costs and net revenue
equals gross revenue minus operating costs.

MBTOC Question

4. Explain why the net revenue per hectare is higher for 1,3-D + Pic
(and the 2nd and 3rd best alternative) than for MB.

US Response

The net revenue appears higher because the assumption is that harvesting
costs are calculated based on yield.  Harvesting costs were estimated to
be about $6.50 per 25 pound box and are a large proportion of operating
costs (ranging from 70% to 75%).  We are investigating to determine
whether this assumption is accurate.  

MBTOC Question

Michigan Zucchini - Table E.4: Economic Impacts of Methyl Bromide
Alternatives

Michigan Zucchini	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	2,368	2,226

* Price per Unit (us$)	$6	$5

= Gross Revenue per Hectare (us$)	$13,484	$12,041

- Operating Costs per Hectare (us$)	$16,522	$15,464

= Net Revenue per Hectare (us$)	$(3,038)	$(3,423)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$385

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$3

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

4. Loss as a Percentage of Net Revenue (%)	0%	-13%

5. Operating Profit Margin (%)	-23%	-28%



5. What is the significance of the negative net revenue using MB? 

US Response

These calculations are based on the information provided by the
applicant based on a single crop system.  We are investigating to
determine whether this assumption is accurate.  



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Brecke, B. J., J. B. Unruh, and D. O. Stephenson IV**.  2005.  Dazomet
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Kubota, C. Associate Professor, Department of Plant Sciences, University
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Louws, Frank J., Lisa M. Ferguson  Nathan P. Lynch, and Paul B.
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disease, nematode and weed management in fresh market tomatoes. Crop
Protection 25: 690-695

Schneider, S., Trout, T., and Ajwa, H. 2005.  2005 Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions. Available online at   HYPERLINK
"http://www.mbao.org/2005/05Proceedings/045SchneiderS%20Replant%20paper%
20MBAO%202005.pdf" 
http://www.mbao.org/2005/05Proceedings/045SchneiderS%20Replant%20paper%2
0MBAO%202005.pdf 

Society of American Florists, California Cut Flower Commission, and
Florida Floriculture Growers, Methyl Bromide National Management
Strategy, Field Grown Ornamentals in Florida and California:  Bulbs, Cut
Flowers, Cut Foliage and Propagative Material, September 2005.

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.2005 Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions. Available online at   HYPERLINK
"http://www.mbao.org/2005/05Proceedings/012TroutT%20mb-fumuse-05.pdf" 
http://www.mbao.org/2005/05Proceedings/012TroutT%20mb-fumuse-05.pdf  

Trout, T., Schneider, S., Ajwa, H., and Gartung, J. 2003. 2003 Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions. Available online at   HYPERLINK
"http://www.mbao.org/2003/055%20TroutTmbp-conf03-peach.pdf" 
http://www.mbao.org/2003/055%20TroutTmbp-conf03-peach.pdf  

USDA. 2002. Crop Profile for Squash in Florida. Available online at  
HYPERLINK "http://www.ipmcenters.org"  www.ipmcenters.org 

 In growing areas of the United States where the weather does not put an
end to a crop, as it does in the Northeast and Midwest, the need to
prepare the ground for the next crop dictates when the current plants
must be pulled from the ground.

 The technique is referred to a “Delphi” in tribute to the oracle at
Delphi where the future was foretold.

 Changing the label to increase the amount that can be applied would
require bith Federal and State approval.  Before Federal approval could
be granted the human health and environmental risk potential would have
to be analyzed and found acceptable.  State approval would also be
contingent on whether the new rates met State regulations regarding
protecting human health and the environment.  This is a lengthly (and
uncertain) process.

US Response to MBTOC Questions of June 2006 for 2008 Nomination

 PAGE   

 PAGE   27 

Page

US Response to MBTOC Questions of June 2006 for 2008 Nomination

