Nominating Party: The United States of America

FILE NAME: USA CUN13 Soil Strawberry Nursery Open Field 

Brief descriptive Title of Nomination:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Strawberry Nursery in Open Fields (Submitted in 2011 for the 2013 Use
Season)

Crop name (open field or protected): Strawberry Nursery Open Field

Quantity of methyl bromide Nominated:

Table 1. Quantity of Methyl Bromide Nominated

Year	Nomination Amount 

2013	3,752 kg



NOMINATING PARTY CONTACT DETAILS:

Contact Person:	John Thompson

Title:	Division Director

Address:	Office of Environmental Policy

	U.S. Department of State

	2201 C Street, N.W. Room 2658

	Washington, D.C. 20520

	U.S.A.

Telephone:	(202) 647-9799

Fax:	(202) 647-5947

E-mail:	  HYPERLINK "mailto:thompsonje2@state.gov" 
thompsonje2@state.gov 

Following the requirements of Decision IX/6 paragraph (a)(1) The United
States of America has determined that the specific use detailed in this
Critical Use Nomination is critical because the lack of availability of
methyl bromide for this use would result in a significant market
disruption.                  ■ Yes	            ( No

					

Signature			       	Name					Date

Title:      			

(Details on this page are requested under Decision Ex. I/4(7), for
posting on the Ozone Secretariat website under Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will
also refer to the original nomination on which the Party’s first-year
exemption was approved, as well as any supplementary information
provided by the Party in relation to that original nomination.  As this
earlier information is retained by MBTOC, a Party need not re-submit
that earlier information.   



CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person:	Jack Housenger	

Title:	Director	

Address:	Biological and Economic Analysis Division			

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	1200 Pennsylvania Avenue, N.W. Mailcode 7503P

	Washington, D.C. 20460

	U.S.A.	

Telephone:	(703) 308-8200		

Fax:	(703) 308-7042	

E-mail:	  HYPERLINK "mailto:Housenger.Jack@epa.gov" 
Housenger.Jack@epa.gov 

		

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION
PACKAGE:

1.  PAPER DOCUMENTS:  

Title of paper documents and appendices	No. of pages	Date sent to Ozone
Secretariat

















2.  ELECTRONIC COPIES OF ALL PAPER DOCUMENTS:  

*Title of each electronic file (for naming convention see notes above)
No. of kilobytes 	Date sent to Ozone Secretariat

USA CUN13 Soil Strawberry Nursery Open Field 















* Identical to paper documents



METHYL BROMIDE CRITICAL USE RENOMINATION FOR Preplant Soil Use (OPEN
FIELD OR PROTECTED ENVIRONMENT)

STRAWBERRY NURSERY

SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE 

Methyl bromide has been the long-time standard in nurseries for the
treatment of soils to achieve pest-free certification of nursery stock. 
The U.S. is nominating strawberry nurseries in California for a critical
use exemption for methyl bromide for use in 2013 (Table 1).  Currently
in California only methyl bromide and 1,3-D are specified treatments for
nursery stock certification (e.g., CDFA, 2009—NIPM #7).  By
regulation, the use of 1,3-D is limited to soils where soil moisture and
texture are amenable to nematicidal activity.  According to the
California Strawberry Nursery Association growers on sandy soils have
been able to use 1,3-D/chloropicrin mixtures as an approved treatment
but the nomination is for the critical use of methyl bromide on 19 ha
where 1,3-D is not an approved treatment, is not economically feasible
or is limited by township caps.  No other alternate strategies are
approved for certification purposes.

The U.S. Government (USG) has reviewed all factors affecting transition
rates in this sector.  Based on this assessment the transition rate has
been greatly increased for this sector.  For the area covered in this
nomination, the USG believes that the narrative discussion included in
this document is technically valid.  The USG has nominated amounts of
methyl bromide based only on those sub-sectors that cannot transition
away from methyl bromide at the accelerated rate.

2.	Summarize why key alternatives are not feasible

California nurseries currently use methyl bromide on all of their land
for transplants designated as quarantine pre-shipment (QPS), which makes
up 99% of methyl bromide use by nurseries.  For the 2013 season, methyl
bromide continues to be critical for California strawberry nurseries for
22 ha of non-QPS uses where there are regulatory restrictions on 1,3-D
and chloropicrin.

Regulations in California on the use of 1,3-D and chloropicrin restrict
their use in some locations, such as clay soils and where township caps
are in place.  Research trials in California have indicated that
iodomethane/chloropicrin, 1,3-D/chloropicrin followed by dazomet, and
chloropicrin followed by dazomet provided similar pest control in runner
nurseries when compared to methyl bromide/chloropicrin (e.g., Fennimore
et al., 2008a; Kabir et al., 2005).  The use of low permeable films has
improved efficacy of alternatives.  

3.	is the use covered by A certification STANDARD?

The certification for strawberry nurseries (e.g., CDFA, 2009) located in
California includes zero tolerance for damaging diseases and
plant-parasitic nematodes in order to minimize the spread of these pests
to production fields.  State authorities may determine appropriate
measures to achieve pest-free designation.  California describes methods
to prepare field soils using methyl bromide or 1,3-D (CDFA, 2009—NIPM
#7).  California regulations (e.g., CDFA, 2009—NIPM #3) for nursery
standards (reg. 3060.2-a) include:

“All nursery stock shall be kept ‘commercially’ clean with respect
to established pests of general distribution.  Commercially clean shall
mean that pests are under effective control, are present only to a light
degree, and that only a few of the plants in any lot or block of nursery
stock or on the premises show any infestation or infection, and of these
none show more than a few individuals of any insect, animal or weed
pests, or more than a few individual infestations of any plant
disease.” 

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

All nurseries currently treat soils with methyl bromide.  This
nomination is only for approximately 1% of nursery soils not designated
as QPS and where 1,3-D is not effective or available due to regulatory
requirements of soil type, moisture, or township caps.

5.	Would it be feasible to expand the use of these methods to cover at
least part of the crop that has requested use of methyl bromide? What
changes would be necessary to enable this?

As previously stated, methyl bromide is critical for the small number of
non-QPS hectares that cannot be treated with 1,3-D due to soil type,
moisture, or township caps.  The USG has reviewed all factors affecting
transition rates in this sector.  Based on this assessment the
transition rate has been greatly increased for most portions of this
sector.  For the area covered in this nomination, the USG believes that
the narrative discussion included in this document is technically valid.
 The USG has nominated amounts of methyl bromide based only on those
sub-sectors that cannot transition away from methyl bromide at the
accelerated rate.

6.	SUMMARY OF RECENT RESEARCH 

Research results for strawberry nurseries were not presented at the MBAO
meeting in 2010.  Previous research for the strawberry runner nurseries
in California (e.g., Fennimore et al., 2008a; Kabir et al., 2005) has
indicated that in research plots some alternatives appear to provide
pest management levels comparable to traditional methyl bromide
treatments.  However, restrictions or lack of efficacy of 1,3-D has
resulted in the critical need for methyl bromide for a small portion of
California nurseries.

Previous research (e.g., Larson and Shaw, 2007) suggested that
inconsistent efficacy of alternatives remains the greatest problem for
transition to alternatives by this industry (this was also the case for
nurseries in Spain; see, e.g., Garcia-Mendez et al., 2007). 
Alternatives that have been evaluated in research trials over the past
several years are 1,3-D/chloropicrin, 1,3-D/chloropicrin + metam-sodium,
1,3-D and metam-sodium, and dazomet as a follow-up application to
1,3-D/chloropicrin or chloropicrin (Fennimore et al., 2008b).  

For the effective production of runner plants, weeds must be kept to a
minimum.  Recently a report on weed control was published (Fennimore et
al., 2008a).  Results indicated that iodomethane/chloropicrin,
1,3-D/chloropicrin followed by dazomet, chloropicrin followed by
dazomet, and methyl bromide/chloropicrin all provided comparable weed
control with similar hand-weeding costs.  Costs of iodomethane for
California nurseries were considered uncertain since it is not currently
on the market for commercial use in California.  A cost analysis for
alternatives for California strawberry nurseries is presented in this
document.  

The industry continues to refine protocols for effective alternatives,
but this requires several seasons of data gathering.  For example, the
use of 1,3-D/chloropicrin followed by dazomet or chloropicrin followed
by dazomet appeared more effective in nursery trials in California
(Kabir et al., 2005) than previous nursery trials where chloropicrin was
applied alone (Larson and Shaw, 2000).  Fennimore et al. (2008b) found
variable effects and indicated that further research is necessary to
optimize the treatment regime.  By optimizing methods identified through
research alternative strategies are being identified.  

7.  ECONOMIC FEASIBILITY OF ALTERNATIVES 

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

The economic analysis of the strawberry nursery applications compared
data on yields, crop prices, revenues and costs using methyl bromide and
using alternative pest control regimens in order to estimate the loss of
methyl bromide availability.  The alternatives identified as technically
feasible – in cases of low pest infestation – for California are
1,3-D + chloropicrin followed by metam sodium.  Iodomethane plus
chloropicrin was registered in California on December of 2010.  However,
the rates are lower than those previously tested on strawberry nursery
plants and the buffers are up to 10 times larger than the rest of the
U.S.

The economic factors that really drives the feasibility analysis for
nursery stock production uses of methyl bromide are: (1) yield losses,
referring to reductions in the quantity produced, (2) increased
production costs, which may be due to the higher-cost of using an
alternative, additional pest control requirements, and/or resulting
shifts in other production or harvesting practices (3) quality losses,
which generally affect the quantity and price received for the goods,
and (4) missed market windows due to plant back time restrictions, which
also affect the quantity and price received for the goods.

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

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

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

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

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

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

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

California strawberry nursery growers are not expected to see any yield
or quality impacts with 1,3-D/chloropicrin plus metam sodium (Table 2). 
But, the new registration of iodomethane plus chloropicrin in California
is at a rate lower than those previously tested and may lead to yield
and quality losses.

Table 2.  California Strawberry Growers Association  : Economic Impacts
of Methyl Bromide Alternatives.

California SGA	Methyl Bromide	Iodomethane (Reg. Dec 2010)	1,3 D + PIC 

fb metam

Production  Loss (%) 	0%	0%	10%

   Production per Hectare 	372	372	235

* Price per Unit (us$)	$ 110.23	$ 110.23	$ 110.23

= Gross Revenue per Hectare (us$)	$ 41,019	$ 41,019	$ 36,918

- Operating Costs per Hectare (us$)**	$ 28,585	$ 43,295	$ 44,788

= Net Revenue per Hectare (us$)	$ 12,434	$ (2,276)	$ (7,870)

Loss Measures *

1. Loss per Hectare (us$)	$ 0	$ 14,710	$ 20.305

2. Loss per Kilogram of Methyl Bromide (us$)	$ 0	$ 55.85	$ 77.09

3. Loss as a Percentage of Gross Revenue (%)	0%	36%	50%

4. Loss as a Percentage of Net Operating Revenue (%)	0%	118%	163%

5. Operating Profit Margin (%)	30%	-6%	-21%

**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.  Production numbers with
iodomethane and the lower use rates in California are still pending.

8.  RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

Table 3:  Nomination Amount (2013)

CITATIONS

CDFA (California Department of Food and Agriculture).  2009.   HYPERLINK
"http://www.cdfa.ca.gov/phpps/PE/Nursery/NIPM.html" 
http://www.cdfa.ca.gov/phpps/PE/Nursery/NIPM.html  

 Regulation for nursery and seed inspection (NIPM #3),   HYPERLINK
"http://www.cdfa.ca.gov//phpps/PE/Nursery/pdfs/nipm_3_regs_nsy_sees_insp
.pdf" 
http://www.cdfa.ca.gov//phpps/PE/Nursery/pdfs/nipm_3_regs_nsy_sees_insp.
pdf ;

 Approved treatment and handling procedures to ensure against nematode
pest infestation of nursery stock (NIPM #7),   HYPERLINK
"http://www.cdfa.ca.gov/phpps/PE/Nursery/pdfs/NIPM_7.pdf" 
http://www.cdfa.ca.gov/phpps/PE/Nursery/pdfs/NIPM_7.pdf  ; CDFA
Strawberry Registration and Certification Program,   HYPERLINK
"http://fpms.ucdavis.edu/Strawberry/CDFAStrawRegs.html" 
http://fpms.ucdavis.edu/Strawberry/CDFAStrawRegs.html 

Fennimore, S. A., Haar, M. J., Goodhue, R. E., and Winterbottom, C. Q.
2008a. Weed control in strawberry runner plant nurseries with methyl
bromide alternative fumigants. HortScience 43(5):1495-1500.

Fennimore, S. A., Duniway, J. M., Browne, G. T., Martin, F. N., Ajwa, H.
A., Westerdahl, B.B., Goodhue, R. E., Haar, M., and Winterbottom, C.
2008b. Methyl bromide alternatives evaluated for California strawberry
nurseries. California Agriculture 62(2):62-67.   HYPERLINK
"http://repositories.cdlib.org/cgi/viewcontent.cgi?article=3194&context=
anrcs/californiaagriculture" 
http://repositories.cdlib.org/cgi/viewcontent.cgi?article=3194&context=a
nrcs/californiaagriculture 

Garcia-Mendez, E., De Cal, A., Melgarejo, P., Salto, T.,
Martinez-Beringola, M. L., Redondo, C., Martinez-Treceno, A., Becerril,
M., Andrade, M. A., Medina, J. J., Soria, C., Lopez-Aranda, J. M., and
Garcia-Sinovas, D. 2007. Strawberry nurseries in Spain: alternatives to
methyl bromide, 2006 results. Annual International Research Conference
on Methyl Bromide Alternatives and Emissions Reductions (2007).  
HYPERLINK
"http://www.mbao.org/2007/Proceedings/063Lopez-ArandaJSpainExperimentsNu
rsery2006.pdf" 
http://www.mbao.org/2007/Proceedings/063Lopez-ArandaJSpainExperimentsNur
sery2006.pdf 

Kabir, Z., Fennimore, S. A., Duniway, J. M., Martin, F. N., Browne, G.
T., Winterbottom, C. Q., Ajwa, H. A., Westerdahl, B. B., Goodhue, R. E.,
and Haar, M. J.  2005.  Alternatives to methyl bromide for strawberry
runner plant production. HortScience 40(6):1709-1715.

Larson, K. D., and Shaw, D.V. 2007. Strawberry nursery soil fumigation
and runner transplant fruit production.  2007 Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions.   HYPERLINK
"http://www.mbao.org/2007/Proceedings/072LarsonKStrawberrynurserysoilfum
igation.pdf" 
http://www.mbao.org/2007/Proceedings/072LarsonKStrawberrynurserysoilfumi
gation.pdf 

Larson, K. D., and Shaw, D.V. 2000. Soil Fumigation and Runner Plant
Production: A Synthesis of 4 Yrs of Strawberry Nursery Field Trials.
HortSci 35(4):642-646.

 The USG does not request methyl bromide for use in areas of low to
moderate pest pressure.  Only cases where key pests are present at
moderate to high levels require methyl bromide for pest pressure.

USA CUN13 Soil Strawberry Nursery Open Field -CA		Page   PAGE  1  of  
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