METHYL BROMIDE CRITICAL USE NOMINATION FOR PREPLANT SOIL USE FOR ORCHARD REPLANT FOR ADMINISTRATIVE PURPOSES ONLY: DATE RECEIVED BY OZONE SECRETARIAT:

YEAR: CUN:

NOMINATING PARTY: The United States of America BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Orchard Replant ( Prepared in 2005)

NOMINATING PARTY CONTACT DETAILS Contact Person: John E. Thompson, Ph. D. Title: International Affairs Officer Address: Office of Environmental Policy U. S. Department of State 2201 C Street N. W. Room 4325 Washington, DC 20520 U. S. A. Telephone: ( 202) 647 9799 Fax: ( 202) 647 5947 E mail: 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: U. S. Orchard Replant ii CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Steve Knizner Title: Acting Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency Mail Code 7503C Washington, DC 20460 U. S. A. Telephone: ( 703) 305 6903 Fax: ( 703) 308 8090 E mail: knizner. steve@ epa. gov LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE LIST ALL PAPER AND ELECTRONIC DOCUMENTS SUBMITTED BY THE NOMINATING PARTY TO THE OZONE SECRETARIAT 1. PAPER DOCUMENTS: Title of Paper Documents and Appendices Number of Pages Date Sent to Ozone Secretariat 2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: Title of Electronic Files Size of File ( kb) Date Sent to Ozone Secretariat U. S. Orchard Replant iii TABLE OF CONTENTS PART A: SUMMARY .................................................................................................................... 8 1. Nominating Party _________________________________________________________ 8 2. Descriptive Title of Nomination______________________________________________ 8 3. Crop and Summary of Crop System___________________________________________ 8 4. Methyl Bromide Nominated _________________________________________________ 9 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 9 6. Summarize Why Key Alternatives Are Not Feasible_____________________________ 11 7. Proportion of Crops Grown Using Methyl Bromide _____________________________ 11 8. Amount of Methyl Bromide Requested for Critical Use __________________________ 13 9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity Nominated for Each Region___________________________________________________________________ 13 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ..................................................................... 14 California Grape and Tree Fruit League   Stone Fruit  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request__________________ 14 California Grape and Tree Fruit League   Stone Fruit  11. Characteristics of Cropping System and Climate_______________________________________________________________ 14 California Grape and Tree Fruit League   Stone Fruit  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ________________________________________________________________________ 16 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT  PART C: TECHNICAL VALIDATION............................................................................................................................. 17 California Grape and Tree Fruit League   Stone Fruit  13. Reason for Alternatives Not Being Feasible __________________________________________________________________ 17 California Grape and Tree Fruit League   Stone Fruit  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ______________________________________________ 19 California Grape and Tree Fruit League   Stone Fruit  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________ 20 California Grape and Tree Fruit League   Stone Fruit  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested _________________________________________ 20 California Grape and Tree Fruit League   Stone Fruit  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? ________________________________________________________________________ 21 California Grape and Tree Fruit League   Stone Fruit  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? ________________ 22 California Grape and Tree Fruit League   Stone Fruit  Summary of Technical Feasibility _ 22 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ..................................................................... 23 California Grape and Tree Fruit League   Raisin & Table Grapes  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request____ 23 U. S. Orchard Replant iv California Grape and Tree Fruit League   Raisin & Table Grapes  11. Characteristics of Cropping System and Climate ________________________________________________ 23 California Grape and Tree Fruit League   Raisin & Table Grapes  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ________________________________________________________________ 25 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES  PART C: TECHNICAL VALIDATION......................................................................................................... 26 California Grape and Tree Fruit League   Raisin & Table Grapes  13. Reason for Alternatives Not Being Feasible _________________________________________________________ 26 California Grape and Tree Fruit League   Raisin & Table Grapes  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ______________________________________ 28 California Grape and Tree Fruit League   Raisin & Table Grapes  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _________ 28 California Grape and Tree Fruit League   Raisin & Table Grapes  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___________________________ 28 California Grape and Tree Fruit League   Raisin & Table Grapes  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide?_________________________________________________________________ 30 California Grape and Tree Fruit League   Raisin & Table Grapes  Summary of Technical Feasibility ________________________________________________________________ 31 CALIFORNIA WALNUT COMMISSION. PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE........................................................................................................................... 32 California Walnut Commission  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request _________________________________ 32 California Walnut Commission  11. Characteristics of Cropping System and Climate ____ 32 California Walnut Commission  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ___________ 34 CALIFORNIA WALNUT COMMISSION  PART C: TECHNICAL VALIDATION............................... 35 California Walnut Commission  13. Reason for Alternatives Not Being Feasible ________ 35 California Walnut Commission  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _________________________________________________________________ 37 California Walnut Commission  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _________________________________________ 37 California Walnut Commission  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___________________________________________________________ 37 California Walnut Commission  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? ______________ 38 California Walnut Commission  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _____________________________________ 39 California Walnut Commission  Summary of Technical Feasibility __________________ 39 U. S. Orchard Replant v ALMOND HULLERS & PROCESSORS ASSOCIATION  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE............................................................................................................ 40 Almond Hullers & Processors Association  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request ________________________ 40 Almond Hullers & Processors Association  11. Characteristics of Cropping System and Climate __________________________________________________________________ 40 Almond Hullers & Processors Association  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested _____ 43 ALMOND HULLERS & PROCESSORS ASSOCIATION  PART C: TECHNICAL VALIDATION ......... 44 Almond Hullers & Processors Association  13. Reason for Alternatives Not Being Feasible 44 Almond Hullers & Processors Association  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide:_________________________________________________________ 46 Almond Hullers & Processors Association  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________ 46 Almond Hullers & Processors Association  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested __________________________________________________ 46 Almond Hullers & Processors Association  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? _________ 48 Almond Hullers & Processors Association  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? ______________________ 48 Almond Hullers & Processors Association  Summary of Technical Feasibility__________ 48 PART D: EMISSION CONTROL .................................................................................................. 49 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 50 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 51 PART E: ECONOMIC ASSESSMENT............................................................................................ 51 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 51 22. Gross and Net Revenue___________________________________________________ 51 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 52 Summary of Economic Feasibility _____________________________________________ 52 PART F. FUTURE PLANS ........................................................................................................... 53 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 53 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 54 25. Additional Comments on the Nomination ____________________________________ 54 26. Citations ______________________________________________________________ 54 APPENDIX A. 2007 METHYL BROMIDE USAGE NUMERICAL INDEX ( BUNI)............................ 57 APPENDIX B. 2006 METHYL BROMIDE RECONSIDERATION FOR ORCHARD REPLANT. ............. 61 U. S. Orchard Replant vi LIST OF TABLES PART A: SUMMARY ____________________________________________________________ 8 Table 4.1: Methyl Bromide Nominated ____________________________________________ 9 Table A. 1: Executive Summary _________________________________________________ 11 Table 7.1: Proportion of Crops Grown Using Methyl Bromide _________________________ 11 Table 8.1: Amount of Methyl Bromide Requested for Critical Use______________________ 13 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _____________________________________________________ 14 California Grape and Tree Fruit League   Stone Fruit  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request _________________________________________ 14 California Grape and Tree Fruit League   Stone Fruit  Table 11.1: Characteristics of Cropping System_________________________________________________________________ 15 California Grape and Tree Fruit League   Stone Fruit  Table 11.2 Characteristics of Climate and Crop Schedule___________________________________________________________ 15 California Grape and Tree Fruit League   Stone Fruit  Table 12.1 Historic Pattern of Use of Methyl Bromide _________________________________________________________ 16 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT  PART C: TECHNICAL VALIDATION_ 17 California Grape and Tree Fruit League   Stone Fruit   Table 13.1: Reason for Alternatives Not Being Feasible___________________________________________________________ 17 California Grape and Tree Fruit League   Stone Fruit   Table 14.1: Technically Infeasible Alternatives Discussion ___________________________________________________ 19 California Grape and Tree Fruit League   Stone Fruit   Table 15.1: Present Registration Status of Alternatives___________________________________________________________ 20 California Grape and Tree Fruit League   Stone Fruit   Table 16.1: Effectiveness of Alternatives   Replant Disorder _______________________________________________________ 20 California Grape and Tree Fruit League   Stone Fruit   Table C. 1: Alternatives Yield Loss Data Summary_______________________________________________________________ 21 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________________________ 23 California Grape and Tree Fruit League   Raisin & Table Grapes  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ________________________________ 23 California Grape and Tree Fruit League   Raisin & Table Grapes  Table 11.1: Characteristics of Cropping System_________________________________________________________ 24 California Grape and Tree Fruit League   Raisin & Table Grapes  Table 11.2 Characteristics of Climate and Crop Schedule ________________________________________________ 24 California Grape and Tree Fruit League   Raisin & Table Grapes  Table 12.1 Historic Pattern of Use of Methyl Bromide ___________________________________________________ 25 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES  PART C: TECHNICAL VALIDATION _____________________________________________________________ 26 California Grape and Tree Fruit League   Raisin & Table Grapes   Table 13.1: Reason for Alternatives Not Being Feasible _____________________________________________ 26 California Grape and Tree Fruit League   Raisin & Table Grapes   Table 15.1: Present Registration Status of Alternatives ___________________________________________ 28 California Grape and Tree Fruit League   Raisin & Table Grapes   Table 16.1: Effectiveness of Alternatives   Replant Disorder ( Nematodes) __________________________________ 29 U. S. Orchard Replant vii California Grape and Tree Fruit League   Raisin & Table Grapes   Table C. 1: Alternatives Yield Loss Data Summary ______________________________________________________ 30 CALIFORNIA WALNUT COMMISSION  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE 32 California Walnut Commission  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request_________________________________________________________ 32 California Walnut Commission  Table 11.1: Characteristics of Cropping System__________ 33 California Walnut Commission  Table 11.2 Characteristics of Climate and Crop Schedule __ 33 California Walnut Commission  Table 12.1 Historic Pattern of Use of Methyl Bromide ____ 34 CALIFORNIA WALNUT COMMISSION  PART C: TECHNICAL VALIDATION_____________________ 35 California Walnut Commission   Table 13.1: Reason for Alternatives Not Being Feasible ___ 35 California Walnut Commission   Table 14.1: Technically Infeasible Alternatives Discussion 37 California Walnut Commission   Table 15.1: Present Registration Status of Alternatives ____ 37 California Walnut Commission   Table 16.1: Effectiveness of Alternatives   Key Pest 1 ____ 37 California Walnut Commission   Table C. 1: Alternatives Yield Loss Data Summary _______ 38 ALMOND HULLERS & PROCESSORS ASSOCIATION  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE____________________________________________________________ 40 Almond Hullers & Processors Association  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request _______________________________________________ 40 Almond Hullers & Processors Association  Table 11.1: Characteristics of Cropping System_ 41 Almond Hullers & Processors Association  Table 11.2 Characteristics of Climate and Crop Schedule _______________________________________________________________ 41 Almond Hullers & Processors Association  Table 12.1 Historic Pattern of Use of Methyl Bromide________________________________________________________________ 43 ALMOND HULLERS & PROCESSORS ASSOCIATION  PART C: TECHNICAL VALIDATION ___________ 44 Almond Hullers & Processors Association   Table 13.1: Reason for Alternatives Not Being Feasible ________________________________________________________________ 44 Almond Hullers & Processors Association   Table 14.1: Technically Infeasible Alternatives Discussion______________________________________________________________ 46 Almond Hullers & Processors Association   Table 15.1: Present Registration Status of Alternatives _____________________________________________________________ 46 Almond Hullers & Processors Association   Table 16.1: Effectiveness of Alternatives   Replant Disorder________________________________________________________________ 47 Almond Hullers & Processors Association   Table C. 1: Alternatives Yield Loss Data Summary _______________________________________________________________________ 47 PART D: EMISSION CONTROL ____________________________________________________ 49 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 50 PART E: ECONOMIC ASSESSMENT _________________________________________________ 51 PART F. FUTURE PLANS ________________________________________________________ 53 APPENDIX A. 2007 Methyl Bromide Usage Numerical Index ( BUNI). __________________ 57 U. S. Orchard Replant Page 8 PART A: SUMMARY 1. NOMINATING PARTY The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION Methyl Bromide Critical Use Nomination for Preplant Soil Use for Orchard Replant ( Prepared in 2005)

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

The typical practice of replanting orchards or vineyards is to remove the old trees after the final harvest and attempting to remove as much of the root system as possible. The soil is fumigated with MB in the late fall and the trees are replanted in late winter. With MB, growers have usually not needed to leave a fallow period between tree removal and the replanting of the new trees. In a minority of orchard replant sites, 1,3 D, sometimes in combination with chloropicrin, can be an alternative to MB. However, it is only effective in orchards with sandy soils where moisture levels at over 1 meter depth are reduced ( and where township restrictions do not apply). When it is used, 1,3 D is applied after removal of old trees, followed by soil U. S. Orchard Replant Page 9 ripping and deep soil drying and then land leveling where needed. Depending on soil texture, availability of preferred new cultivars, and finances of the enterprise, the land is left fallow for one year to accomplish all these activities.

4. METHYL BROMIDE NOMINATED TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG)* NOMINATION AREA ( HA)

2007 405,415 1,219 * Includes research amount 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE The U. S. Nomination is for orchard replant areas where alternatives are not suitable, either because of legal restrictions or physical features, such as unacceptable soil type. For many sites of orchard replant with stone fruit, grapes, walnuts, and almonds in California, MB is a critical tool for establishing healthy, long lived orchards, until results of research trials enable development of protocols for alternatives that can be applied on a commercial scale. Where conditions are acceptable, growers in California currently use alternative measures to manage orchard replant disorder ( Browne et al., 2002b; McKenry, 1999).

In U. S. orchard replant situations there are certain factors that make some alternatives to MB unsuitable. These include:   The efficacy of alternatives may not be sufficient for commercial purposes in some areas, making these alternatives infeasible for use in orchard replant.   Some alternatives may be comparable to MB, especially when key pests occur at low pressure, and in such cases the U. S. is only nominating a CUE where the key pest pressure is moderate to high.   Regulatory constraints, such as 1,3 D limitations in California due to the township caps, make the best alternatives unavailable in some areas.   The best alternative may not be suitable for use in certain soil conditions, such as excessive moisture 1 1.5 m deep.

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

According to an in depth report on orchard replant ( McKenry, 1999), in 1999, at least 85% of U. S. Orchard Replant Page 10 the California walnut acreage was infested with one or more problem nematodes ( Pratylenchus vulnus, Criconemella xenoplax, or Meloidogyne spp.). No rootstocks are currently available that have sufficient resistance to control these pests. About 60% of vineyards are infested with problem nematodes, although tolerant rootstocks can help ameliorate the replant problem for some nematodes. However, vineyards are also susceptible to Phylloxera and Armillaria root rots. At least 60% of cling peach areas are infested with Criconemella xenoplax and another 35% of stone fruit plantings are infested with P. vulnus or C. xenoplax. Around 35% of almond plantings are infested with C. xenoplax and/ or P. vulnus; 15% of almond orchards are infected with bacterial canker, and 5% are infected with oak root fungus.

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

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

Prior to 1990, 1,3 D was considered at least as good as MB for treatment of replant problem ( McKenry, 1999). However, due to environmental and health concerns ( it is a B2 carcinogen and was found off of treatment sites), 1,3 D was banned, and MB became the predominant treatment for orchard replant. With the re labeling of 1,3 D in the mid 1990s there were new restrictions on its use and application, including township caps in California. The reduced rates were considered ineffective for some severe replant situations ( reduced to 325 kg/ ha from 427 kg/ ha). MB, therefore, remains the standard for the industry when establishing nearly all of California's orchards, except in those with light soils and with appropriate moisture conditions, where lower rates of 1,3 D can be effective ( McKenry, 1999). [ Each township is allowed a maximum of approximately 41,000 kg per year, in a township of approximately 9300 ha; at 225 kg/ ha, 180 ha can be treated with 1,3 D per township.] U. S. Orchard Replant Page 11 TABLE A. 1: EXECUTIVE SUMMARY Region California Grape and Tree Fruit League   Stone Fruit California Grape and Tree Fruit League   Raisin & Table Grapes California Walnut Commission Almond Hullers & Processors Association AMOUNT OF APPLICANT REQUEST 2007 Kilograms 716,449 165,561 226,796 206,384 AMOUNT OF NOMINATION*

2007 Kilograms 267,531 26,356 30,205 79,664 * See Appendix A for a complete description of how the nominated amount was calculated.

6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

The best alternative for the orchard replant sector is 1,3 D or 1,3 D with chloropicrin, and/ or metam sodium, especially in light soils or under minimum disease pressure. Under some soil and moisture conditions ( high moisture at surface and less than 12% at 1 1.5 meters) 1,3 D can act as an effective management tool for replant problems. However, there is a critical need for MB in some orchards in California, either because of legally mandated township caps for 1,3 D, or because surface moisture requirements can not be met ( e. g., soils can not be adequately dried prior to use of 1,3 D). With almonds in recent years, between 2% and 21% of replant sites were fumigated with MB, while walnuts in 21,316 hectares ( only about 1/ 3 of the area is actually treated in strip applications) had MB applications in 2001 ( see Section 17   Walnuts, below). In the same year, 1,3 D was applied to 113 hectares and metam sodium was applied to 28 hectares.

7. ( i) PROPORTION OF CROPS GROWN USING METHYL BROMIDE TABLE 7.1: PROPORTION OF CROPS GROWN USING METHYL BROMIDE REGION WHERE METHYL BROMIDE USE IS REQUESTED AVERAGE TOTAL REPLANT AREA IN 2001 AND 2002 ( HA) [ AREA OF MB USE/ TOTAL AREA REPLANTED PER YEAR] PROPORTION OF TOTAL REPLANT AREA TREATED WITH METHYL BROMIDE PER YEAR (%)

California Grape and Tree Fruit League   Stone Fruit Not available Not available California Grape and Tree Fruit League   Raisin & Table Grapes Not available Not available California Walnut Commission Not available Not available Almond Hullers & Processors Association 496/ 5900 ( 2001) 820/ 3992 ( 2002) 278/ 12,502 ( 2003) a 8% ( 2001) 21% ( 2002) 2% ( 2003) a NATIONAL TOTAL: Not available U. S. Orchard Replant Page 12 a 2003 data based on preliminary reports to California Department of Pesticide Regulation.

7. ( ii) IF ONLY PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL BROMIDE THERE.

Some areas of California are amenable to these crops and have soil types and moisture characteristics that allow the use of alternative treatments. 1,3 D and chloropicrin can be an effective alternative to MB in areas with soils that contain less than 12% moisture at 1.5 meters and can be sufficiently moistened in the top 30 cm. Areas considered in this nomination have either regulatory or other reasons ( e. g., soil type) that prevent alternatives from acting effectively in successfully managing replant disorder. Until protocols are developed for commercial application of effective alternatives, MB is critical for successful orchard replant.

7. ( iii) WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE THIS?

Generally, it will be difficult to expand the use of the best alternative, 1,3 D, to a greater percent of orchard replant situations because of physical and legal restrictions. First, at current label rates, 1,3 D can be effective in light soils, but not medium to heavy soils where moisture content below 1 1.5 meters and on the surface reduces the number of effective sites. Secondly, only if township cap limitations were reduced would there be a likelihood that 1,3 D could supplant the critical need for MB in many orchards. This is not a realistic scenario given environmental and health concerns for 1,3 D ( as well as metam sodium) in California. Furthermore, prior to label cancellation in 1990, 1,3 D was used at a higher rate ( 427 kg/ ha) than the current maximum label rate ( 375 kg/ ha), established after its reintroduction for perennials in 1996 ( McKenry, 1999). The higher rate was considered significantly more effective than the current rate ( where 1,3 D is allowed under township cap restrictions). Rates are unlikely to be increased due to the probable carcinogenic nature of 1,3 D ( B2 carcinogen). Aside from township caps, efficacy of 1,3 D is highly dependent on soil type, requiring light soils to be most effective at the current label rates. Because research is making significant gains in knowledge of alternatives ( e. g., Browne et al., 2004; Lampinen et al., 2004; Schneider et al., 2004), it may be possible to improve the efficacy of some alternatives by improving application technologies in conjunction with crop rotation, fallowing, rootstock, or use of VIF ( use is regulated in California). But these advances will require further research before commercial use in areas where MB is currently critical. U. S. Orchard Replant Page 13 8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE TABLE 8.1. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION California Grape and Tree Fruit League   Stone Fruit California Grape and Tree Fruit League   Raisin & Table Grapes California Walnut Commission Almond Hullers & Processors Association YEAR OF EXEMPTION REQUEST 2007 2007 2007 2007 KILOGRAMS OF METHYL BROMIDE 716,449 165,561 226,796 206,388 USE: FLAT FUMIGATION a OR STRIP/ BED TREATMENT Usually flat fumigation Flat fumigation Flat fumigation Usually flat fumigation FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 98: 2 98: 2 98: 2 98: 2 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( ha) 2,131 433 809 567 APPLICATION RATE* b, c ( kg/ ha) [ ACTIVE INGREDIENT] 336 382 280 364 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT 33.6 38.2 28 36.4 * For Flat Fumigation treatment application rate and dosage rate may be the same. a California Grape and Tree Fruit League   Stone Fruit Various methods are used depending on the particular location, fumigation can be flat fumigation, strip, or even " by the hole" ( for individual tree replacement; MB is the only product that has acceptable technology for hole application   approximately 0.5 kg/ tree). Strip fumigation would comprise approximately 65% of the total area that is actually fumigated. b California Grape and Tree Fruit League   Stone Fruit Requested rate of 219 kg/ ha is dose rate ( 21.9 g/ m2) rather than rate applied as if entire hectare were treated ( 335 kg/ ha). c Almond Hullers & Processors Association Various methods are used depending on the particular location, fumigation can be Flat Fumigation, strip, or even " by the hole" ( for individual tree replacement; MB is the only product that has acceptable technology for hole application   approximately 0.5 kg/ tree). Strip fumigation would comprise approximately 65% of the total area that is actually fumigated.

9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION:

The amount of MB nominated by the U. S. was calculated as follows:   The percent of regional hectares in the applicant's request was divided by the total area planted in that crop in the region covered by the request.   Hectares counted in more than one application or rotated within one year of an application to a crop that also uses MB were subtracted. There was no double counting in this sector.   Growth or increasing production ( the amount of area requested by the applicant that is greater than that historically treated) was subtracted.   Only the area experiencing one or more of the following impacts were included in the nominated amount: moderate to heavy key pest pressure, regulatory impacts, and unsuitable soils. U. S. Orchard Replant Page 14 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT 10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY PESTS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED California Grape and Tree Fruit League   Stone Fruit Replant problem is a disease complex comprised of interactions between various pathogens and environmental factors. Nematodes ( Primary pests): Meloidogyne ( root knot); Criconemella ( ring); Xiphinema ( dagger); Pratylenchus ( root lesion); and Tylenchulus ( citrus) Pathogens: Armellaria, Phytophthora, and various fungi, depending on orchard location and conditions that are thought to contribute to orchard replant disorder. Insect: Pollyphylla decemlineata ( Tenlined June beetle) Some alternatives, such as 1,3 D and chloropicrin, may be effective in reducing the effects of orchard replant disorder where there is low disease pressure or where there are no legal restriction in light, sandy loam soils, and where there is acceptable soil moisture. In other situations, where soils are medium to heavy, or where township caps are applicable, MB is currently the only single compound that can effectively target root remnants from previous orchard trees. Strategies that include multiple techniques, such as use of herbicides and nematicides, have the potential to reduce pest problems in orchard replant. However, these combination techniques must first be tested and proven so as not to compromise orchard productivity. Short term fallow along with nematode tolerant rootstock peach seedlings have looked promising in research trials ( e. g., Browne, 2003b).

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE The typical practice of replanting orchards with MB is to remove the old trees after the final harvest ( typically 20 25 years after planting). The soil is harrowed and the remaining roots are removed. The soil is fumigated in the late fall and the trees are replanted in the early winter. When using MB growers have traditionally not needed to leave a fallow period between tree removal and the replanting of the new trees.

The typical practice of replanting orchards with 1,3 D + chloropicrin ( the best alternative where conditions permit), is to remove the old trees after harvest and as many of the roots as time and resources permit. After the removal of the old trees the soil is ripped and then irrigated to allow the soil to settle. Any roots that are pulled to the surface are removed, and the soil is graded. Due to the late harvest of the stone fruit crops there is not generally a fallow period between the removal of the old trees and replanting with new trees. U. S. Orchard Replant Page 15 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS California Grape and Tree Fruit League   Stone Fruit CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Stone fruit trees for production ANNUAL OR PERENNIAL CROP: (# of years between replanting) Perennial ( 20 25 years)

TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) None; however, short term fallow along with nematode tolerant rootstock peach seedlings have looked promising in research trials ( e. g., Browne, 2003b).

SOIL TYPES: ( Sand, loam, clay, etc.) Varied ( light, medium, heavy)

FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once in life of orchard ( 20 25 years), until replant with new orchard OTHER RELEVANT FACTORS: None identified CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA plant hardiness zones 9a, 9b RAINFALL ( mm) 16 72.1 17.3 0 trace 1.0 trace 0 44.7 56.9 9.9 30.5 OUTSIDE TEMP. ( ° C) 14.4 14.8 20.8 25.7 30.3 27.4 25.1 18.4 13.4 9.6 10.3 10.6 FUMIGATION SCHEDULE 1st year, land preparation and fumigation; no additional fumigation for life of orchard (~ 20 years) PLANTING SCHEDULE Occurs 2nd year, after fumigation KEY MARKET WINDOW: Not applicable * For Fresno, California.

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Orchard replant into previously planted orchard land ( the typical situation in California) requires reducing pathogen populations ( mostly nematodes and fungi) and nutrient sources of previous orchard tree roots and root remnants. This requires an effective material that is volatile and can penetrate into the soil to reach these plant materials. In sandy, loam soils, where restrictions do not apply, 1,3 D may be an acceptable alternative that can penetrate to the target areas. In other situations, this compound and other alternatives are not able to move sufficiently through the soil to remove the problem pests. Thus, there is a critical need for MB not only for the stone fruit consortium, but for other consortia of this sector. The infrequent use of MB ( once in 25 40 years) and the positive benefits of vigorous early tree growth make MB a key component of orchard fruit and nut production. U. S. Orchard Replant Page 16 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT 12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 2,815 3,522 1,723 1,063 1,169 Not available RATIO OF FLAT FUMIGATION a METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Usually flat fumigation [ if strip   65% of area is treated] Usually flat fumigation [ if strip   65% of area is treated] Usually flat fumigation [ if strip   65% of area is treated] Usually flat fumigation [ if strip   65% of area is treated] Usually flat fumigation [ if strip   65% of area is treated] Not available AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 946,612 1,184,391 579,254 357,558 392,717 Not available FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 98: 2 98: 2 98: 2 98: 2 98: 2 Not available METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Shank injected Shank injected Shank injected Shank injected Shank injected Not available APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 336 336 336 336 336 Not available ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 33.6 33.6 33.6 33.6 33.6 Not available * For Flat Fumigation treatment application rate and dosage rate may be the same. a Various methods are used depending on the particular location, fumigation can be Flat Fumigation, strip, or even " by the hole" ( for individual tree replacement; MB is the only product that has acceptable technology for hole application   approximately 0.5 kg/ tree). U. S. Orchard Replant Page 17 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. PART C: TECHNICAL VALIDATION CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Chloropicrin Has activity as a fungicide and may be useful if fungi are significant causal agents of replant disorder ( Trout et al., 2002); generally will not reduce nematodes significantly and they are major cause of replant disorder; may have phytotoxicity problems at rates that are effective against pests ( Browne et al., 2002a) Alone, not effective for nematode problems 1,3 dichloropropene ( 1,3 D) Most orchards fall in areas with township cap restrictions on use of 1,3 D. May be effective where township caps do not apply and where soil moisture and texture are such that 1,3 D can penetrate to remnant tree roots of previous orchard. Where legal restrictions are in place and/ or where soils are medium to heavy, 1,3 D does not effectively control nematodes associated with replant disorder. Comparative yield with 1,3 D were valued at 5585 kg/ ha versus 8903 kg/ ha with MB ( Duncan et al, 2003). At US$ 0.30 per kg peaches, this represents a significant economic impact. Only with light soils, if no legal restrictions apply Metam sodium May be effective in killing root tissue near soil surface, but will not kill roots below 75 cm when metam sodium is applied at label rates; not an effective nematicide since it can not reach deep areas of soil, which is the primary cause of orchard replant problems; generally not effective in areas where water percolation is a problem ( e. g., clay soils). However, in the future, new delivery systems could increase effectiveness of this compound to make it a more acceptable alternative to MB ( where soil conditions are amenable to its use). Reducing time in which material can diffuse throughout target area will improve efficacy ( McKenry, 1999); generally not effective in areas where water percolation is a problem ( e. g., clay soils). Comparative yield with metam sodium were valued at 6880 kg/ ha versus 8903 kg/ ha with MB ( Duncan et al, 2003). At US$ 0.30 per kg peaches, this represents a significant economic impact. No Dazomet This alternative has been examined by researchers and is inconsistent in field trials. This has been deemed not feasible due to lack of performance in field trials and inability to penetrate and kill nematodes at depths required for orchard replant acceptability. This product requires that there be uniform saturation of the granules to ensure that the product will perform consistently. This is not feasible in a typical orchard situation. This product "  will not be successful until more is known about the dissolution rate of the granules" ( McKenry, 1999). No U. S. Orchard Replant Page 18 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE? Nematicides Other nematicides ( besides 1,3 D) have limited use due to their lack of performance or due to regulatory issues. Therefore, this product was deemed not feasible No NON CHEMICAL ALTERNATIVES Fallow Not sufficient alone; frequently done for 1 year regardless of fumigant that follows; may require 4 10 year fallow for some crops ( McKenry, 1999) and may not be sufficient even then; may provide partial control in some crops, however, economically difficult for grower to sustain ( Browne et al., 2002b; Trout et al., 2002). However, short term fallow along with nematode tolerant rootstock peach seedlings have looked promising in research trials ( e. g., Browne, 2003b, 2004). No Rootstock Genetic factors are known that confer some tolerance for orchard replant problems   for example, in one study an orchard with Marianna 2624 Plum rootstock was not as sensitive as an orchard with Nemaguard peach rootstock ( McKenry, 1999). This is in spite of the resistance of Nemaguard to reproduction of root knot nematodes   however, feeding on Nemaguard roots were aided by reproduction on remnant roots causing significant replant problem. Rootstocks for all of the commodities in this sector are subject to differential effects from soil and other environmental factors, as well as the array of pests that comprise individual orchards. Consequently, rootstock can only be considered a component of an overall orchard management plan, and not a solution to the replant problem. However, short term fallow along with nematode tolerant rootstock peach seedlings have looked promising in research trials ( e. g., Browne, 2003b, 2004). No Biofumigation, solarization, steam, biological control, cover crops and mulching, Crop rotation / fallow, crop residue and compost, substrate/ plug plants, plowing/ tillage, resistant cultivars, grafting/ resistant rootstock, physical removal, organic amendments/ compost, general IPM Each of the not in kind alternatives were listed as options for replacement of MB. Many of these alternatives are currently being employed with current replant practices. Alternatives such as biofumigation, solarization, and steam are not feasible due to planting times, one time fumigation requirement per orchard ( steam treatment), or inability to attain sufficient biomass of plant material ( biofumigation). Biological control may have promise but research has not identified agents that can be used on a commercial scale or that work consistently well. The University of California is investigating biological control of major fungal pathogens, but this work is still in the early stages of research. As such, MB is currently considered critical to the industry. No U. S. Orchard Replant Page 19 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin 1,3 D + chloropicrin + metam sodium 1,3 D + metamsodium Effective against nematodes, fungi, and to kill remnant roots when 1,3 D is used in orchards with light soils; not feasible in medium or heavy soils; subject to township caps and specific moisture requirements. Promising results from research trials indicated that efficacy may be improved by refining application protocols and use rates ( see e. g., Browne et al., 2003a, 2004). Possibly, after further research that will optimize application methods, if no legal restrictions apply and where soil type is amenable * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Herbicides ( e. g., triclopyr, glyphosate) Not effective treatment alone. Herbicides are used for killing remnant roots of previous orchard plants; research with walnuts ( McKenry, 1999) suggested that herbicide treatment followed by 18 months fallow can result in root knot nematode control of 97% compared to untreated plots. However, this effect only lasted 6 months, not long enough to achieve acceptable establishment of new orchard; no herbicides were found that kill grape roots ( McKenry, 1999). In stone fruit, while remnant roots were killed after 18 months, endoparasitic nematodes were not significantly reduced ( McKenry et al., 1995). The combination of herbicide costs plus additional 18 months waiting period prior to planting, becomes an economic burden, especially with the limited effectiveness of treatment. U. S. Orchard Replant Page 20 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Sodium azide No registration package has been submitted No Unknown Propargyl bromide No registration package has been submitted No Unknown Iodomethane Not registered in U. S. Yes Unknown CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   REPLANT DISORDER KEY PEST: REPLANT DISORDER AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF TRIALS DISEASE (% OR RATING) # OF TRIALS ACTUAL YIELDS ( T/ HA) CITATION [ 1] MB ( 400 kg/ ha) [ 2] 1,3 D ( 350 kg/ ha) + metamsodium ( 125 kg/ ha) [ 3] 1 year fallow ( non fumigated) [ 4] non fumigated Peach, fumigation Fall, 1997; Replant, Spring, 1998; 4 reps, research plots Trunk diameter ( mm for MB trt; and % of MB value); Aug. 2002: [ 1] 114a [ 2] 92% ab [ 3] 86% bc [ 4] 81% c Same Market Yield ( kg/ tree MB trt; and % of MB value); Aug. 2002: [ 1] 38a [ 2] 100% a [ 3] 93% a [ 4] 86% a Trout et al., 2002 [ 1] MB ( 400 kg/ ha) [ 2] 1,3 D ( 260 kg/ ha) + chloropicrin ( 150 kg/ ha) + metam sodium ( 63 kg/ ha) [ 3] 1 year fallow ( non fumigated) [ 4] non fumigated Peach, fumigation Fall, 1998; Replant, Spring, 1999; 4 reps, research plots Trunk diameter ( mm for MB trt; and % of MB value); Aug. 2002: [ 1] 94.1a [ 2] 102% a [ 3] 89% b [ 4] 82% b Same Market Yield ( kg/ tree MB trt; and % of MB value); July, 2002: [ 1] 30ab [ 2] 109% a [ 3] 87% bc [ 4] 75% c Trout et al., 2002 U. S. Orchard Replant Page 21 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D ( 385 kg/ ha) Nematodes, roots 0 20% ( based on research plots) 10% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) + metam sodium ( 65 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots) 1,3 D ( 350 kg/ ha) + metam sodium ( 125 kg/ ha) Nematodes, roots 0 10% ( based on research plots) 5% ( based on research plots)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS See discussion below No alternatives are currently feasible in numerous orchard replant sites ( i. e., those with medium to heavy soils) and/ or where township cap restrictions apply. In these cases losses of trees are likely to be greater than 20% ( McKenry, 1999). Listed above are alternatives for sites where soils are amenable to 1,3 D and where township caps are not applicable.

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

In situations with light soil, and water available to moisten the top 30 cm of soil, 1,3 D with chloropicrin or metam sodium can be effective treatments for orchard replant problems. In medium or heavy soils, high moisture content below 1 to 1.5 meters usually reduces the efficacy of 1,3 D and precludes its use. MB is, therefore, critical since no other treatment has been proven to exhibit such a positive effect on achieving a healthy orchard for 20 25 years of production. Fallowing and crop rotation studies ( Browne et al., 2003b, 2004) suggest orchard replant disorder can be reduced with certain crop rotations, but further studies are needed to test on a commercial scale. Nematode control has been short lived ( only up to 6 to 9 months) in some studies ( McKenry, 1999. In a research trial, establishing peach and almond orchards on previous vineyard soil appears to improve orchard establishment regardless of chemical fumigant ( Browne et al., 2004; Lampinen et al., 2004). Tolerant rootstocks with resistance to the primary nematode pests are being developed, but orchard replant disorder is caused by varying factors that are different in different orchard locations and according to the crop grown ( and crop grown prior to the orchard replant). U. S. Orchard Replant Page 22 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. 18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?

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

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   STONE FRUIT. SUMMARY OF TECHNICAL FEASIBILITY For replant situations where alternatives are not effective, MB is considered critical to the healthy establishment of orchards. In those stone fruit orchard replant sites with medium to heavy soils and/ or where township cap restrictions apply losses of trees could be greater than 20% ( McKenry, 1999). Orchard replant problems for all orchard replant sites are a result of biological and environmental causes, and interactions of these forces. Studies of individual pest populations tell only a portion of the story of replant complex, since individual pests cause only a portion of the adverse growth effects. Nevertheless, Criconemella xenoplax infests at least 60% of hectares planted in cling peaches ( McKenry, 1999). An additional 35% of fresh peach, plum, and nectarine plantings are infested with P. vulnus and a somewhat smaller area is infested with C. xenoplax. As such, it is clear that the long life of orchards requires that optimal pest management strategies be employed to overcome replant disorder during the one opportunity available   at orchard establishment. The long history of 1,3 D use in California suggests that at optimal conditions it ( or in combination with another chemical) is the best alternative to MB. However, the reality of California orchard locations precludes some growers from taking advantage of 1,3 D, since either township caps or soil texture/ moisture issues reduce efficacy or legal availability. Therefore, for 2007, for stone fruit replant where alternatives are not effective, there is a critical need for MB for establishment of commercial operations. Currently, research is being conducted examining non fumigant treatments. Some non chemical treatments have shown promise in small scale research trials, such as planting cover crops on previous vineyards ( Browne, 2003b, 2004; Lampinen et al., 2004). Long term studies will have to be conducted before these types of treatments are developed for commercial applications. U. S. Orchard Replant Page 23 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY PESTS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED ( e. g. Effective herbicide available, but not registered for this crop; mandatory requirement to meet certification for disease tolerance)

California Grape and Tree Fruit League   Raisin & Table Grapes Replant problem is a disease complex comprised of interactions between various pathogens and environmental factors. Nematodes ( Primary pests): Meloidogyne ( root knot); Criconemella ( ring); Xiphinema ( dagger); Pratylenchus ( root lesion); and Tylenchulus ( citrus) Pathogens: Armellaria, Phytophthora, and various fungi, depending on orchard location and conditions, that are thought to contribute to orchard replant disorder. Insect: At some sites Pollyphylla decemlineata ( tenlined June beetle) Some alternatives, such as 1,3 D and chloropicrin, may be effective in reducing the effects of orchard replant disorder in vineyards, especially where there is low disease pressure or where there are no legal restriction in light, sandy loam soils, and where there is acceptable soil moisture. For root knot and citrus nematode control, Inline and drip applied 1,3 D have showed good efficacy in research trials ( Schneider et al., 2004). Rootstock " Harmony" has showed good efficacy against rootknot nematodes after six seasons, but poor efficacy against citrus nematodes ( Schneider et al., 2004). In situations where soils are medium to heavy, or where township caps are applicable, MB is the only single compound that effectively targets root remnants from previous orchard trees. Strategies that include multiple techniques, such as use of herbicides and fallow and nematicides, have the potential to reduce pest problems in orchard replant. However, these combination techniques must first be tested and proven so as not to compromise orchard productivity. Some research suggests that long term fallow benefits diminished after four seasons ( Schneider et al., 2004).

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE As in stone fruit orchards, the typical practice of replanting vineyards with MB is to remove the old plantings after the final harvest ( typically 20 25 years after planting). The soil is harrowed and the remaining roots are removed. The soil is fumigated in the late fall and the trees are replanted in the early winter. When using MB growers have traditionally not needed to leave a fallow period between tree removal and the replanting of the new trees.

The typical practice of replanting with 1,3 D + chloropicrin ( the best alternative where conditions permit), is to remove the old plants after harvest and as many of the roots as time and U. S. Orchard Replant Page 24 resources permit. After the removal of the old plants the soil is ripped and then irrigated to allow the soil to settle. Any roots that are pulled to the surface are removed, and the soil is graded.

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Raisins and table grapes ANNUAL OR PERENNIAL CROP: (# of years between replanting) Perennial ( average of 22 year vineyard life)

TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) None SOIL TYPES: ( Sand, loam, clay, etc.) Light FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once in 22 years OTHER RELEVANT FACTORS: The applicant did not identify any other relevant factors.

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA plant hardiness zones 9a, 9b RAINFALL ( mm): 30 60 CM/ YR 16 72.1 17.3 0 trace 1.0 trace 0 44.7 56.9 9.9 30.5 OUTSIDE TEMP. ( ° C) 14.4 14.8 20.8 25.7 30.3 27.4 25.1 18.4 13.4 9.6 10.3 10.6 FUMIGATION SCHEDULE 1st year, land preparation and fumigation; no additional fumigation for life of orchard (~ 22 years) PLANTING SCHEDULE Occurs 2nd year, after fumigation KEY MARKET WINDOW: Not applicable * For Fresno, California CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Replanting vineyards into non virgin areas ( the typical situation in California) requires removing pathogens ( nematodes and fungi) and nutrient sources of previous orchard tree roots and root remnants. This requires an effective material that is volatile and can penetrate into the soil to reach these plant materials. In sandy, loam soils, where restrictions do not apply, 1,3 D may be an acceptable alternative that can penetrate to the target areas. However, in vineyard regions of California, township caps may reduce use of 1,3 D to a fraction of planted vineyard replant situations. U. S. Orchard Replant Page 25 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 316 251 273 67 96 Not available RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Not available AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 124,210 108,035 70,732 18,248 20,193 Not available FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 98: 2 98: 2 Not available Not available Not available Not available METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Shank injected Shank injected Shank injected Shank injected Shank injected Not available APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 393 430 259 271 210 Not available ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 39.3 43.0 25.9 27.1 21.0 Not available * For Flat Fumigation treatment application rate and dosage rate may be the same. U. S. Orchard Replant Page 26 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. PART C: TECHNICAL VALIDATION CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D Where soil moisture is acceptable and township caps are not instituted, 1,3 D may provide sufficient management of replant disorder in vineyards with light soils; usually more effective with chloropicrin. Only with light soils, if no legal restrictions apply Metam sodium Not an effective nematicide since it can not reach deep areas of soil, which is the primary cause of orchard replant problems; generally not effective in areas where water percolation is a problem ( e. g., clay soils); nematodes are the primary pest in the replant disorder complex; generally not effective in areas where water percolation is a problem ( e. g., clay soils). No Chloropicrin Where fungi are primary pest ( requires addition of 1,3 D is nematodes are present) No Dazomet This alternative has not been examined by researchers for vineyards, however, it is likely that problems with this chemical are similar to the stone fruit industry   i. e., it is likely similar to metam sodium in that it would not penetrate and kill nematodes at depths required for orchard replant acceptability. This product requires that there be uniform saturation of the granules to ensure that the product will perform consistently. This likely would not be feasible in a typical vineyard situation. No Nematicides Other nematicides ( besides 1,3 D) have limited use due to their lack of performance or due to regulatory issues. Therefore, this product was deemed not feasible No Sodium tetrathiocarbonate This compound does not penetrate the old roots of the previous vineyard. Old roots then can be a source of inoculum for various fungal and nematodes pests. Therefore, the use of this product alone will not provide adequate control of the pest complex in vineyards. Generally this product is used in combination with other practices that will allow for successful replanting. No U. S. Orchard Replant Page 27 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

NON CHEMICAL ALTERNATIVES Fallow Not sufficient alone; frequently done for 1 year regardless of fumigant that follows; may require 4 10 year fallow for some crops ( Browne, 2002b) and may not be sufficient even then, especially if vineyard viruses, such as grape fan leaf virus ( GFLV) have occurred; may provide partial control in some crops, however, economically difficult for grower to sustain ( McKenry, 1999; McKenry et al., 1995). No Rootstock Some rootstocks are available, such as Teleki 5C or Harmony, which can significantly reduce certain species of nematodes   but no multiple resistance. Used in combination with 1,3 D, significant reductions in rootknot and citrus nematodes have resulted in research tests ( see Schneider et al., 2002, 2003; Ferris and Walker, 2002). No Biofumigation, solarization, steam, biological control, cover crops and mulching, crop rotation / fallow, crop residue and compost, substrate/ plug plants, plowing/ tillage, resistant cultivars, grafting/ resistant rootstock, physical removal, organic amendments/ compost, general IPM Each of the not in kind alternatives were listed as options for replacement of MB. Many of these alternatives are currently being employed with current replant practices ( Schneider et al., 2000). IPM approaches are being extensively investigated ( Schneider et al., 1999). Alternatives such as biofumigation, solarization, and steam are not feasible due to planting times, one time fumigation requirement per orchard ( steam treatment), or inability to attain sufficient biomass of plant material ( biofumigation). Development of durable resistance to nematodes in grape rootstock is an ongoing and challenging area of research ( Ferris and Walker, 2002). Biological control may have promise but research has not identified agents that can be used on a commercial scale or that work consistently well. The University of California is investigating biological control of major fungal pathogens, but this work is still in the early stages of research. As such, MB is currently considered critical to the industry. No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin 1,3 D + chloropicrin + metam sodium 1,3 D + metamsodium Effective against nematodes, fungi, and to kill remnant roots when 1,3 D is used in orchards with light soils; not feasible in medium or heavy soils; subject to township caps and specific moisture requirements. Promising results from research trials indicated that efficacy may be improved by refining application protocols and use rates ( see e. g., Schneider, 2004). Possibly, after further research that will optimize application methods, if no legal restrictions apply and where soil type is amenable * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. U. S. Orchard Replant Page 28 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

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

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Sodium azide Not registered in U. S., no registration package has been received No Unknown Propargyl bromide Not registered in U. S., no registration package has been received No Unknown Iodomethane Not registered in U. S. Yes Unknown CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED U. S. Orchard Replant Page 29 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   REPLANT DISORDER ( NEMATODES). KEY PEST: REPLANT DISORDER ( NEMATODES)

METHYL BROMIDE FORMULATIONS AND ALTERNATIVES ( include dosage rates and application method) # OF TRIALS DISEASE (% OR RATING) CITATION [ 1] not fumigated [ 2] MB ( 455 kg/ ha) [ shanked, tarp] [ 3] metam sodium ( 125 kg/ ha) [ microspray] [ 4] InLine + metam sodium ( 125 kg/ ha) [ microspray] [ 5] chloropicrin ( 455 kg/ ha) [ drip] + metam sodium ( 125 kg/ ha) [ microspray] 5 reps; grapes Meloidogyne spp. (#/ 100 cc soil) ( trial planted and sampled 2001)

[ 1] 324a [ 2] 0c [ 3] 290a [ 4] 0c [ 5] 8b Tylenchulus semipenetrans (#/ 100 cc soil) ( trial planted and sampled 2001) [ 1] 121a [ 2] 0c [ 3] 157a [ 4] 0c [ 5] 2bc Schneider et al., 2002 Meloidogyne spp. per 100 cc soil ( trial planted 1998, sampled 2001)

Thompson seedless rootstock Teleki 5C rootstock Harmony rootstock [ 1] not fumigated [ 2] 1 year fallow [ 3] 1 year fallow + cover crop [ 4] MB ( 455 kg/ ha) [ shanked, tarp] [ 5] 1,3 D ( 352 kg/ ha) [ in 60 mm water] + metam sodium ( 125 kg/ ha) [ microspray] [ 6] 1,3 D ( 352 kg/ ha) [ in 100 mm water] + metam sodium ( 125 kg/ ha) [ microspray] 5 reps; grapes [ 1] 144ab [ 2] 215a [ 3] 145ab [ 4] 1def [ 5] 0.2ef [ 6] 6cde [ 1] 261a [ 2] 49b [ 3] 190a [ 4] 0.3c [ 5] 0.6c [ 6] 0.2c [ 1] 0.8a [ 2] 0.0a [ 3] 0.1a [ 4] 0.0a [ 5] 0.0a [ 6] 0.0a Schneider et al., 2002 Tylenchulus semipenetrans per 100 cc soil ( trial planted 1998, sampled 2001)

Thompson seedless rootstock Teleki 5C rootstock Harmony rootstock [ 1] not fumigated [ 2] 1 year fallow [ 3] 1 year fallow + cover crop [ 4] MB ( 455 kg/ ha) [ shanked, tarp] [ 5] 1,3 D ( 352 kg/ ha) [ in 60 mm water] + metam sodium ( 125 kg/ ha) [ microspray] [ 6] 1,3 D ( 352 kg/ ha) [ in 100 mm water] + metam sodium ( 125 kg/ ha) [ microspray] 5 reps; grapes [ 1] 638a [ 2] 352a [ 3] 463a [ 4] 0.4c [ 5] 3c [ 6] 6b [ 1] 301a [ 2] 434a [ 3] 342a [ 4] 4b [ 5] 1b [ 6] 3b [ 1] 913a [ 2] 1123a [ 3] 723a [ 4] 2b [ 5] 6b [ 6] 7b Schneider et al., 2002 U. S. Orchard Replant Page 30 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D ( 385 kg/ ha) Nematodes, roots 0 20% ( based on research plots) 10% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) + metam sodium ( 65 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots)

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

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS See discussion below No alternatives are currently feasible in numerous orchard replant sites ( i. e., those with medium to heavy soils) and/ or where township cap restrictions apply. In these cases losses of trees are likely to be greater than 20% ( McKenry, 1999). Listed above are alternatives for sites where soils are amenable to 1,3 D and where township caps are not applicable.

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

In situations with light soil, and water available to moisten the top 30 cm of soil, 1,3 D with chloropicrin or metam sodium can be effective treatments for replant problems. However, in medium or heavy soils, high moisture content below 1 to 1.5 meters usually reduces the efficacy of 1,3 D and precludes its use. MB is, therefore, critical since no other treatment has been proven to exhibit such a positive effect on achieving a healthy vineyard for 20 25 years of production. Alternatives that are being investigated include fallowing studies ( frequently with prior treatment with an herbicide to kill remnant roots from previous plantings). Thus far, nematode control is short lived ( only up to 6 to 9 months) ( McKenry, 1999). Rootstock with resistance to the primary nematode pests are being developed, but orchard replant disorder is caused by varying factors that are different in different orchard locations and according to the crop grown ( and crop grown prior to the orchard replant). U. S. Orchard Replant Page 31 CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. 18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?

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

CALIFORNIA GRAPE AND TREE FRUIT LEAGUE   RAISIN & TABLE GRAPES. SUMMARY OF TECHNICAL FEASIBILITY Less than 1% of the total area planted to raisin and table grapes is subject to replanting ( and, therefore, MB) every year. In these cases losses of vines are likely to be greater than 20% ( McKenry, 1999) without MB. As with all replant sites, orchard replant problems for vineyards are a result of biological and environmental causes, and probably interactions of these forces. Studies of individual pest populations tell only a small portion of the story of replant complex, since individual pests cause only a portion of the adverse growth effects. In situations with an identified pest, such as rootknot nematodes, there are promising resistant ( or tolerant) rootstocks that may help alleviate the problem ( e. g., Schneider et al, 2003, 2004); long term fallow did not appear to reduce nematode populations in field trials.

It is clear that the long life of vineyards requires that optimal pest management strategies be employed to overcome replant disorder during the one opportunity available   at time of establishment. The long history of 1,3 D use in California suggests that at optimal conditions it ( or in combination with another chemical) is the best alternative to MB. However, the reality of California orchard and vineyard locations precludes the majority of growers taking advantage of the material since either township caps or soil texture/ moisture issues reduce efficacy or legal availability to 1,3 D. Therefore, for 2007, for vineyard replant where alternatives are not effective, there is a critical need for MB for establishment of commercial operations. U. S. Orchard Replant Page 32 CALIFORNIA WALNUT COMMISSION. PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA WALNUT COMMISSION. 10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA WALNUT COMMISSION. TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY PESTS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED California Walnut Commission ( Central Valley and coastal valleys) Replant problem caused by interactions of pests and environment, primarily Nematodes: ( in ~ 85% of orchards) Pratylenchus vulnus, Mesocriconema xenoplax, Meloidogyne spp. Township caps and unacceptable soil moisture (> 12% at over 1 meter depths in medium and heavy soils) limit 1,3 D use ( the best alternative) to approximately only 30% of orchard land.

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

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

CALIFORNIA WALNUT COMMISSION. 11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE The typical practice of replanting orchards with MB is to remove the old trees after the final harvest ( typically 30 40 years   and sometimes longer   after planting). The soil is harrowed and the remaining roots are removed. The soil is fumigated in the late fall and the trees are replanted in the early winter. When using MB growers have traditionally not needed to leave a fallow period between tree removal and the replanting of the new trees.

When using 1,3 D + chloropicrin ( the best alternative where conditions permit), the old trees are removed with as many of the roots as time and resources permit. After the removal of the old trees the soil is ripped and then irrigated to allow the soil to settle. Any roots that are pulled to the surface are removed, and the soil is graded. U. S. Orchard Replant Page 33 CALIFORNIA WALNUT COMMISSION. TABLE. 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS REGION B CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) English walnuts on black/ Paradox rootstocks ANNUAL OR PERENNIAL CROP: (# of years between replanting) Perennial TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) None SOIL TYPES: ( Sand, loam, clay, etc.) Light ( 30%), medium ( 40%), heavy ( 30%)

FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once in orchard life ( up to 40 years)

OTHER RELEVANT FACTORS: No other relevant factors were identified by the applicant.

CALIFORNIA WALNUT COMMISSION. TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA plant hardiness zones 9a, 9b RAINFALL ( mm): 30 60 CM/ YR 16 72.1 17.3 0 trace 1.0 trace 0 44.7 56.9 9.9 30.5 OUTSIDE TEMP. ( ° C) 14.4 14.8 20.8 25.7 30.3 27.4 25.1 18.4 13.4 9.6 10.3 10.6 FUMIGATION SCHEDULE 1st year, land preparation and fumigation; no additional fumigation for life of orchard (~ 40 years) PLANTING SCHEDULE Occurs 2nd year, after fumigation KEY MARKET WINDOW: Not applicable * For Fresno, California CALIFORNIA WALNUT COMMISSION. 11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

In approximately 70% of walnut orchard situations ( Central Valley and coastal valleys in California) surface soil moisture and restrictions due to township caps, make the best alternative, 1,3 D, unlikely to replace MB for 2007. U. S. Orchard Replant Page 34 CALIFORNIA WALNUT COMMISSION. 12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA WALNUT COMMISSION. TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 249 348 89 Not available Not available Not available RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat fumigation Not available AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 111,518 156,162 39,687 24,308 (?) 59,643 (?) Not available FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 98: 2 98: 2 98: 2 Not available Not available Not available METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) shank injected shank injected shank injected Not available Not available Not available APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 448 448 448 Not available Not available Not available ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 44.8 44.8 44.8 Not available Not available Not available * For Flat Fumigation treatment application rate and dosage rate may be the same. U. S. Orchard Replant Page 35 CALIFORNIA WALNUT COMMISSION. PART C: TECHNICAL VALIDATION CALIFORNIA WALNUT COMMISSION. 13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA WALNUT COMMISSION. TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D With appropriate soil type and moisture conditions, an effective nematicide, usually more effective for orchard replant problems with chloropicrin for added fungicidal activity; also is relatively effective in killing remnant roots from previous orchard planting; however, subject to strict township caps and specific moisture requirements. Typically will be formulated with chloropicrin. With conducive soils, if no legal restrictions apply Chloropicrin May perform acceptably alone when fungi are primary cause of orchard replant problem; for nematode causation, presence of 1,3 D is necessary. No Metam sodium Not an effective nematicide since it can not reach deep areas of soil, which is the primary cause of orchard replant problems; generally not effective in areas where water percolation is a problem ( e. g., clay soils); however, can sometimes kill remnant tree roots that harbor nematodes, but legal label rates ( 363 kg/ ha) generally can only kill roots above the surface 75 cm ( McKenry, 1999); below this level, nematodes populations survived. Generally not effective in areas where water percolation is a problem ( e. g., clay soils). No Dazomet This alternative has been examined by researchers and is inconsistent in field trials. This has been deemed not feasible due to lack of performance in field trials and inability to penetrate and kill nematodes at depths required for orchard replant acceptability. This product requires that there be uniform saturation of the granules to ensure that the product will perform consistently. This is not feasible in a typical orchard situation. No Nematicides Other nematicides ( besides 1,3 D) have limited use due to their lack of performance or due to regulatory issues. Therefore, this product was deemed not feasible No U. S. Orchard Replant Page 36 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

NON CHEMICAL ALTERNATIVES Fallow Not sufficient alone; frequently done for 1 year regardless of fumigant that follows; may require 4 10 year fallow for some crops ( McKenry, 1999); may provide partial control in some crops, however, economically difficult for grower to sustain ( Browne et al., 2002b; Trout et al., 2002); might be used following herbicide treatment but is additional expense for reduced efficacy compared to more effective fumigants. No Resistant rootstock No commercially acceptable rootstocks are currently available that have resistance to nematodes ( McKenry, 1999) No Biofumigation, solarization, steam, biological control, cover crops and mulching, crop rotation / fallow, crop residue and compost, substrate/ plug plants, plowing/ tillage, resistant cultivars, grafting/ resistant rootstock, physical removal, organic amendments/ compost, general IPM Each of the not in kind alternatives were listed as options for replacement of MB. Many of these alternatives are currently being employed with current replant practices. Alternatives such as biofumigation, solarization, and steam are not feasible due to planting times, one time fumigation requirement per orchard ( steam treatment), or inability to attain sufficient biomass of plant material ( biofumigation). Biological control may have promise but research has not identified agents that can be used on a commercial scale or that work consistently well. The University of California is investigating biological control of major fungal pathogens, but this work is still in the early stages of research. As such, MB is currently considered critical to the industry No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin Only with light soils, if no legal restrictions apply 1,3 D + metamsodium Only with light soils, if no legal restrictions apply 1,3 D + chloropicrin + metam sodium 1,3 D mixtures can be effective in light soils in areas with no legal restrictions [ in walnuts, probably only 30% of orchard replant situations ( McKenry, 1999)]; or situations where moisture levels are acceptable ( requires less that 12% at depths of up to 1.5 meters, and sufficient moisture at surface to disperse compounds, while reducing emissions); restrictions reduce orchard sites where 1,3 D is feasible option; in heavy soils 1,3 D is not a feasible alternative Only with light soils, if no legal restrictions apply * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. U. S. Orchard Replant Page 37 CALIFORNIA WALNUT COMMISSION. 14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

CALIFORNIA WALNUT COMMISSION REGION C. TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Herbicides ( e. g., triclopyr, glyphosate) Not effective treatment alone. Herbicides are used for killing remnant roots of previous orchard plants; research with walnuts ( McKenry, 1999) suggested that herbicide treatment followed by 18 months fallow can result in root knot nematode control of 97% compared to untreated plots. However, this effect only lasted 6 months, not long enough to achieve acceptable establishment of new orchard; no herbicides were found that kill grape roots ( McKenry, 1999). In stone fruit, while remnant roots were killed after 18 months, endoparasitic nematodes were not significantly reduced ( McKenry et al., 1995). The combination of herbicide costs plus additional 18 months waiting period prior to planting becomes an economic burden, especially with the limited effectiveness of treatment.

CALIFORNIA WALNUT COMMISSION. 15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

CALIFORNIA WALNUT COMMISSION. TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Sodium azide No registration package has been received No Unknown Propargyl bromide No registration package has been received No Unknown Iodomethane Not registered in U. S. Yes Unknown CALIFORNIA WALNUT COMMISSION. 16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED CALIFORNIA WALNUT COMMISSION. TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   KEY PEST 1: NEMATODES.

KEY PEST: REPLANT DISORDER AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS METHYL BROMIDE FORMULATIONS AND ALTERNATIVES ( include dosage rates and application method) # OF TRIALS DISEASE (% OR RATING) # OF TRIALS ACTUAL YIELDS ( T/ HA) CITATION see Table 16.1 for Regions A ( Stone Fruit), B ( Grapes), & D ( Almonds) U. S. Orchard Replant Page 38 CALIFORNIA WALNUT COMMISSION. TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D ( 385 kg/ ha) Nematodes, roots 0 20% ( based on research plots) 10% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) + metam sodium ( 65 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots)

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

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS See discussion below No alternatives are currently feasible in numerous orchard replant sites ( i. e., those with medium to heavy soils) and/ or where township cap restrictions apply. In these cases losses of trees are likely to be greater than 20% ( McKenry, 1999). Listed above are alternatives for sites where soils are amenable to 1,3 D and where township caps are not applicable.

CALIFORNIA WALNUT COMMISSION. 17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

According to the consortium, in 2001, MB was used on 21,316 hectares ( only about 1/ 3 of the area is actually treated in strip applications). In the same year, 1,3 D was applied to 113 hectares and metam sodium was applied to 28 hectares. The limited ( although increasing) use of the best alternative 1,3 D, is primarily due to township caps in the concentrated areas of walnut production in California, and 1,3 D use may be limited by moisture factors when 1,3 D is not an effective nematicide in heavy soils of an orchard and soils with greater than 12% moisture. In this situation MB is critical and its use is of considerable effectiveness in light of the longevity of walnut orchards and importance of early tree health to long producing orchards. It requires 8 10 years for trees to produce a saleable crop and the failure to start the orchard with healthy trees or in a pathogen infested site will reduce production over its 40 year life. Improper orchard replant can lead to additional replant within 10 years with no production in the interim. U. S. Orchard Replant Page 39 CALIFORNIA WALNUT COMMISSION. 18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

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

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

CALIFORNIA WALNUT COMMISSION. SUMMARY OF TECHNICAL FEASIBILITY Where alternatives, such as 1,3 D and chloropicrin , are not effective ( e. g., sites with medium to heavy soils, and/ or where township cap restrictions apply), MB will be critical to the healthy establishment of walnut orchards in 2007. In these cases losses of trees may be greater than 20% ( McKenry, 1999). McKenry ( 1999) estimated that 85% of land used for California walnuts was infested with one or more of three important nematode pests ( Pratylenchus vulnus, Criconemella xenoplax, or Meloidogyne spp.). Studies of individual pest populations tell only a small portion of the story of replant complex, since individual pests cause only a portion of the adverse growth effects. As with the stone fruit orchards, orchard replant problems for walnut orchards are a result of biological and environmental causes, and probably interactions of these forces. Unfortunately, there are no commercially available resistant rootstocks that can provide consistent relief from orchard replant problem in walnuts. It is clear that the long life of orchards requires that optimal pest management strategies be employed to overcome replant disorder during the one opportunity available   at orchard establishment. The long history of 1,3 D use in California suggests that at optimal conditions it ( or in combination with another chemical) is the best chemical alternative to MB. However, the reality of California orchard locations precludes the majority of growers taking advantage of the material since either township caps or soil texture/ moisture issues reduces efficacy or legal availability to 1,3 D. Therefore, for 2007, for walnut replant where alternatives are not effective, there is a critical need for MB for establishment of commercial operations. U. S. Orchard Replant Page 40 ALMOND HULLERS & PROCESSORS ASSOCIATION. PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ALMOND HULLERS & PROCESSORS ASSOCIATION. 10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST:

ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY PESTS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Almond Hullers and Processors Association ( California) Replant problem ( affects ~ 25% of total growing area) is a disease complex comprising an interaction of pests ( primarily nematodes) and environmental factors. Nematodes ( affects 35 50% of total growing area): Meloidogyne incognita ( root knot), Pratylenchus vulnus ( root lesion), Mesocriconema xenoplax ( ring), Xiphinema americanum ( dagger); Bacteria: Pseudomonas syringae ( canker) ( affects 15% of total growing area); Fungi: Armillaria mellea ( oak root fungus) ( affects 5% of total growing area) Many new almond orchards were planted between 1979 and 1982. These orchards will soon need to be replanted as the life of the orchard is reaching its maximum ( 25 30 years). Because little virgin land is available, replant problems will occur in these locations. Because of township caps ( 30% of area) and water moisture issues ( 65% of area), the best alternative, 1,3 D, is not available or effective as a replacement in many situations. Therefore, MB is considered critical for this industry. Alternatives, such as 1,3 D and chloropicrin, may be effective in reducing the effects of orchard replant disorder where there is low disease pressure or where there are no legal restriction in light, sandy loam soils, and where there is acceptable soil moisture. In other situations, where soils are medium to heavy, or where township caps are applicable, MB currently the product that has been sufficiently tested to effectively target root remnants from previous orchard trees. Strategies that include multiple techniques, such as use of herbicides, crop rotations, and fallow have the potential to reduce pest problems in orchard replant. Research is making progress in defining the most effective alternatives ( e. g., Lampinen et al., 2004; Browne et al., 2004). However, these combination techniques must first be tested so as not to compromise orchard productivity.

ALMOND HULLERS & PROCESSORS ASSOCIATION. 11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE The demand for almonds in the future is increasing, thus, after 2005, it is estimated that there will be numerous orchards replanted to almonds that were originally planted from 1979 1982, in addition to other orchards that will be replanted to almonds. Almonds, like other crops in this sector are infrequent users of MB, since fumigation occurs only once in the long life of the orchard. U. S. Orchard Replant Page 41 The typical practice of replanting orchards with MB is to remove the old trees after the final harvest ( typically 20 25 years after planting). The soil is harrowed and the remaining roots are removed. The soil is fumigated in the late fall and the trees are replanted in the early winter. When using MB growers have traditionally not needed to leave a fallow period between tree removal and the replanting of the new trees.

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

ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS REGION D CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) almond trees ANNUAL OR PERENNIAL CROP: (# of years between replanting) perennial ( 25 30 years)

TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) none SOIL TYPES: ( Sand, loam, clay, etc.) light, medium, heavy FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) once in 25 to 30 years OTHER RELEVANT FACTORS: No other relevant factors were identified by the applicant.

ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA plant hardiness zones 9a, 9b RAINFALL ( mm): 30 60 CM/ YR 16 72.1 17.3 0 trace 1.0 trace 0 44.7 56.9 9.9 30.5 OUTSIDE TEMP. ( ° C) 14.4 14.8 20.8 25.7 30.3 27.4 25.1 18.4 13.4 9.6 10.3 10.6 FUMIGATION SCHEDULE 1st year, land preparation and fumigation; no additional fumigation for life of orchard (~ 25 to 30 years) PLANTING SCHEDULE Occurs 2nd year, after fumigation KEY MARKET WINDOW: Not applicable * For Fresno, California U. S. Orchard Replant Page 42 ALMOND HULLERS & PROCESSORS ASSOCIATION. 11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Orchards replanted into previous orchard land ( the typical situation in California) must reduce pathogen populations ( mostly nematodes and fungi) and nutrient sources of old orchard tree roots and root remnants. This requires an effective material that is volatile and can penetrate into the soil to reach these plant materials. In sandy, loam soils, where restrictions do not apply, 1,3 D may be an acceptable alternative that can penetrate to the target areas. In other situations, this compound and other alternatives are not able to move sufficiently through the soil to remove the problem pests. Thus, there is a critical need for MB for almond replant for 2007, as well as for other orchard replant crops of this sector. The infrequent use of MB ( once in 25 40 years, or longer) and the positive benefits of vigorous early tree growth make MB a key component of orchard fruit and nut production until research studies result in effective protocols for use of alternatives on commercial sites. U. S. Orchard Replant Page 43 ALMOND HULLERS & PROCESSORS ASSOCIATION. 12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003a AREA TREATED ( hectares) 1,613 2,046 1,430 496 820 278 RATIO OF FLAT FUMIGATION b METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Flat fumigation ( broadcast) Flat fumigation ( broadcast) Flat fumigation ( broadcast) Flat fumigation ( broadcast) Flat fumigation ( broadcast) Flat fumigation ( broadcast)

AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 547,622 703,401 497,810 174,502 217,032 85,375 FORMULATIONS OF METHYL BROMIDE ( methyl bromide/ chloropicrin) 98: 2 98: 2 98: 2 98: 2 98: 2 98: 2 METHOD BY WHICH METHYL BROMIDE APPLIED shank injected shank injected shank injected shank injected Shank injected Shank injected APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 340 344 348 352 265 307 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 34.0 34.4 34.8 35.2 26.5 30.7 * For Flat Fumigation treatment application rate and dosage rate may be the same. a Data from preliminary estimates by California Department of Pesticide Regulation. b Various methods are used depending on the particular situation; fumigation can be flat fumigation, strip, or even " by the hole" ( for individual tree replacement; MB is the only product that has acceptable technology for hole application   approximately 0.5 kg/ tree). U. S. Orchard Replant Page 44 ALMOND HULLERS & PROCESSORS ASSOCIATION. PART C: TECHNICAL VALIDATION ALMOND HULLERS & PROCESSORS ASSOCIATION. 13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D Can be effective in orchards with light soils; currently not feasible in medium or heavy soils; usually more effective when formulated with chloropicrin; subject to township caps and specific moisture requirements. ( e. g., Browne et al., 2003a). Promising results have been reported with 1,3 D/ chloropicrin for treatment of replant disorder ( Browne et al., 2003a, 2004) Possibly, after further research that will optimize application methods Chloropicrin May perform acceptably alone when fungi are primary cause of orchard replant problem; for nematode causation, MB or 1,3 D is preferred. Promising results have been reported with some rates of chloropicrin for treatment of replant disorder ( Browne et al., 2003a, 2004) Possibly, after further research that will optimize application methods Metam sodium Not an effective nematicide since it can not reach deep areas of soil, which is the primary cause of orchard replant problems; generally not effective in areas where water percolation is a problem ( e. g., clay soils). No Dazomet This alternative has been examined by researchers and is inconsistent in field trials. This has been deemed not feasible due to lack of performance in field trials and inability to penetrate and kill nematodes at depths required for orchard replant acceptability. This product requires that there be uniform saturation of the granules to ensure that the product will perform consistently. This is not feasible in a typical orchard situation. No Nematicides Other nematicides ( besides 1,3 D) have limited use due to their lack of performance or due to regulatory issues. Therefore, this product was deemed not feasible No NON CHEMICAL ALTERNATIVES Fallow, or crop rotation Not sufficient alone; sometimes done regardless of fumigant that follows; may require 4 10 year fallow for some crops ( McKenry, 1999) and may not be sufficient even then; may provide partial control in some crops, however, economically difficult for grower to sustain ( Browne et al., 2002b; Trout et al., 2002). Some research suggests that short term rotations of some crops can reduce replant disorder, but large scale studies need to be completed ( Browne et al., 2004). No U. S. Orchard Replant Page 45 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Rootstock Similar situation to stone fruit, rootstocks can help reduce some problem nematodes, but are not tolerant to an array of pests, and do not address overall replant " complex" ( Browne et al., 2003a). Initial results of research examining cover crops suggest reduction of replant disorder when wheat is incorporated into soil prior to planting nematode tolerant rootstocks ( Browne, 2003b). However, this research must be continued, and results confirmed, before commercial application can be accepted. No Biofumigation, solarization, steam, Biological Control, cover crops and mulching, crop rotation / fallow, crop residue and compost, substrate/ plug plants, plowing/ tillage, resistant cultivars, grafting/ resistant rootstock, physical removal, organic amendments/ compost, general IPM Each of the not in kind alternatives were listed as options for replacement of MB. Many of these alternatives are currently being employed with current replant practices. Alternatives such as biofumigation, solarization, and steam are not feasible due to planting times, one time fumigation requirement per orchard ( steam treatment), and inability to attain sufficient biomass of plant material ( biofumigation). Biological control may have promise, but research has not identified agents that can be used on a commercial scale or that work consistently well. The University of California is investigating biological control of major fungal pathogens, but this work is still in the early stages of research. As such, MB is currently considered critical to the industry No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin 1,3 D + chloropicrin + metam sodium 1,3 D + metamsodium Effective against nematodes, fungi, and to kill remnant roots when 1,3 D is used in orchards with light soils; not feasible in medium or heavy soils; subject to township caps and specific moisture requirements. Promising results from research trials indicated that efficacy may be improved by refining application protocols and use rates ( see e. g., Browne et al., 2003a, 2004). Possibly, after further research that will optimize application methods, if no legal restrictions apply and where soil type is amenable U. S. Orchard Replant Page 46 * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

ALMOND HULLERS & PROCESSORS ASSOCIATION. 14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Herbicides ( e. g., triclopyr, glyphosate) Not acceptable treatment alone. Herbicides are used for killing remnant roots of previous orchard plants; research with walnuts ( McKenry, 1999) suggested that herbicide treatment followed by 18 months fallow can result in root knot nematode control of 97% compared to untreated plots. However, this effect only lasted 6 months, not long enough to achieve acceptable establishment of new orchard; no herbicides were found that kill grape roots ( McKenry, 1999). In stone fruit, while remnant roots were killed after 18 months, endoparasitic nematodes were not significantly reduced ( McKenry et al., 1995). The combination of herbicide costs plus additional 18 months waiting period prior to planting, becomes an economic burden, especially with the limited effectiveness of treatment.

ALMOND HULLERS & PROCESSORS ASSOCIATION. 15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS State if registered for this crop, registered for crop but use restricted, registered for other crops but not target crop, or not registered REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Sodium azide No registration package has been received No Unknown Propargyl bromide No registration package has been received No Unknown Iodomethane Not registered in U. S. Yes Unknown ALMOND HULLERS & PROCESSORS ASSOCIATION. 16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED U. S. Orchard Replant Page 47 ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   REPLANT DISORDER. KEY PEST: REPLANT DISORDER AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS METHYL BROMIDE FORMULATIONS AND ALTERNATIVES ( include dosage rates and application method) # OF TRIALS DISEASE (% OR RATING) # OF TRIALS ACTUAL YIELDS ( T/ HA) CITATION fungal pathogens [ 1] MB ( 409 kg/ ha) [ 2] chloropicrin ( 425 kg/ ha) [ 3] 1,3 D ( 409 kg/ ha) [ 4] non fumigated Almond ( Marianna 2624 rootstock), 2001; 4 reps, research plots ( 19 m x 22 m), no tarp; Trunk diameter ( mm) ( increase after 8 months postfumigation [ 1] 4b [ 2] 10c [ 3] 2a [ 4] 1a same Trees (%) w/ growth > 1.5 m height ( in 8 months): [ 1] 21% a [ 2] 96% b [ 3] 1% a [ 4] 2% a Browne et al., 2002b fungal pathogens [ 1] MB ( 0.34 kg/ tree) + chloropicrin ( 0.11 kg/ tree) [ 2] chloropicrin ( 0.45 kg/ tree) [ 3] non fumigated Almond ( Marianna 2624 rootstock), 2002; 4 reps, research plots ( 19 m x 22 m), no tarp; Trunk diameter ( mm) ( increase after 8 months postfumigation [ 1] 15b [ 2] 14b [ 3] 4a same Trees (%) w/ growth > 1.5 m height ( in 8 months): [ 1] 94% [ 2] 83% [ 3] 6% Browne et al., 2002b ALMOND HULLERS & PROCESSORS ASSOCIATION. TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE* LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D ( 385 kg/ ha) Nematodes, roots 0 20% ( based on research plots) 10% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots) 1,3 D ( 265 kg/ ha) + chloropicrin ( 150 kg/ ha) + metam sodium ( 65 kg/ ha) Nematodes, fungi, roots 0 10% ( based on research plots) 5% ( based on research plots)

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

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS See discussion below * 1,3 D is not a feasible alternative where soil moisture is not optimal or where township caps restrict its use.

No alternatives are currently feasible in numerous orchard replant sites ( i. e., those with medium to heavy soils) and/ or where township cap restrictions apply. In these cases losses of trees are likely to be greater than 20% ( McKenry, 1999). Listed above are alternatives for sites where soils are amenable to 1,3 D and where township caps are not applicable. U. S. Orchard Replant Page 48 ALMOND HULLERS & PROCESSORS ASSOCIATION. 17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

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

ALMOND HULLERS & PROCESSORS ASSOCIATION. 18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

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

ALMOND HULLERS & PROCESSORS ASSOCIATION. SUMMARY OF TECHNICAL FEASIBILITY U. S. Orchard Replant Page 49 Currently, no alternatives are feasible in the majority of almond orchard replant sites ( i. e., those with medium to heavy soils) and/ or where township cap restrictions apply. In these cases losses of trees are likely to be greater than 20% ( McKenry, 1999). As with the other commodities of the orchard replant sector, replant problems for almonds are a result of biological and environmental causes, and interactions of these forces. Studies of individual pest populations tell only a small portion of the story of replant complex, since individual pests can cause only a portion of the adverse growth effects. Nevertheless, approximately 35% of hectares planted in almonds have infestations of Criconemella xenoplax and/ or Pratylenchus vulnus ( McKenry, 1999). Nemaguard, the most commonly used almond rootstock, has resistance only to Meloidogyne spp. As such, it is clear that the long life of orchards requires that optimal pest management strategies be employed to overcome replant disorder during the one opportunity available   at orchard establishment. The long history of 1,3 D use in California suggests that at optimal conditions it ( or in combination with another chemical) is the best alternative to MB. However, the reality of California orchards precludes the majority of growers from taking advantage of the material since either township caps or soil texture/ moisture issues reduce efficacy or legal availability to 1,3 D. Therefore, for 2007, for almond replant where alternatives are not effective, there is a critical need for MB for establishment of commercial operations. Currently, research is being conducted examining non fumigant treatments. Some non chemical treatments have shown promise in small scale research trials, such as use of crop rotation ( Browne et al., 2003b, 2004). Continued studies will have to be conducted before these types of treatments are developed for commercial application.

PART D: EMISSION CONTROL Research is being conducted among all the orchard replant commodities to address the orchard replant disorder complex. Fumigation is only one means of achieving optimal orchard establishment. Other practices can reduce long term effects of pathogens and biotic and abiotic causes of this disorder. Such practices as fallowing land, crop rotation, strategic fertilization, water management, development of tolerant rootstocks, deep injection of chemicals   all will reduce the emissions of MB ( or other toxic chemicals that might be alternatives). Current research also includes studies with soil amendments, such as thiosulfate fertilizers that may act as barriers or absorbents of MB and reduce emissions. U. S. Orchard Replant Page 50 19. TECHNIQUES THAT HAVE AND WILL BE USED TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS IN THE PARTICULAR USE TABLE 19.1: TECHNIQUES TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS TECHNIQUE OR STEP TAKEN VIF OR HIGH BARRIER FILMS METHYL BROMIDE DOSAGE REDUCTION INCREASED % CHLOROPICRIN IN METHYL BROMIDE FORMULATION LESS FREQUENT APPLICATION WHAT USE/ EMISSION REDUCTION METHODS ARE PRESENTLY ADOPTED? VIF and high density tarps being tested ( almond) Testing reduction from 98: 2 to 75: 25 ( almond) When fungal pathogens are main concern chloropicrin percent is increased Fumigation is applied only once in 20 40 years for this sector WHAT FURTHER USE/ EMISSION REDUCTION STEPS WILL BE TAKEN FOR THE METHYL BROMIDE USED FOR CRITICAL USES? Testing Deep injection; use of additional herbicides to kill remnant roots to increase efficacy of MB and other fumigants; reduction of MB in formulation Deep injection, increased chloropicrin in formulation to 50: 50 being examined Fumigation is applied only once in 20 40 years for this sector OTHER MEASURES ( please describe) Unidentified Combination of chemicals and cultural practices such as fallow + alternatives or reduced MB Combination of chemicals and cultural practices such as fallow + alternatives or reduced MB Fumigation is applied only once in 20 40 years for this sector Various techniques are being studied to improve the efficacy of alternatives. Primary is the development of application techniques to improve delivery of the best alternatives, such as 1,3 D and metam sodium ( e. g., McKenry, 2001). In situations with no township caps, and where soil moisture is less than 12% at 1.5 meters, 1,3 D may be effective   this would occur generally in orchards with light, sandy soils. Although the cropping system of these orchards makes the use of MB cost effective, current research ( e. g., Browne et al., 2004; Lampinen et al., 2004; Schneider et al., 2004) is advancing the understanding of alternatives in orchard replant. This research will ultimately result in the development of protocols that will be adapted for commercial use. U. S. Orchard Replant Page 51 20. IF METHYL BROMIDE EMISSION REDUCTION TECHNIQUES ARE NOT BEING USED, OR ARE NOT PLANNED FOR THE CIRCUMSTANCES OF THE NOMINATION, STATE REASONS:

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

PART E: ECONOMIC ASSESSMENT 21. COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD:

TABLE 21.1: COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD This table is not included since none of the alternatives are technically feasible. See Summary of Economic Feasibility below.

22. GROSS AND NET REVENUE: