Legard, D., personal communication, January 9, 2005. Reply to MBTOC 2005 Page 43 Lewis, C. 2003 ( President, Hy Yield Bromine). Personal communication through S. A. Toth ( steve_ toth@ ncsu. edu) , Extension Entomologist & Pest Management Information Specialist, North Carolina State University; message forwarded electronically to G. Tomimatsu, December 29, 2003.

Locascio. S. J., and D. W. Dickson. 1998. Metam sodium combined with chloropicrin as an alternative to methyl bromide. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro98. html.

Locascio, S. J., J. P. Gilreath, D. W. Dickson, T. A. Kucharek, J. P. Jones, and J. W. Noling. 1997. Fumigant alternatives to methyl bromide for polyethylene mulched tomato. HortSci. 32: 1208 1211.

Martin, F. N. 2003. Development of alternative strategies for management of soilborne pathogens currently controlled with methyl bromide. Ann. Rev. Phytopathol. 41: 325  350.

MBTOC ( 1994): 1994 Report of the Methyl Bromide Technical Options Committee for the 1995 Assessment of the UNEP Montreal Protocol on Substances that Deplete the Ozone Layer. Nairobi.

Melban, K. 2003. California Pepper Commission. Personal Communication with G. Tomimatsu. Kenny@ tabcomp. com. 11/ 26/ 2003.

Munn. D. A. 1992. " Comparison of shredded newspaper and wheat straw as crop mulches." Hort technol. 2: 361  366.

Noling, J. W. 2003. University of Florida Lake Alfred. Personal Communication with G. Tomimatsu. Jwn@ lal. ufl. edu. 11/ 25/ 2003.

Noling, J. W., E. Rosskopf, and D. L. Chellemi. 2000. Impacts of alternative fumigants on soil pest control and tomato yield. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro00. html.

Ou, L. T., K. Y. Chung, J. E. Thomas, T. A. Obreza, and D. W. Dickson. 1995. Degradation of 1,3 dichloropropene ( 1,3 D) in soils with different histories of field applications of 1,3 D. J. Nematol. 25: 249   257.

Phatak, S. C., D. R. Sumner, H. D. Wells, D. K. Bell, and N. C. Glaze. 1983. Biological control of yellow nutsedge, Cyperus esculentus, with the indigenous rust fungus Puccinia canaliculata. Science. 219: 1446   1448.

Patterson, D. T. 1998. Suppression of purple nutsedge ( Cyperus rotundus) with polyethylene film mulch. Weed Technology, 12: 275 280. Reply to MBTOC 2005 Page 44 Porter, I., S. Mattner, R. Mann, R. Gounder, J. Banks, and P. Fraser. 1994. Strawberry Fruit Production and results from trials in Different Geographic Regions. A Presentation to the Methyl Bromide Alternatives Conference, Lisbon, September 1994 Schneider S. M., E. N. Rosskopf, J. G. Leesch, D. O. Chellemi, C. T. Bull, and M. Mazzola. 2003. United States Department of Agriculture   Agricultural Research Service research on alternatives to methyl bromide: pre plant and post harvest. Pest Manag Sci. 59: 814 826.

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

Smelt, J. H., S. J. H. Crum, and W. Teinissen. 1989. Accelerated transformation of the fumigant methyl isocyanate in soil after repeated application of metam sodium. J. Environ. Sci. Health B24: 437 455.

Stall, W. M. and J. Morales Payan. 2000. The critical period of nutsedge interference in tomato. S. W. Florida Research & Education Center. Available on the web at www. imok. ufl. edu/ liv/ groups/ IPM/ weed_ con/ nutsedge. htm UNEP ( United Nations Environment Programme). 1998. Methyl Bromide Technical Options Committee ( MBTOC) 1998 assessment of alternatives to methyl bromide. p. 49.

U. S. EPA. 2002. Peppers Field. Peppers Grown Outdoors on Plastic Mulch. CUN2003/ 058 Verhagen, C., G. Lebbink, and J. Bloem. 1996. Enhanced biodegradation of the nematicides 1,3 dichloropropene and methyl isothiocyanate in a variety of soils. Soil Biol. Biochem. 28: 1753   1756.

Webster, T. M. 2002. Nutsedge eradication: impossible dream? National Nursery Proc. RMRS P 000. U. S. DA Forest Service, Rocky Mtn Res. Station, Ogden, Utah.

Webster, T. M., A. S. Csinos, A. W. Johnson, C. C. Dowler, D. R. Sumner, R. L. Fery. 2001. Methyl bromide alternatives in a bell pepper squash rotation. Crop Protection 20: 605 614.

Wilen, C. A., M. E. McGiffen, and C. L. Elmore. 2003. Nutsedge: Integrated Pest Management for Home Gardeners and Landscape Professionals. University of California IPM Publication # 4732. Available on the Web at www. ipm. ucdavis. edu. Reply to MBTOC 2005 Page 45 7. SMOKEHOUSE HAMS Overview of the U. S. Nomination The U. S. has requested 135.742 metric tons of methyl bromide for use on uncooked ( dry cured or ` country') hams for 2006. MBTOC was unable to make a recommendation for this sector.

Currently there are no viable alternatives to methyl bromide for the dried meat industry: phosphine does not control mites ( a major pest affecting this sector) and heat would alter the product. In U. S. pork processing plants that produce dry cured pork products there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  Pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to MB, making these alternatives technically and/ or economically infeasible. Phosphine, alone or in combination with carbon dioxide does not control mites, a major pest on cured hams.  Geographic distribution of the facilities: Facilities included in this nomination are located in the southern U. S. where mild temperatures and high relative humidity result in key pest pressures that are moderate to severe. These ambient conditions require that pests be killed because they will only reinfest the facility after fumigation.  Age and type of facility: older food processing facilities, especially those constructed of wood, experience more frequent and severe pest infestations that must be controlled by fumigation. In the U. S. it is usual for dry cured processed pork to be produced in traditional facilities. These facilities are usually constructed of wood and many are decades old, if not older. Many newer facilities are constructed using the older facilities as models.  Constraints of the alternatives: some types of commodities ( e. g., those containing high levels of fats and oils) prevent the use of heat as an alternative because of its effect on the final product ( e. g., rancidity). All of the pork products are relatively high fat products so rancidity would be a problem. In addition, using heat will alter the character of the final product, producing, for example, a cooked pork product rather than a dry cured pork product with the attendant flavor differences.  Transition to newly available alternatives: Sulfuryl fluoride recently received a Federal registration for certain commodities and structures, such as cereal mills. At present, pork and pork products are not included among the legal uses of sulfuryl fluoride, so this chemical is not an option for these facilities.  Delay in plant operations: e. g., the use of some alternatives can add a delay to production by requiring additional time to complete the fumigation process. Production delays can result in significant economic impacts to the processors.

It is common for producers of cured pork products to experience pest pressure from insects such as the ham skipper, the red legged ham beetle, dermestid beetles, and mites. These insects infest and feed on meat as it cures and ages. Environmental conditions ( temperature and humidity) in and around the facility strongly influence the level of pest pressure. Under favorable ambient conditions, such as those seen in silo curing, pest pressure increases and a regular fumigation schedule is recommended. In the U. S., the Food and Drug Administration ( FDA) regulates the Reply to MBTOC 2005 Page 46 maximum levels of live or dead insects or insect parts that may be present in stored food products. Food commodities that exceed maximum limits allowed are considered adulterated by FDA and thus unfit for human consumption. There are currently no alternatives registered for use on hams in the U. S. that would provide the same level of pest control.

The specific name and physical address of each facility was not requested in the forms filled out by the applicants in the United States. However, general location information for the following facilities is known:

  Kentucky ( Cadiz, Greenville)   Missouri ( California)   North Carolina ( Boone, Goldsboro, Smithfield, Wayne County)   Virginia ( Surry)   Tennessee ( Various locations)   South Carolina ( Various locations).

In order to address this concern, USG has requested location information from the post harvest sector participants. The forms have begun to come in from the applicants and are currently under review. When the analysis is complete it will be forwarded to MBTOC.

It has been difficult to determine the amount of methyl bromide used historically in this sector. Some data have been supplied by applicants32:

METHYL BROMIDE CONSUMPTION FOR THE PAST 5 YEARS AND THE AMOUNT REQUIRED IN THE YEAR( S) NOMINATED Historical Use Requested Use For each year specify: 1997 1998 1999 2000 2001 2002 2005 2006 Amount of MB ( kg) 1,159 1,309 1,291 972 1,659 1,528 170,350 170,350 Volume Treated 1000 m ³ 50 53 52 41 48 43 7,087 7,087 Formulation of MB Information not provided Information not provided Dosage Rate ( kg/ 1000 m ³ ) 31 30 32 29 38 35 25 25 Actual ( A) or Estimate ( E) Information not provided Information not provided There are currently no alternatives to methyl Bromide in Ham fumigation. Phosphine, alone and in combination with carbon dioxide, does not control mites, a major pest in cured pork products. Additionally, according to the phosphine label, the state of North Carolina has further restricted the use of this alternative. According to state regulations, phosphine may only be used to control rats and mice, but not insects.

32 Data for only one company. Given the small share of the market for dry cured pork products represented by the reporting company, these data cannot be taken as representative. Reply to MBTOC 2005 Page 47 In the U. S., the Food and Drug Administration ( FDA) regulates the maximum levels of live or dead insects or insect parts that may be present in stored food products. Food commodities that exceed maximum limits allowed are considered adulterated by FDA and thus unfit for human consumption and cannot be sold. The law is part of the Federal Food, Drug, and Cosmetic Act and available on the World Wide Web at: http:// www. cfsan. fda. gov/~ dms/ dalbook. html). Another source for the Food, Drug, and Cosmetics Act can be found at: http:// www. fda. gov/ opacom/ laws/ fdcact/ fdcact4. htm Meat Inspections are through the Food Safety and Inspection Service ( FSIS) of the United States Department of Agriculture ( USDA). Under authority of the Federal Meat, Poultry and Egg Products Inspection Acts, FSIS inspects and monitors all meat, poultry and egg products sold in interstate and foreign commerce to ensure compliance with mandatory U. S. food safety standards and inspection legislation. http:// www. fsis. usda. gov/ regulations_&_ policies/ federal_ inspection_ programs/ index. asp Establishments have the option to apply for Federal or State inspection. Under the agreement, a State's program must enforce requirements " at least equal to" those imposed under the Federal Meat and Poultry Products Inspection Acts. However, product produced under State inspection is limited to intrastate commerce. FSIS provides up to 50% of the State's operating funds, as well as training and other assistance. http:// www. fsis. usda. gov/ regulations_&_ policies/ state_ inspection_ programs/ index. asp Technical and Economic Assessment of MBTOC/ TEAP Report We have not been provided by MBTOC with information on their technical assessment of the performance of alternatives, or their economic assessment on the impact of converting to alternatives. To support the MBTOC's recommended change in the U. S. request citations of the research references and economic assessments that led to the MBTOC conclusions are needed so we can understand the justification. The technical references should describe the species tested, pest numbers, concentrations, times, and commodity volumes. Economic references should describe the costs of converting from methyl bromide to alternatives, the impact of higher yield losses, longer plant back intervals, the economic feasibility if key market windows are missed, and the economic impact of a 20% transition to alternatives including estimates of management costs for more intensive programs and how the impact of less reliable alternatives is calculated. The sources of estimates of the extent of pest pressure should describe the rationale for using other estimates, a description of the questions, species being surveyed and quantitative levels used.

U. S. 2006 nomination In responding to MBTOC concerns USG has developed some information suggesting that less methyl bromide is needed in this sector than previously thought. Accordingly, USG is submitting an amended request for this sector of 40.854 metric tons of methyl bromide, a reduction to less than 1/ 3 of the previously requested amount.

Citations Bell, C. H. 2000. Fumigation in the 21st Century. Crop Protection, 19: 563 69. Reply to MBTOC 2005 Page 48 8. FIELD GROWN STRAWBERRIES Overview of the U. S. Nomination The U. S. is requesting 1,918.4 metric tons of methyl bromide for use on field grown strawberries in California ( 1,452.732 metric tons), Florida ( 310.997 metric tons), and the southeastern U. S. ( 152.294 metric tons).

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

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

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

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

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

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

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

MBTOC reasons that the amount calculated by the USG was predicated on a 1X township cap but that the ` Ornamental' portion of the U. S. nomination indicates that a greater availability of 1,3 D is expected for 2006. MBTOC further argues that there are available substitutes for methyl bromide and cites " Porter, in press", to justify a 20% reduction in the nominated amount. MBTOC states that Pic EC ® or metam and pic are ` technically suitable' for Florida and the southeastern US. MBTOC also states that reduced dosage is appropriate because the treated portion of the beds can be held to 200kg/ ha and because dosages can be reduced when higher density films ( including VIF) are used, citing Fennimore et al 2005 and Gilreath et al 2003. Reply to MBTOC 2005 Page 49 U. S. Response to MBTOC's prior recommendations The U. S. nomination for strawberry field grown strawberry fruit is a critical need for an amount of methyl bromide in areas with moderate to severe pest pressure, because currently there are no feasible alternatives and farmers would face severe economic hardships in the absence of methyl bromide. Where there is moderate to severe pest pressure, the suggested alternatives for strawberry fruit production fail to provide the necessary degree of pest control or their use is not easily adoptable due to state imposed restrictions. The nomination also notes that applying alternatives is further complicated when plant back restrictions prevent farmers from meeting marketing windows ( e. g., winter or early spring) when strawberry sale prices are as much as 100% higher than during the rest of the year ( see Market Window Information). The nomination notes significant progress in adopting emission reduction technologies and changing formulations and application rates to reduce methyl bromide dosage rates to some of the lowest in the world, and that further trials are being conducted to evaluate new alternatives, and to test ways of overcoming constraints in further lowering methyl bromide formulations and adopting even more impermeable barriers.

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

a. Township caps MBTOC indicates their understanding that the nomination was based on 1X township caps. In fact, a weighted average of expected probability of 1X and 2X cap was used in developing the U. S. request, so the MBTOC assumption on this issue is incorrect33. MBTOC reasons that the availability of 1,3, D for strawberry production will be greater than the 1X township cap but this is by no means certain ( see footnote below). MBTOC cites the ` Ornamentals' section of the nomination to bolster their assertion. The ` Ornamentals' section was in error, and the USG thanks MBTOC for noting this discrepancy ( which has now been corrected).

b. Alternatives are technically and economically feasible so a 20% reduction for phasein of alternatives such as 1,3 D/ Pic or metam sodium was used: alternatives can be used in areas where 1,3 D is not appropriate MBTOC appears to disagree with the U. S. assessments of yield loss.

33 In practice, the weights applied were 1/ 3 of the 2X cap and 2/ 3 of the 1X cap. In the current judgment of USG experts this places too much likelihood on an increased township cap. In repeated conversations with State of California pesticide regulators, USG has been given no indication that the township caps would be raised beyond the temporary increase in the cap except as negotiated in individual agreements. In order to be eligible for an increased cap amount under these agreements, a township must have an unused ( banked) amount available to increase the cap. As the program currently stands, only townships with banked amounts can increase their use of 1,3 D above the 1X cap. As townships exceed the 1X cap they lose their ability to increase the caps by depleting their ` banked' amount. Reply to MBTOC 2005 Page 50 The U. S. assessments of yield loss were developed from technically appropriate studies relevant to the specific circumstances of the U. S. situation. Technically appropriate studies are those which:

Included an untreated control for comparison purposes

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

Give estimates of yield changes ( differences)

Include methyl bromide as a standard The U. S. nomination was restricted to those situations where ` key' pest pressure was moderate to severe34 and where these pests could not be controlled by alternatives and, therefore, would result in yield loss.

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

Although it is difficult to be certain how the MBTOC analysis was conducted and what it includes because it has not been reviewed and published and was not provided to the U. S. experts to evaluate35, U. S. experts were able to make some educated guesses about the analysis36. The analysis for strawberry fruit is described in a paper is listed as being " in press" as conference proceedings with a date after the MBTOC recommendations on the U. S. nomination were tendered.

A version of the paper was presented by Dr. Ian Porter at the Methyl Bromide Alternatives Organization meeting in San Diego, November 2003 and the subject of considerable controversy 34 In the judgment of U. S. experts pressure was such that yield losses of the magnitude of those used in the economic assessment would be sustained.

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

36 Some of this material with references had been previously presented at the Methyl Bromide Alternatives Organization 2003 meeting ( San Diego). At that time U. S. experts expressed their view that many if not most of the studies were not an appropriate application of the information. Reply to MBTOC 2005 Page 51 and questioning among participants. Dr. Porter's paper included a number of papers which U. S. experts believe are not representative of the specific conditions included in the U. S. nomination in determining the usefulness of alternatives because the research was carried out under conditions of no pest pressure37. If no pests are present any alternative, or indeed not using any pesticide at all, will all work equally well. By including situations where there is no pest pressure one in effect adds ( many) " 0" to the equation38 describing the differences in yield between crops grown using methyl bromide and those grown using an alternative. This has the effect of lowering the average difference between yields using methyl bromide and yields using an alternative. If a sufficient number of " 0" are added, the result will be to ( falsely) eliminate the yield differences between methyl bromide and the alternative treatments.

In other studies, pests were present but they were not the same pests that were present in all of the U. S. circumstances. Taking the case of the southeastern U. S., for example, weeds, diseases, fungi, and nematodes all infest the crops. Some of these pests can be controlled with alternatives, but some of the weeds, in particular nutsedges ( nut grasses), nightshades, and some hard seed coated weeds, cannot. Situations without weeds will show small or no yield losses when alternatives are used while the true situation when ( key) weeds are present is that there are large yield losses39. Including these factors has the effect of adding " 0" yield difference as many times as there are papers.

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

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

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

Experts are familiar with the occurrence of high prices for fresh produce early in the season, prices which decline as the produce becomes abundant ( and more familiar) later in the season.

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

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

39 So, for example, studies conducted in California, where there is less pressure for weeds will not give an accurate picture of the situation in the southeastern U. S. where nutsedge, nightshades, and hard seed coated weeds are a major problem. Reply to MBTOC 2005 Page 52 The U. S. has provided marketing data documenting the existence of these market windows and their effects on the revenue and profits earned by farmers. Farmers tell us that nearly all of their net revenue ( approximately 90%) above cost is earned during the short period of high prices. For some crops, 75% of the economic loss is due to missing a market window rather than through smaller crops, lower fruit quality, or higher costs.

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

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

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

A second issue with the transition to drip applied fumigants is the need to setup the entire irrigation system before they fumigate. In the traditional production system ( i. e. broadcast fumigation), growers migrate most of their irrigation headers and other main line pipes over from the previous season's crop to the new after the end of that season ( in November/ December/ January). However, with drip applied fumigants growers will need two sets of this equipment, an increased cost that is difficult for many growers to absorb. It is difficult to get firm prices on this but I have an estimate of $ 500 / acre for the additional equipment. Another related issue is that growers cannot use drip applied fumigants on land that has not had strawberries on it before due to a similar issue. The main valves and pipes for the irrigation system need to be setup for strawberry, and this can't be done while another crop is in the ground, and there is insufficient time put this equipment in and setup for drip applied Reply to MBTOC 2005 Page 53 fumigation. Growers in this situation will have to use broadcast fumigation for the first year on new non strawberry ground. 40 Losses result not only from missing market windows but also from the inability to plant other crops in rotation with strawberries, losing the revenue from these crops USG experts have examined a " Porter paper in press" 41 and have a number of concerns with the applying the results of this paper in the context of the specific circumstances of the U. S. nomination. Although it has a ` publication date" of one year later than the San Diego presentation, we find that our concerns on this issue remain the same. The studies used in the meta analysis are not listed and no indication is given of the criteria used to include or exclude a study from the analysis.

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

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

Florida At moderate to severe pest pressure only MB can effectively control the target pests found in Florida. In addition, the use of alternatives are limited in some areas because the soil overlays a vulnerable water table ( karst geography). Finally, there are other areas where regulatory restrictions such as mandatory buffers around inhabited structures make alternatives infeasible. MB applications in strawberries are typically made using 67: 33 or, where feasible, 50: 50 mixtures with chloropicrin under plastic mulch. Related dosage rates of 202 kg/ ha are below the threshold in the MBTOC 2002 Report, making further reduction difficult to achieve without 40 Daniel Legard, PhD, personal communication, January 3, 2005. 41 Porter, I., S. Mattner, R. Mann, R. Gounder, J. Banks, and P. Fraser. 1994. Strawberry Fruit Production and results from trials in Different Geographic Regions. A Presentation to the Methyl Bromide Alternatives Conference, Lisbon, September 1994. Reply to MBTOC 2005 Page 54 compromising pest management.

Southeastern U. S.

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

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

TABLE 1: COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Methyl Bromide 100 1,248 1,248 1,248 Chloropicrin+ metam sodium 73 964 964 964 1,3 d chloropicrin 86 1,416 1,416 1,416 Metam Sodium 70 849 849 849 * As percentage of typical or 3 year average yield, compared to methyl bromide.

TABLE 2: YEAR 1 GROSS AND NET REVENUE Year 1 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 29,818 $ 5484 Chloropicrin+ metam sodium $ 20,679 $ 1,716 1,3 d chloropicrin $ 24,362 $ 702 Metam Sodium $ 19,829 $ 2,396 TABLE 3: YEAR 2 GROSS AND NET REVENUE Year 2 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 29,818 $ 5484 Chloropicrin+ metam sodium $ 20,679 $ 1,716 1,3 d chloropicrin $ 24,362 $ 702 Metam Sodium $ 19,829 $ 2,396 Reply to MBTOC 2005 Page 55 TABLE 4: YEAR 3 GROSS AND NET REVENUE YEAR 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 29,818 $ 5484 Chloropicrin+ metam sodium $ 20,679 $ 1,716 1,3 d chloropicrin $ 24,362 $ 702 Metam Sodium $ 19,829 $ 2,396 Reply to MBTOC 2005 Page 56 CALIFORNIA  TABLE 5: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA METHYL BROMIDE ALTERNATIVE PIC+ MS ALTERNATIVE 1,3 D+ PIC ALTERNATIVE MS YIELD LOSS (%) 0 27% 14% 30%

YIELD PER HECTARE ( FRESH) 48,438 35,359 41,639 33,906 * PRICE PER UNIT ( US$) $ 1.71 $ 1.62 $ 1.62 $ 1.62 = GROSS REVENUE PER HECTARE ( US$) $ 73,683 51,099 60,173 48,999  OPERATING COSTS PER HECTARE ( US$) $ 60,131 55,339 58,438 54,921 = NET REVENUE PER HECTARE ( US$) $ 13,552 ( 4,240) ( 1,735) ( 5,922)

LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 17,792 11,817 19,474 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 88.19 58.57 96.52 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 24% 16% 26%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 131% 87% 144%

FLORIDA  TABLE 6: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FLORIDA METHYL BROMIDE ALTERNATIVE 1,3 D+ PIC YIELD LOSS (%) 0 25 YIELD PER HECTARE 3,138 2,353 * PRICE PER UNIT ( US$) 23.10 23.10 = GROSS REVENUE PER HECTARE ( US$) 72,511 54,360  OPERATING COSTS PER HECTARE ( US$) 44,459 40,795 = NET REVENUE PER HECTARE ( US$) 28,012 13,565 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 14,447 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 77.72 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 20%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 52% Reply to MBTOC 2005 Page 57 EASTERN UNITED STATES  TABLE 7: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES EASTERN UNITED STATES METHYL BROMIDE ALTERNATIVE PIC+ MS ALTERNATIVE 1,3 D+ PIC ALTERNATIVE MS YIELD LOSS (%) 0% 27% 14% 30%

YIELD PER HECTARE 22,417 16,364 19,270 15,692 * PRICE PER UNIT ( US$) 2.59 2.59 2.59 2.59 = GROSS REVENUE PER HECTARE ( US$) 51,892 37,881 44,608 36,324  OPERATING COSTS PER HECTARE ( US$) 29,623 30,555 31,658 30,270 = NET REVENUE PER HECTARE ( US$) 22,269 7,327 12,950 6,054 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 14,942 9,319 16,215 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 99.49 62.05 107.96 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 29% 18% 31%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 67% 42% 73%

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

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

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

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

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

( 3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usually easy to measure, at least over some unit, e. g., a hectare of land or a storage operation. However, high value commodities or crops may provide high revenues but may also Reply to MBTOC 2005 Page 58 entail high costs. Losses of even a small percentage of gross revenues could have important impacts on the profitability of the activity.

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

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

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

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

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

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

For Florida, three scenarios were compared to the methyl bromide baseline: 1) 1,3 D plus chloropicrin; 2) Iodomethane; and 3) Iodomethane + chloropicrin. Because Iodomethane is not registered, it is not considered a feasible alternative but the analysis is provided for comparative purposes. Reply to MBTOC 2005 Page 59 Florida In 2002, Florida had 2,792 hectares ( 6,900 acres) or 100% of harvested area treated with an average of 75 kilograms ( 166 pounds) of methyl bromide per hectare ( acre). The closest chemical alternative to methyl bromide is 1,3 D plus chloropicrin ( as Telone C 35). However, US EPA estimates that approximately 40% of Florida's strawberry growing areas overlay Karst geology, which prohibits the use of 1,3 D because of the potential for groundwater contamination. The use of 1,3 D also requires a 30 m buffer around inhabited structures. This would reduce the strawberry producing acreage by about 10%. Nematodes and nutsedge are key pests in Florida strawberry controlled with methyl bromide. Chloropicrin is not as effective in controlling weeds as methyl bromide. Using chloropicrin adds to production costs through increased labor costs for weeding and harvesting.

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

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

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

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

California In California, 1,3 D plus chloropicrin would also be the primary replacement for methyl bromide. California restricts total use of 1,3 D, at the local level ( township cap). Approximately 63% of California's strawberry areas are fumigated with methyl bromide, and 31% are fumigated with alternatives. Approximately 15% of the strawberry areas are on hillsides with slopes severe Reply to MBTOC 2005 Page 60 enough to make drip irrigation impractical.

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

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

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

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

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

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

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

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

It should be noted that the applicants do not consider any alternative to be feasible and that these estimates are an attempt to measure potential impacts. Reply to MBTOC 2005 Page 61 c. use of methyl bromide can be reduced because soil pests can be controlled with a use rate of 200kg/ ha and because use of higher density films ( including VIF) will allow pest control at lower dosages.

In making this assertion MBTOC has relied on the work cited in two papers, Fennimore et al, 2003 and Gilreath et al, 2003. Fennimore was contacted to determine whether, in his opinion, his work could be appropriately used to support lower application rates. His reply, reproduced below, indicates that he is very uncomfortable with this interpretation of his results42.

42 From: Steven Fennimore [ mailto: safennimore@ ucdavis. edu] Sent: Fri Jan 07 16: 24: 43 2005 To: Dan Legard Cc: jmduniway@ ucdavis. edu; haajwa@ ucdavis. edu Subject: MBTOC VIF stance Hi Dan I am a bit disturbed to learn from you that the some in MBTOC may have come to the conclusion that VIF will allow reduced rates of methyl bromide. While I stand behind my research that indicates clearly that the weed control efficacy of drip applied chloropicrin and Inline are improved under VIF compared to standard film, these fumigants are used to control many other pests besides weeds. For example, results do not necessarily suggest that VIF improves phytopthora cactorum control. Our research results presented at MBAO are preliminary and we are currently preparing peer reviewed publications. When those are written we will have a more clear understanding of the potential benefits and limitations of VIF than we have now. I do believe that VIF offers real potential benefits, however I caution anyone to make policy decisions about VIF based on my preliminary results presented at MBAO Steve Fennimore Extension Specialist University of California, Davis 1636 East Alisal St Salinas, CA 93905 831 755 2896 Reply to MBTOC 2005 Page 62 Technical and Economic Assessment of MBTOC/ TEAP Report.

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

U. S. 2006 nomination In summary, the USG disagrees with MBTOC's recommendation that the U. S. request can be reduced and reiterates its request for an additional 397.597 metric tons of methyl bromide for a total of 1,918.4 metric tons of methyl bromide.

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

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

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

Crop Profile for Strawberries in California. 1999. United States Department of Agriculture, NSF Center for Integrated Pest Management.

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

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

Florida Department of Agriculture and Consumer Services. Florida Agricultural Statistics Service. Reply to MBTOC 2005 Page 63 Florida Summary of Plant Protection Regulations. Oct. 2002. Florida Department of Agriculture and Consumer Services.

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

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

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

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

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

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

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

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

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

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

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

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

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

Sorenson, Kenneth A., W. Douglas Gubler, Norman C. Welch, and Craig Osteen. The Importance of Pesticides and Other Pest Management Practices in U. S. Strawberry Reply to MBTOC 2005 Page 64 Production. 1997. Special Funded Project of the United States Department of Agriculture, National Agricultural Pesticide Impact Assessment program. Document Number 1 CA 97.

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

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

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

Webster, T. M., A. S. Casinos, A. W. Johnson, C. C. Dowler, D. R. Sumner, and R. L. Fery. 2001( a). Methyl bromide alternatives in a bell pepper squash rotation. Crop Rotation 20: 605 614 Webster, T. M. and G. E. Macdonald. 2001( b). A survey of weeds in various crops in Georgia. Weed Technol. 15: 771 790.

CITATIONS REVIEWED BUT NOT APPLICABLE Southeastern Literature Citations Benlioglu S., Boz, O., Yildiz A., Kaskavalci G., Benlioglu, K., 2002. Soil Solarization Options in Aydin Strawberry Without Methyl Bromide. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions.

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

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

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

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

California Studies: Reply to MBTOC 2005 Page 65 Ajwa, H. Study conducted from 2001 through 2003. Iodomethane and Iodine  based Materials for Strawberry Production in California. Publication not specified, UC Davis.

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

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

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

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

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

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

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

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

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

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

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

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

Noling J. W. The Practical Realities of Alternatives to Methyl Bromide: Concluding Remarks. Presented at the Methyl Bromide Alternatives  Meeting the Deadlines Symposium. 2002. Published in Phytopathology 92: 1373 1375. Reply to MBTOC 2005 Page 66 Subbarao K. V. Methyl Bromide Alternatives  Meeting the Deadlines. Presented at the 92nd Annual Meeting of the American Phytopathological Society, Augus 14, 2000. Accepted for publication by the American Phytopathological Society on 23 July 2002.

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

Yates S. R., Gan J. Papiernik S. K. Dungan R. and Wang D. Reducing Fumigant Emissions After Soil Application. 2002. Phytopathology 92: 1344 1348. Reply to MBTOC 2005 Page 67 9. FIELD GROWN TOMATOES Overview of the U. S. nomination The U. S. is requesting 2,844.985 metric tons of methyl bromide for use on field grown tomatoes in the following areas: Michigan ( 10.746 metric tons), California ( 102.058 metric tons), and the southeastern U. S. Florida and Georgia as well as other states in the southeast ( 2, 726.68 metric tons) with a small additional amount ( 5.501 metric tons) for research purposes.

Currently registered alternatives to methyl bromide do not consistently provide effective control of nutsedge weed species and more time is needed to evaluate relationship between fumigant alternatives, various mulches, and herbicide systems under different growing conditions.

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

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

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

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

delay in planting and harvesting: e. g., the plant back interval for telone+ chloropicrin is two weeks longer than methyl bromide+ chloropicrin, and in Michigan an additional delay would occur because soil temperature must be higher to fumigate with alternatives. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices.

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

Overview of MBTOC's prior Recommendation MBTOC has recommended a total of 2,217.433 metric tons of methyl bromide distributed as follows: Michigan ( 10.746metric tons), the southeastern U. S. ( 2,197.5 metric tons) and California ( 9.185 metric tons). The research amount was approved.

MBTOC suggests that California can use shank injected 1,3 D/ pic and avoid the problems that drip applied poses on the hilly terrain that forms the basis for the California request. MBTOC asserts that only 9% of the California terrain is precluded from this option due to binding township caps. In the case of the southeastern states, MBTOC has indicated their view that alternatives are technically and economically feasible and applies a 20% phasein factor. MBTOC further states that the dosage can be reduced for a maximum applied rate of 200kg/ ha for the treated areas and may be further reduced if high density films, including VIF are used. Reply to MBTOC 2005 Page 68 California MBTOC has suggested that shank injected 1,3 D/ Pic can be used in all areas that are not currently impacted by the township caps. In making this suggestion they are ignoring both the technical and regulatory factors described above and the actual working of the township caps in California. The township cap is a maximum that can be applied assuming that the method of application is deep shank injection. For all other forms of injection an ` application factor' is applied. The purpose of this application factor is to reduce the amount of 1,3 D that can be applied to a given area, reducing exposure to the population to a level comparable to that experienced when deep shank injection is used.

Deep shank injection cannot be used to control pests in California tomato production. Unlike Florida, where the soils are sandy to a considerable depth, in California the soils are prepared for planting to a depth of 12 18 inches43. The deep shank method injects 1,3 D below this level where the soil is not prepared and breaks into clumps. The soil must be re tilled before planting which risks introducing pathogens back into the planting zone. When shallow shank injection is used, the higher application factors mean that a much smaller area can be injected.

Dr. Legard44 of the California Strawberry Commission has estimated the impact on maximum acreage treated if 1,3 D is ( shallow) shank injected into the soil rather than drip applied a s a liquid. Using Telone C35 ® at 39 50 gallons per treated acre, 138.8 to 178.0 acres per township could be treated. When Inline ® is used at 25 gallons per acre45 473.7 acres per township can be treated. In other words, the use of drip applied 1,3 D results in 2.5 to 3 times as many treated acres. Shank injection of 1,3 D will greatly reduce the acreage treated46.

The U. S. assessment that the alternatives are not technically and economically feasible rests on two kinds of losses47: changes in yields which result in a lesser amount harvested and therefore 43 This corresponds to 30 45 cm. 44 Daniel Legard, PhD, personal communication. January 9, 2005. 45 The common use rate on strawberries in California 46 The main concern associated with broadcast fumigation with telone C35 is related to the telone township cap. There are different emission ratios used for the different application methods that adjusts the amount of telone applied to the township cap. The lbs used are " adjusted" by the following factors ( 1x for deep shank, 1.1x for drip applied, 1.8x for shallow shank). Hopefully, most growers would use deep shank where possible for broadcast telone applications. However, broadcast applications still involve treating approximately 40% more acreage than drip ( 2 row bed and slightly lower for 3 and 4 row beds, which are becoming more popular in the North).

47 From a theoretical perspective there are additional losses that should be included: differences in costs between methyl bromide and the alternatives and changes in yield quality. Cost differences between methyl bromide and the alternatives can occur because the prices of the materials differ, amounts used differ, equipment needs differ, additional materials are needed, such as an additional herbicide, an additional application step, either of the alternative or of some ancillary material is required, or there are additional land preparation or other costs. In practice, cost differences between methyl bromide and alternatives are generally small and can usually be ignored.

Quality difference in the yield, such as smaller, scarred, less sweet, or other differences in fruit quality would also be factors in assessing economic loss. In practice quality differences have not been reported in the available literature and so losses from his source cannot be incorporated into the analysis. Reply to MBTOC 2005 Page 69 lower revenues to farmers, and later yields which resulted in further reduced revenues to farmers ( missed market windows, shorter harvest periods, the inability to grow a second crop). The proportion of loss attributable to each component differs from sector to sector, and within sectors, depending on the local circumstances of the nomination. As an example, for tomatoes in both Michigan and the southeastern United States, approximately 70% to 75% of the loss is attributable to missing the high value market time and 25% to 30% of the loss is attributable to lower yield Southeastern United States MBTOC has asserted that for the southeastern United States alternatives are technically and economically feasible. Using this assertion as a basis they recommend a 20% reduction for phase in of alternatives such as 1,3D/ Pic or metam sodium with or without Pic.

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

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

Included an untreated control for comparison purposes on pest levels

Included methyl bromide as a treatment standard

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

Give estimates of yield changes ( differences)

The U. S. nomination was restricted to those situations where the presence and prevalence of pests (` key' pests) that could not be controlled by alternatives to methyl bromide was moderate to severe48 and would result in yield loss.

As we understand it from discussions at MOP 16, MBTOC used what they describe, interchangeably as a " meta analysis" or an ` average'. The procedure MBTOC used was not a meta analysis in that a meta analysis includes only studies which are similar enough from a statistical standpoint that they can be combined and analyzed as if they comprised one study, and the studies need to be identified, appraised and summarized according to an explicit and reproducible methodology that is designed to answer a specific research question. In this case, the appropriate research question would be the performance of alternatives to methyl bromide under the conditions of the U. S. nomination ( i. e. with moderate to severe pressure from key pests). The null hypothesis would be that alternatives work as well as methyl bromide in the conditions of the U. S. nomination. The U. S. nomination is specifically for the use of methyl bromide where key pests ( pests not adequately controlled by alternatives to methyl bromide) are present at moderate to severe levels and/ or soil, climate, terrain, or regulatory conditions are such that alternatives to methyl bromide either cannot be used or result in significant economic losses when used. These economic losses must be of sufficient magnitude that they render the alternative " not economically feasible" which presents a serious problem in applying the meta analysis. Our understanding is that this analysis includes some studies conducted under 48 In the judgment of U. S. experts pressure was such that yield losses of the magnitude of those used in the economic assessment would be sustained. Reply to MBTOC 2005 Page 70 circumstances that are not similar to the limited conditions included in the U. S. nomination, such as the presence of moderate to severe pest pressure.

Although it is difficult to be certain how the MBTOC analysis was conducted and what it includes because it has not been reviewed and published and was not provided to the U. S. experts to evaluate49, we are able to make some educated guesses about the analysis50. The analysis for strawberry fruit is described in a paper is listed as being " in press" as conference proceedings with a date after the MBTOC recommendations on the U. S. nomination were tendered.

A version of the paper was presented by Dr. Ian Porter at the Methyl Bromide Alternatives Organization meeting in San Diego, November 2003 and was the subject of some controversy and concern among a number of participants. Dr. Porter's paper included a number of papers which U. S. experts believe are not appropriate for use in determining the usefulness of alternatives because the research was carried out under conditions of no pest pressure, and are therefore not relevant to the specific circumstances of our nomination51. If no pests are present any alternative, or indeed not using any pesticide at all, will all work equally well. By including situations where there is no pest pressure one in effect adds ( many) " 100" to the equation52 describing the differences in yield between crops grown using methyl bromide and those grown using an alternative. This has the effect of lowering the average difference between yields using methyl bromide and yields using an alternative. If a sufficient number of " 100" are added, the result will be to ( falsely) eliminate the yield differences between methyl bromide and the alternatives.

In other papers, pests were present but they were not the pests present in the all of the U. S. circumstances. Taking the case of the southeastern US, for example, weeds, diseases, fungi, and nematodes all afflict the crops. Some of these pests can be controlled with alternatives, but some of the weeds, in particular nutsedges ( nut grasses), nightshades, and some hard seed coated weeds, cannot. Situations without weeds will show small or no yield losses when alternatives are used while the true situation when ( key) weeds are present is that there are relatively large yield losses. Including these factors again has the effect of adding " 100" yield difference as many times as there are papers.

49 The US Government requested references from two of the authors of the paper to allow us to better understand the analysis, but this information has not yet been provided 50 Some of this material with references had been previously presented at the Methyl Bromide Alternatives Organization 2003 meeting ( San Diego). At that time U. S. experts expressed their view that many if not most of the studies were not an appropriate application of the information.

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

52 The actual procedure was to add in yields expressed as a percentage of ( anticipated) yield using methyl bromide. How this yield was estimated is puzzling as many of the studies did not include a methyl bromide control. Because there was no indication of pest pressure in many instances, many of the entries indicated yields of approximately 100%, obviating the differences between methyl bromide and the alternatives. Reply to MBTOC 2005 Page 71 If the issue had been to average all papers, describing some " average" worldwide situation, the procedure followed in this approach would be appropriate. However, The U. S. submitted requests for continued methyl bromide use only instances of sufficiently high pest pressure ( not average) for pests which cannot be controlled by alternatives to methyl bromide.

In the case of crops other than strawberries, the basis for MBTOC's suggestion of no differences in yields between methyl bromide treatments and treatments with the alternatives is more difficult to assess. MBTOC representatives at MOP 16 indicated that their " expert judgment" was the basis for the finding that alternatives were technically and economically feasible. It is impossible to determine from this statement whether the conditions used by the experts to make their findings are similar to the particular conditions of the U. S. nomination. Given what we already know about the applicability of the meta analysis for strawberries to the U. S. circumstances, it seems likely that MBTOC is not using experience accrued in situations similar to those prevailing in the portions of the U. S. for which methyl bromide is requested, but rather relying on more generalized experience to make these judgments for which no data or references have been provided.

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

Turning now to the component of economic loss that is a consequence of market timing we find that MBTOC has completely ignored losses arising from market windows.

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

Many of the alternatives will cause farmers to miss the market window. In conditions of cold soil temperatures, such as in Michigan and coastal California, where the growing season is short, alternatives cannot be used until the soil temperatures reach at least 40 F. This temperature is reached 3 4 weeks into the growing season, delaying planting and consequently harvesting for that time. Because the Michigan growing season is already short due to the cold temperatures, even apart from missing the market window, delaying planting will result in a smaller harvestable amount. In other situations the " plant back" interval is longer, by 2 4 weeks, relative to the methyl bromide plant back times. Requiring a longer interval before a crop can be planted will delay the harvesting, again causing a farmer to miss a market window. Some alternatives also require a different bed preparation, which will also delay the planting time. The strawberry crop in California is one example of this situation.

It is difficult to determine the basis MBTOC used in determining that alternatives for methyl bromide are both technically and economically feasible in tomato production. USG technical Reply to MBTOC 2005 Page 72 experts asked MBTOC to explain the basis for their decision53 and were told that in some cases a meta analysis served as the basis, and in other cases the basis was experience. When asked for references, USG experts were directed to " the Porter paper in press". USG experts have examined a " Porter paper in press" 54 and have a number of concerns over its applicability to the specific circumstances of the U. S. CUE. Although it has a publication date of one year later than the San Diego presentation, we find that our concerns over its applicability have not been resolved. The studies used in the meta analysis are not listed and no indication is given of the criteria used to include or exclude a study from the analysis.

There is no indication that MBTOC considered the specific circumstances of the U. S. nomination ( which are that methyl bromide is requested only for situations where regulatory concerns preclude use of an alternative or where there are ` key' pests present at moderate to severe levels, or where terrain conditions ( temperature, topography) result in no alternative being technically and economically feasible). MBTOC has not cited research findings supporting their contention that alternatives are both technically and economically feasible; the U. S. has presented extensive results in the circumstances of the nomination to support our position.

We conclude that, at present, no economically feasible alternatives to MeBr exist for use in Southeastern U. S. tomato production. Two factors have proven most important in our conclusion. These are yield loss and missed market windows, which are discussed individually below.

1. Yield Loss  Expected yield losses of somewhat over 6% 55 are anticipated throughout southeastern U. S. tomato production.

2. Missed Market Windows  We agree with Southeastern US's assertion that growers will likely receive significantly lower prices for their produce if they switch to 1,3 D + chloropicrin. This is due to changes in the harvest schedule caused by the above described soil temperature complications and extended plant back intervals when using these alternatives.

Our analysis of this effect is based on the fact that prices farmers receive for their tomatoes vary widely over the course of the growing season. Driving these fluctuations are the forces of supply and demand. Early in the growing season, when relatively few tomatoes are harvested, the supply is at is lowest and the market price is at its highest. As harvested quantities increase, the 53 MBTOC suggests that alternatives were both technically and economically feasible for the pre plant sectors of field grown peppers, strawberries, and tomatoes. The same assertions were made for portions of other countries' nominations as well. 54 Porter, I., S. Mattner, R. Mann, R. Gounder, J. Banks, and P. Fraser. 1994. Strawberry Fruit Production and results from trials in Different Geographic Regions. A Presentation to the Methyl Bromide Alternatives Conference, Lisbon, September 1994. 55 The submitted data showed that using the above best alternative the growers are expected to suffer 6.2% yield losses ( Chellemi, Botts and Noling. 2001). A combination of 1,3 D + chloropicrin + pebulate appeared to be the best alternative in controlling key pests in tomato fields. Since pebulate is no longer available then the growers will need to substitute another herbicides such as halosulfuron, rimsulfuron or trifloxysulfuron to control nutsedge weeds. These herbicides, however, have significant limitations. In addition, losses will be higher in areas of Karst geology, where 1,3 D may not be used. Reply to MBTOC 2005 Page 73 price declines. In order to maximize their revenues, tomato growers manage their production systems with the goal of harvesting the largest possible quantity of tomatoes when the prices are at their highs. The ability to sell produce at these higher prices makes a significant contribution toward the profitability of tomato operations.

To describe these conditions in Southeastern U. S. tomato production, we used weekly tomato sales data from the U. S. Department of Agriculture for the previous three years to gauge the impact of early season price fluctuations on gross revenues. Though data availability is limiting, we assume that if tomato growers adjust the timing of their production system, as required when using 1,3 D + Chloropicrin, that they will, over the course of the growing season, accumulate gross revenues reduced by approximately 15%. We reduced the season average price by 15% in our analysis of the alternatives to reflect this. Based on currently available information, we believe this reduction in gross revenues serves as a reasonable indicator of the typical effect of planting delays resulting when MeBr alternatives are used in Southeastern US.

MBTOC has suggested that rates can be reduced to a maximum level of 200kg/ ha MBTOC has also reduced the amount recommended for tomatoes stating: " A further adjustment was applied to reduce the dosage to the guideline level of 200kg/ ha under the strips." When this issue was discussed with MBTOC members during the 16th MOP, U. S. experts agreed to clarify whether the reported rates were in fact the rates used under the strips ( as the U. S. believed) or whether they were the average for an acre as MBTOC believed56. The U. S. has verified that the application rates provided in the quantitative assessment ( the Methyl Bromide Usage Numerical Index, or BUNI) are in fact the rates under the strips. The number of acres reported is the " treated acres", so that a strip application results in two thirds of an acre being fumigated while one third is the untreated is reported as two thirds of an acre.

They have further suggested that rates can be reduced still further if higher density tarps, including VIF, are used. One of the papers cited in support of this proposal is Fennimore et el, 2003. Fennimore was contacted to determine whether, in his opinion, his work could be appropriately used to support lower application rates. His reply, reproduced below, indicates that he is very uncomfortable with this interpretation of his results57.

56 If the rates were an average per acre, as MBTOC believed, given that in strip treatments approximately one third of the acre is left untreated, the rates applied would, in some cases, exceed the MBTOC recommended dosage of 200kg/ ha. 57 From: Steven Fennimore [ mailto: safennimore@ ucdavis. edu] Sent: Fri Jan 07 16: 24: 43 2005 To: Dan Legard Cc: jmduniway@ ucdavis. edu; haajwa@ ucdavis. edu Subject: MBTOC VIF stance Hi Dan I am a bit disturbed to learn from you that the some in MBTOC may have come to the conclusion that VIF will allow reduced rates of methyl bromide. While I stand behind my research that indicates clearly that the weed control efficacy of drip applied chloropicrin and Inline are improved under VIF compared to standard film, these fumigants are used to Reply to MBTOC 2005 Page 74 Technical and Economic Assessment of MBTOC/ TEAP Report. We have not been provided by MBTOC with information on their technical assessment of the performance of alternatives, ortheir economic assessment on the impact of converting to alternatives. To support the MBTOC's recommended change in the U. S. request citations of the research references and economic assessments that led to the MBTOC conclusions are needed so we can understand the justification. The technical references should describe the species tested, pest numbers, concentrations, times, and commodity volumes. Economic references should describe the costs of converting from methyl bromide to alternatives, the impact of higher yield losses, longer plant back intervals, the economic feasibility if key market windows are missed, and the economic impact of a 20% transition to alternatives including estimates of management costs for more intensive programs and how the impact of less reliable alternatives is calculated. The sources of estimates of the extent of pest pressure should describe the rationale for using other estimates, a complete description of the questions, species being surveyed and quantitative levels used.

U. S. 2006 nomination In summary, the USG does not agree with MBTOC's contention that the U. S. request can be reduced and reiterates it request for an additional 622.053 metric tons of methyl bromide for a total of 2,844.985 metric tons of methyl bromide.

Citations Chellemi, D., Botts, D. A. and Noling, J. W. 2001. Field scale demonstration/ validation studies of methyl bromide in plastic mulch culture in Florida, USDA ARS specific co operative agreement SCA # 58 6617 6 013, Executive Summary ( 1996 2001) submitted to the USEPA

control many other pests besides weeds. For example, results do not necessarily suggest that VIF improves phytopthora cactorum control. Our research results presented at MBAO are preliminary and we are currently preparing peer reviewed publications. When those are written we will have a more clear understanding of the potential benefits and limitations of VIF than we have now. I do believe that VIF offers real potential benefits, however I caution anyone to make policy decisions about VIF based on my preliminary results presented at MBAO Steve Fennimore Extension Specialist University of California, Davis 1636 East Alisal St Salinas, CA 93905 831 755 2896 Reply to MBTOC 2005 Page 75 Burnette, G. 2003. Personal communication, November 25, 2003.

Culpepper, Stanley. 2004. Faculty, University of Georgia, Athens, GA. Comments on methyl bromide Critical use nomination for preplant soil use for tomato grown in open fields.

Florida. 2000. Florida soil temperatures. Web address: www. imok. ufl/ edu/ weather/ archive/ 200/ clim00 Hausbeck, M. and Cortright, B. 2003. Soil temperature data submitted to BEAD ( OPP, US EPA) in support of methyl bromide critical use exemption application.

Jacob, W. C. 1977. Range of mean outside temperature and rainfall in South Eastern United States. Climatic Atlas of the United States. Published by the US Department of Commerce.

Lamour, H. H. and Hausbeck, M. 2003. Effect of crop rotation on the survival of Phytophthora capsici in Michigan. Plant Disease 87: 841 845.

Locasio, S. J., Gilreath, J. P., Dickson, D. W., Kucharek, T. A., Jones, J. P. and Noling, J. W. 1997. Fumigant alternatives to methyl bromide for polyethylene mulched tomato. HortScience 32( 7) 1208 1211.

Morales, J. P., Santos, B. M., Stall, W. M. and Bewick. T. A. 1997. Effects of purple nutsedge ( Cyprus rotundus) on tomato and bell pepper vegetative growth and fruit yield. Weed Science Technology 11: 672 676.

Nelson, K. A. and Renner, K. A. 2002. Yellow nutsedge ( Cyprus esculentus) control and tuber production with glyphosate and ALS inhibiting herbicides. Weed Technology 16( 3): 512 519.

Norton, J., Nelson, R. D., Nelson, M. D., Olson, B. O., Mey, B. V. and Lepez, G. 2000. Field evaluation of alternatives to methyl bromide for pre plant soil fumigant in California tomatoes. USDA IR 4 methyl bromide alternatives program for minor crop. Report submitted to the US EPA during 2003 in support of methyl bromide critical use exemption.

Stall, W. M. and Morales Payan, J. P. 2003. The critical period of nutsedge interference in tomato, Florida. Web address: http:// www. imok. ufl. edu/ liv/ groups/ ipm/ weed_ con/ nutsedge. htm U. S. Environmental Protection Agency. 1998. Re registration Eligibility Decision ( RED) 1,3 dichloroprppene. Available at http:// www. epa. gov/ REDs/ 0328red. pdf U. S. Environmental Protection Agency. 1998. Feasibility of using gas permeable tarps to reduce methyl bromide emissions associated with soil fumigation in the United States.