Methyl Bromide Critical Use Nomination for Preplant Soil Use on
strawberry nurseries in Open Fields or in Protected Environments

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 Strawberry Nurseries Grown in Open
Fields or in Protected Environments (Submitted in 2006 for the 2008 Use
Season)

Nominating Party Contact Details

Contact Person:	John E. Thompson, Ph. D.

Title:	International Affairs Officer

Address:	Office of Environmental Policy

	U.S. Department of State

	2201 C Street N.W. Room 4325

	Washington, DC 20520

	U.S.A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail:	  HYPERLINK<EMAIL_ADDRESS><EMAIL_ADDRESS>

Following the requirements of Decision IX/6 paragraph (a)(1), the United
States of America has determined that the specific use detailed in this
Critical Use Nomination is critical because the lack of availability of
methyl bromide for this use would result in a significant market
disruption.

( Yes                                  ( No

Signature

Name

Date

Title:

Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Acting Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U.S.A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail<EMAIL_ADDRESS>

List of Documents Sent to the Ozone Secretariat in Official Nomination
Package

List all paper and electronic documents submitted by the Nominating
Party to the Ozone Secretariat

Paper Documents:

Title of Paper Documents and Appendices	Number of Pages	Date Sent to
Ozone Secretariat

electronic copies of all paper documents:

Title of Electronic Files	Size of File (kb)	Date Sent to Ozone
Secretariat

Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125769766"  Part A: Summary
PAGEREF _Toc125769766 \h  6

  HYPERLINK \l "_Toc125769767"  1. Nominating Party	  PAGEREF
_Toc125769767 \h  6

  HYPERLINK \l "_Toc125769768"  2. Descriptive Title of Nomination
PAGEREF _Toc125769768 \h  6

  HYPERLINK \l "_Toc125769769"  3. Crop and Summary of Crop System
PAGEREF _Toc125769769 \h  6

  HYPERLINK \l "_Toc125769770"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125769770 \h  6

  HYPERLINK \l "_Toc125769771"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125769771 \h  6

  HYPERLINK \l "_Toc125769772"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125769772 \h  7

  HYPERLINK \l "_Toc125769773"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125769773 \h  8

  HYPERLINK \l "_Toc125769774"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125769774 \h  8

  HYPERLINK \l "_Toc125769775"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125769775 \h  9

  HYPERLINK \l "_Toc125769776"  Southeastern States - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125769776 \h  9

  HYPERLINK \l "_Toc125769777"  Southeastern States - 10. Key Diseases
and Weeds for which Methyl Bromide Is Requested and Specific Reasons for
this Request	  PAGEREF _Toc125769777 \h  9

  HYPERLINK \l "_Toc125769778"  Southeastern States - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125769778
\h  10

  HYPERLINK \l "_Toc125769779"  Southeastern States - 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested	  PAGEREF _Toc125769779 \h
11

  HYPERLINK \l "_Toc125769780"  Southeastern States - Part C: Technical
Validation	  PAGEREF _Toc125769780 \h  12

  HYPERLINK \l "_Toc125769781"  Southeastern States - 13. Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125769781 \h  12

  HYPERLINK \l "_Toc125769782"  Southeastern States - 14. List and
Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:
PAGEREF _Toc125769782 \h  18

  HYPERLINK \l "_Toc125769783"  Southeastern States - 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125769783 \h  18

  HYPERLINK \l "_Toc125769784"  Southeastern States - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested
 PAGEREF _Toc125769784 \h  18

  HYPERLINK \l "_Toc125769785"  Southeastern States - 17. Are There Any
Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide	  PAGEREF _Toc125769785 \h  20

  HYPERLINK \l "_Toc125769786"  Southeastern States - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide	  PAGEREF _Toc125769786 \h  20

  HYPERLINK \l "_Toc125769787"  Southeastern States - Summary of
Technical Feasibility	  PAGEREF _Toc125769787 \h  20

  HYPERLINK \l "_Toc125769788"  California - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125769788 \h  21

  HYPERLINK \l "_Toc125769789"  California - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc125769789 \h  21

  HYPERLINK \l "_Toc125769790"  California - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125769790 \h  21

  HYPERLINK \l "_Toc125769791"  California – 11. (ii) Indicate if any
of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?	  PAGEREF _Toc125769791 \h  22

  HYPERLINK \l "_Toc125769792"  California - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc125769792 \h  23

  HYPERLINK \l "_Toc125769793"  California - Part C: Technical
Validation	  PAGEREF _Toc125769793 \h  24

  HYPERLINK \l "_Toc125769794"  California - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125769794 \h  24

  HYPERLINK \l "_Toc125769795"  California - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125769795 \h  24

  HYPERLINK \l "_Toc125769796"  California - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125769796 \h  24

  HYPERLINK \l "_Toc125769797"  California - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested
 PAGEREF _Toc125769797 \h  24

  HYPERLINK \l "_Toc125769798"  California - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125769798 \h  32

  HYPERLINK \l "_Toc125769799"  California - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide
PAGEREF _Toc125769799 \h  32

  HYPERLINK \l "_Toc125769800"  California - Summary of Technical
Feasibility	  PAGEREF _Toc125769800 \h  32

  HYPERLINK \l "_Toc125769801"  Part D: Emission Control	  PAGEREF
_Toc125769801 \h  33

  HYPERLINK \l "_Toc125769802"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use
 PAGEREF _Toc125769802 \h  33

  HYPERLINK \l "_Toc125769803"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125769803 \h  33

  HYPERLINK \l "_Toc125769804"  Part E: Economic Assessment	  PAGEREF
_Toc125769804 \h  34

  HYPERLINK \l "_Toc125769805"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125769805 \h  34

  HYPERLINK \l "_Toc125769806"  Southeastern States-22. Gross and Net
Revenue	  PAGEREF _Toc125769806 \h  34

  HYPERLINK \l "_Toc125769807"  California-22. Gross and Net Revenue
PAGEREF _Toc125769807 \h  35

  HYPERLINK \l "_Toc125769808"  Summary of Economic Feasibility
PAGEREF _Toc125769808 \h  36

  HYPERLINK \l "_Toc125769809"  Part F. Future Plans	  PAGEREF
_Toc125769809 \h  38

  HYPERLINK \l "_Toc125769810"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125769810 \h  38

  HYPERLINK \l "_Toc125769811"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125769811 \h  38

  HYPERLINK \l "_Toc125769812"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125769812 \h  38

  HYPERLINK \l "_Toc125769813"  26. Citations	  PAGEREF _Toc125769813 \h
 39

  HYPERLINK \l "_Toc125769814"  Appendix B. California Strawberry
Nursery Narrative, 2005	  PAGEREF _Toc125769814 \h  45

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125187603"  Part A:
Summary	  PAGEREF _Toc125187603 \h  6

  HYPERLINK \l "_Toc125187604"  Table 4.1: Methyl Bromide Nominated
PAGEREF _Toc125187604 \h  6

  HYPERLINK \l "_Toc125187605"  Table A.1: Executive Summary	  PAGEREF
_Toc125187605 \h  7

  HYPERLINK \l "_Toc125187606"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125187606 \h  8

  HYPERLINK \l "_Toc125187607"  Southeastern States and California-
Table 8.1: Amount of Methyl Bromide Requested for Critical Use	  PAGEREF
_Toc125187607 \h  8

  HYPERLINK \l "_Toc125187608"  Southeastern States - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125187608 \h  9

  HYPERLINK \l "_Toc125187609"  Southeastern States - Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request	  PAGEREF
_Toc125187609 \h  9

  HYPERLINK \l "_Toc125187610"  Southeastern States - Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125187610 \h  10

  HYPERLINK \l "_Toc125187611"  Southeastern States - Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125187611 \h
10

  HYPERLINK \l "_Toc125187612"  Southeastern States - Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125187612 \h  11

  HYPERLINK \l "_Toc125187613"  Southeastern States - Part C: Technical
Validation	  PAGEREF _Toc125187613 \h  12

  HYPERLINK \l "_Toc125187614"  Southeastern States – Table 13.1:
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125187614 \h
12

  HYPERLINK \l "_Toc125187615"  Southeastern States – Table 14.1:
Technically Infeasible Alternatives Discussion	  PAGEREF _Toc125187615
\h  18

  HYPERLINK \l "_Toc125187616"  Southeastern States – Table 15.1:
Present Registration Status of Alternatives	  PAGEREF _Toc125187616 \h
18

  HYPERLINK \l "_Toc125187617"  Southeastern States – Table 16.1:
Effectiveness of Alternatives –Weeds 1	  PAGEREF _Toc125187617 \h  19

  HYPERLINK \l "_Toc125187618"  Southeastern States – Table C.1:
Alternatives Yield Loss Data Summary	  PAGEREF _Toc125187618 \h  19

  HYPERLINK \l "_Toc125187619"  California - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125187619 \h  21

  HYPERLINK \l "_Toc125187620"  California - Table 10.1: Key Diseases
and Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125187620
\h  21

  HYPERLINK \l "_Toc125187621"  California - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc125187621 \h  21

  HYPERLINK \l "_Toc125187622"  California - Table 11.2 Characteristics
of Climate and Crop Schedule	  PAGEREF _Toc125187622 \h  22

  HYPERLINK \l "_Toc125187623"  California - Table 11.3 Characteristics
of Climate and Crop Schedule	  PAGEREF _Toc125187623 \h  22

  HYPERLINK \l "_Toc125187624"  California - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125187624 \h  23

  HYPERLINK \l "_Toc125187625"  California - Part C: Technical
Validation	  PAGEREF _Toc125187625 \h  24

  HYPERLINK \l "_Toc125187626"  Southeastern States – Table 13.1:
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125187626 \h
24

  HYPERLINK \l "_Toc125187627"  Southeastern States – Table 14.1:
Technically Infeasible Alternatives Discussion	  PAGEREF _Toc125187627
\h  24

  HYPERLINK \l "_Toc125187628"  California – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125187628 \h  24

  HYPERLINK \l "_Toc125187629"  California – Table 16.1: Effectiveness
of Alternatives – Chemical Alternatives to Methyl Bromide Fumigation
– How Well Do They Work?	  PAGEREF _Toc125187629 \h  26

  HYPERLINK \l "_Toc125187630"  California – Table 16.2: Effectiveness
of Alternatives Chloropicrin Effect on Weed Seed Viability.	  PAGEREF
_Toc125187630 \h  27

  HYPERLINK \l "_Toc125187631"  California – Table 16.3: Effectiveness
of Alternatives - Soil Fumigation and Runner Plant Production.	  PAGEREF
_Toc125187631 \h  28

  HYPERLINK \l "_Toc125187632"  California – Table 16.4: Effectiveness
of Alternatives - Evaluation of Alternatives  to Methyl Bromide for Soil
Fumigation at Commercial Fruit and Nut Tree Nurseries	  PAGEREF
_Toc125187632 \h  29

  HYPERLINK \l "_Toc125187633"  California – Table 16.5a and 16.5b:
Effectiveness of Alternatives - Evaluation of Alternatives  to Methyl
Bromide for the Control of Soil Pests	  PAGEREF _Toc125187633 \h  30

  HYPERLINK \l "_Toc125187634"  California – Table 16.5a: Fruit yield
(grams per plant) of strawberry at Watsonville, CA in 2002	  PAGEREF
_Toc125187634 \h  30

  HYPERLINK \l "_Toc125187635"  California – Table 16.5b: Fruit yield
(grams per plant) of strawberry at Watsonville, CA in 2003	  PAGEREF
_Toc125187635 \h  31

  HYPERLINK \l "_Toc125187636"  California – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125187636 \h  32

  HYPERLINK \l "_Toc125187637"  Part D: Emission Control	  PAGEREF
_Toc125187637 \h  33

  HYPERLINK \l "_Toc125187638"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125187638 \h  33

  HYPERLINK \l "_Toc125187639"  Part E: Economic Assessment	  PAGEREF
_Toc125187639 \h  34

  HYPERLINK \l "_Toc125187640"  Table 21.1: Operating Costs with
Alternatives Compared to Methyl Bromide Over 3-Year Period	  PAGEREF
_Toc125187640 \h  34

  HYPERLINK \l "_Toc125187641"  Southeastern States-Table 22.1: Years 1,
2, and 3 Gross and Net Revenue	  PAGEREF _Toc125187641 \h  34

  HYPERLINK \l "_Toc125187642"  California-Table 22.1: Years 1, 2, and 3
Gross and Net Revenue	  PAGEREF _Toc125187642 \h  35

  HYPERLINK \l "_Toc125187643"  Southeastern States - Table E.1:
Economic Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125187643
\h  35

  HYPERLINK \l "_Toc125187644"  California - Table E.2: Economic Impacts
of Methyl Bromide Alternatives	  PAGEREF _Toc125187644 \h  36

  HYPERLINK \l "_Toc125187645"  Part F. Future Plans	  PAGEREF
_Toc125187645 \h  38

  HYPERLINK \l "_Toc125187646"  APPENDIX A.  2007 Methyl Bromide Usage
Numerical Index (BUNI).	  PAGEREF _Toc125187646 \h  44

  HYPERLINK \l "_Toc125187647"  Appendix B. California Strawberry
Nursery Narrative, 2005	  PAGEREF _Toc125187647 \h  45

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

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

The United States of America (U.S.)

2. Descriptive Title of Nomination   TC "2. Descriptive Title of
Nomination" \f C \l "2"

Methyl Bromide (MB) Critical Use Nomination for Preplant Soil Use for
Strawberry Nurseries in Open Fields or in Protected Environments
(Prepared in 2005 for the 2008 Use Season)

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

Southeastern U.S. growers (from Maryland, North Carolina, and Tennessee)
produce transplants in open fields.  An individual field is planted to
strawberries once every three years.  Approximately 85% of transplants
produced are exported to Florida.

California growers produce their transplants over a five-year cycle (see
Appendix B for an extensive overview—submitted by the California
Strawberry Commission—of the California strawberry nursery production
system).  Screenhouses are used during the first two years and open
field plantings are used during the last three years.  MeBr is needed in
production years 2 thru 5.  Individual planting sites are planted to
strawberries once every three years.  The fourth and fifth production
years account for 22% and 77%, respectively, of the current MeBr nursery
usage in California.  Transplants produced are distributed widely
throughout the U.S. and other countries.

4. Methyl Bromide Nominated  TC "4. Methyl Bromide Nominated" \f C \l
"2"

Table 4.1: Methyl Bromide Nominated  TC "Table 4.1: Methyl Bromide
Nominated" \f F \l "1"

Year	Nomination Amount (kg)*	Nomination Area (ha)

2008	8,838	31

* Includes research amount of 454 kgs.

5. Brief Summary of the Need for Methyl Bromide as a Critical Use  TC
"5. Brief Summary of the Need for Methyl Bromide as a Critical Use" \f C
\l "2"

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

Pest control efficacy of alternatives: the efficacy of alternatives may
not be comparable to MeBr in some areas, making these alternatives
infeasible

Quarantine and Pre-Shipment uses are not included in this CUE

For the 2008 season, MeBr is critical for strawberry nurseries to
produce plants free of diseases and nematodes to meet state and foreign
certification standards, as well as prospective buyer expectations.  In
addition to these certification-related pest control concerns, weed
control is also essential to insure maximum runner production and
prevent the spread of noxious weeds.  The available alternatives have
not been developed sufficiently to provide effective control of the key
pests to depths of 1 m.  In addition, there are no markets for plants
that do not meet the certification standards, which mean that losses up
to 100% are possible when inadequate pest control occurs.  Failure to
adequately manage pests in transplants will jeopardize the viability of
the transplant and fruit production industries in the U.S., as well as
the viability of fruit production in countries purchasing U.S. plants
(e.g., Canada, Mexico, Spain, countries in South America, and some
others).

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

Region	California 	Southeastern States

Amount of Applicant Request

 Kilograms	4,690 	34,934

Amount of Nomination*

	2008 Kilograms	4,690 	3,693

	* See Appendix A for complete description on how nominated amount was
calculated.

6. Summarize Why Key Alternatives Are Not Feasible  TC "6. Summarize Why
Key Alternatives Are Not Feasible" \f C \l "2"

The key alternatives are 1,3-dichloropropene (1,3-D)/chloropicrin,
1,3-D/chloropicrin/metam-sodium, and 1,3-D/metam-sodium.  Dazomet is
also a possible alternative probably in combination with chloropicrin
and/or 1,3-D.  These chemicals, in addition to other strategies, such as
use of high density tarps, may ultimately reduce or replace MB.
However, to maintain certification quality protocols for effective use
of these alternatives have not been sufficiently developed to provide
adequate disease and nematode control throughout the root zone (up to 1
m deep).  Additionally, these alternatives will require further study to
show their consistency in providing control of yellow and purple
nutsedge (Cyperus esculentus, C. rotundus) (SE states only) and a number
of other critical weed pests in California (Table 10.1).  The
certification requirements associated with the requesting states are
strict (virtually zero tolerance for any damaging diseases and
plant-parasitic nematodes) in order to minimize the prospect of
spreading these nematode and diseases to other states and countries
where these plants are shipped.  Research has been cited (e.g., Kabir et
al., 2003) in this review that indicates potential alternatives for some
nurseries, but the need for MeBr for 2008 is critical until alternatives
have been sufficiently tested for use in commercial strawberry nursery
operations.

7. (i) Proportion of Crops Grown Using Methyl Bromide  TC "7. Proportion
of Crops Grown Using Methyl Bromide" \f C \l "2"

Table 7.1: Proportion of Crops Grown Using Methyl Bromide  TC "Table
7.1: Proportion of Crops Grown Using Methyl Bromide" \f F \l "1"

Region where Methyl Bromide use is requested	Total crop area –
2001-2002 Average (ha)	Proportion of total crop area treated with methyl
bromide (%)

Southeastern States	69	100

California	1,386	100

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.

Pest-free standards for nursery stock make complete transition to
alternatives difficult.

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?

Not applicable because the alternatives have not been proven effective
for the control of the target pests in nursery production.

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

Southeastern States And California- Table 8.1: Amount of Methyl Bromide
Requested for Critical Use  TC "Southeastern States and California-
Table 8.1: Amount of Methyl Bromide Requested for Critical Use" \f F \l
"1"

Region: 	SOUTHEASTERN STATES	CALIFORNIA

Year of Exemption Request	2008	2008

Kilograms of Methyl Bromide	34,934	4,690

Use: Flat fumigation or Strip/Bed Treatment	FLAT FUMIGATION	FLAT
FUMIGATION

Formulation (ratio of methyl bromide/chloropicrin mixture) to be used
for the CUE	67:33	67:33

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (ha)	85	18 (w/o QPS)

Application rate (kg/ha) for the formulation	604	390

Application rate (kg/ha) for METHYL BROMIDE	413	263

Dosage rate (g/m2) of formulation used to calculate requested kilograms
of methyl bromide	60.4	39.0

Dosage rate (g/m2) of METHYL BROMIDE 	41.1	26.1

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

The amount of methyl bromide 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.  Values greater than 100 percent are due to the inclusion
of additional varieties in the applicant’s request that were not
included in the USDA National Agricultural Statistics Service surveys of
the crop.

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

 Growth or increasing production (the amount of area requested by the
applicant that is greater than that historically treated) was
subtracted.  The two applicants that included growth in their request
had the growth amount removed.

There was a small adjustment for use rate in one of the applications.

Quarantine and pre-shipment (QPS) hectares is the area in the
applicant’s request subject to QPS treatments.  Both applicants had
QPS listed the amount requested and reflects the subtraction of the QPS
amount.

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

Southeastern States - Part B: Crop Characteristics and Methyl Bromide
Use  TC "Southeastern States - Part B: Crop Characteristics and Methyl
Bromide Use" \f F \l "1"    TC "Southeastern States - Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"

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

Southeastern States - Table 10.1: Key Diseases and Weeds and Reason for
Methyl Bromide Request  TC "Southeastern States - Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request" \f F \l "1"

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level (and % of total growing area
with moderate-severe infestation of pest)	Specific reasons why methyl
bromide is needed

Southeastern Nurseries	Weeds: Yellow nutsedge (Cyperus esculentus) and
Purple nutsedge (Cyperus rotundus) (50%)

Diseases: Black root rot (Rhizoctonia and Pythium spp.) (100%); Crown
rot (Phytophthora cactorum) (<5%); root-knot nematodes (Meloidogyne
spp.) (100%)	The major issue for pest management in the nursery is the
zero-tolerance threshold for pests.  To meet certification and
production requirements, MeBr is critical for the portion of nursery
land that cannot accomplish certification otherwise.

Southeastern States - 11. (i) Characteristics of Cropping System and
Climate  TC " Southeastern States - 11. Characteristics of Cropping
System and Climate" \f C \l "2"

Southeastern States - Table 11.1: Characteristics of Cropping System  TC
" Southeastern States - Table 11.1: Characteristics of Cropping System"
\f F \l "1"

Characteristics	Southeastern States

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

Annual or Perennial Crop: (# of years between replanting) 	Annual crop,
replanted in same site once every three years

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	Various crops planted

Soil Types:  (Sand, loam, clay, etc.)	93% medium and 7% light soils,
containing up to 2% organic matter

Frequency of methyl bromide Fumigation:

(e.g. every two years)	Every year

Other relevant factors:	None identified

Southeastern States - Table 11.2 Characteristics of Climate and Crop
Schedule  TC " Southeastern States - Table 11.2 Characteristics of
Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	6a, 6b, 7a, 7b, 8a, 8b

Rainfall (mm)	163	124	109	87	78	146	113	202	109	116	54	76

Outside Temp. ((C)	9.4	14.5	17.7	23.4	26	25.9	22.6	14.9	7.7	3.4	2.9	4.2

Fumigation Schedule

	X	X

Planting

Schedule

X	X

	Harvest schedule

	2X	X

* Macon, GA

Southeastern States – 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?

None were identified as being limiting factors.

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

Southeastern States - Table 12.1 Historic Pattern of Use of Methyl
Bromide  TC "Southeastern States - Table 12.1 Historic Pattern of Use of
Methyl Bromide" \f F \l "1"

For as many years as possible as shown specify:	1999	2000	2001	2002	2003
2004

Area Treated (hectares)	82	55	67	71	75	83

ratio of flat fumigation methyl bromide use to strip/bed use if strip
treatment is used	Nearly all flat fumigation	Nearly all flat fumigation
Nearly all flat fumigation	Nearly all flat fumigation	Nearly all flat
fumigation	Nearly all flat fumigation

Amount of methyl bromide active ingredient used

(total kilograms)	33,764	22,900	27,747	29,251	30,923	34,433

formulations of methyl bromide

(methyl bromide/ chloropicrin)	67:33	67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied 	Soil injection	Soil injection
Soil injection	Soil injection	Soil injection	Soil injection

Application rate of formulations in kg/ha	619	619	619	619	619	619

Application rate of Methyl Bromide in kg/ha*	413	413	413	413	413	413

Actual dosage rate of formulations (g/m2)*	61.9	61.9	61.9	61.9	61.9	61.9

Actual dosage rate of METHYL BROMIDE (g/m2)*	41.3	41.3	41.3	41.3	41.3
41.3

Southeastern States - Part C: Technical Validation  TC "Southeastern
States - Part C: Technical Validation" \f F \l "1"    TC "Southeastern
States - Part C: Technical Validation" \f C \l "1"

Southeastern States - 13. Reason for Alternatives Not Being Feasible  TC
"Southeastern States - 13. Reason for Alternatives Not Being Feasible"
\f C \l "2"

Southeastern States – Table 13.1: Reason for Alternatives Not Being
Feasible  TC "Southeastern States – Table 13.1: Reason for
Alternatives Not Being Feasible" \f F \l "1"

Name of Alternative	Technical and regulatory* reasons for the
alternative not being feasible or available 	Is the

alternative considered cost effective?

Chemical Alternatives

Chloropicrin	Reduced efficacy on nutsedge (Locascio 1997 & 1999); in
some instances it caused increased emergence of nutsedge (Motis and
Gilreath 2002); Unlikely that nematode control required by state
certification programs can be attained throughout the 1 m root zone.

Chloropicrin is generally considered a good control measure for certain
pathogens (Pythium, Phytophthora, Fusarium, Verticillium), but is not
considered effective for nematode or weed control.  [See also
chloropicrin issues addressed in the fumigant combination entries in
this section.]	No

Non Chemical Alternatives

Biofumigation	Lack of adequate data on the activity of biofumigation
materials on nutsedge control; Based on studies with other crops,
allelochemicals may cause phytotoxic effects (Norsworthy 2002; Johnson
et al. 1993); unlikely that the level of disease and nematode control
required by state certification programs can be attained throughout the
1 m deep root zone.

Biofumigation is not feasible alone because it does not provide
adequate, or consistent, control of target pests to produce a
certifiable strawberry nursery stock.  Research conducted in Florida
showed some control of plant pathogens, but no control of nematodes or
weeds in the soil.  In cases where biofumigation have been shown to
control weeds, the data are mostly for small-seeded weed species that
have small carbohydrate energy sources compared to nutsedge.  The data
on biofumigation are too limited to consider it as a practical
alternative to methyl bromide, and strategies to incorporate
biofumigation with other alternatives have not been adequately
developed.

It is not clear that Brassica crops can be supplied in such quantity
needed to control target pests.  Estimates are that the biofumigant
would have to occupy approximately 3 hectares for every hectare of
strawberry production.  Incorporation of Brassica at these levels would
be likely to have allelopathic effects on the target crop. 	No

Solarization	Even in warm climates (Georgia) it is difficult to attain
temperatures lethal to nutsedge (50-55(C) at depths below 10 centimeters
(Miles et. al. 2002).  However, research to enhance the efficacy of
solarization with tarps is being conducted (e.g., Arbel et al., 2003).

Solarization is not a feasible alternative by itself because it does not
provide adequate control of target pests to produce certifiable
strawberry nursery stock.  Use of solarization might not be practical
due to the depth of heating required to eliminate viable weed seed,
nematodes, and disease organisms.  The time for solarization to raise
soil temperatures to the level needed to kill soil pathogens in most
strawberry nursery regions is likely to also be the time when the crops
themselves must complete their growth cycle.  In one Southeast field
trial, solarization gave poor yields in two years out of three with
losses ranging from 0% to 40% (Miles et. al. 2002).	No

General IPM	IPM, the use of pest monitoring activities coupled with
chemical and non-chemical management tools, has been adopted already for
management of weed, diseases, and nematodes in most nurseries.

General IPM is being used in strawberry nursery stock production, but it
is not feasible alone to provide adequate pest control.   IPM practices
include field sanitation to limit inoculum buildup, crop rotation to
provide non host periods, and breeding for resistance to pathogens.

	No

Cover crops mulching	Cover crops/mulching is currently being used but it
is not feasible as a replacement for MB; disease and nematode control
required by state certification programs require several years of
pest-free history prior to certification.

Some cover crops that have been shown to reduce weed populations also
reduced or delayed crop maturity and/or emergence, as well as yields
(Burgos et al., 1996; Galloway et al., 1996).  Cowpea and sun hemp have
been shown to suppress nutsedge, but the effect is short lived due to
the weed’s capacity for rapid tuber production. Allelochemicals
released by some cover crops or organic mulches can injure crops
(Johnson et al., 1993; Norsworthy, 2002).

	No

Crop rotation/fallow	Growers typically use this practice by growing
other crops in two out of three years; this practice has not resulted in
a level of disease and nematode control required by state certification
programs throughout the 1 m deep root zone; no suitable nutsedge
controls are available during production of the rotational crops
(Culpepper, 2002).

A three-year crop rotation/fallow is being used in strawberry nursery
stock production in conjunction with other pest management strategies
(e.g., 1,3-D).  Strategies for use with other alternatives are being
studied, but are not currently developed to use in a commercial nursery
for the 2008 use season.

Although such crop rotation and fallow procedures are generally
considered useful pest management tools for weeds, diseases and
nematodes, they are rarely considered standalone control measures.
Significantly longer time frames may produce higher levels of control
for most pests, but are generally considered impractical because of
limited land availability and high costs.

Johnson & Mullinix (1997) showed that uninterrupted plantings of peanut,
corn, or cotton, with moderate levels of weed management suppressed
yellow nutsedge in Georgia.  Their data also showed an increase in
nutsedge densities in fallow plots, likely due to the longevity of
nutsedge tubers in soil, mild winters that prevent winter-kill of
tubers, and the ability of tubers to regenerate with the long growing
season in the southeastern coastal plain.  	No

Soilless culture	Soilless culture is not being used, and it is not
feasible for 2008, because it would require a costly transformation of
the U.S. production system.  According to data provided by The National
Center for Food and Agricultural Policy, a greenhouse typically costs
between US$12.5 million and US$20 million per hectare.  Although yields
obtained through greenhouse production are higher than yields of the
best growers, the issue of capitalization for this and other sectors
make the alternative not feasible as a near term strategy to reduce
reliance on MB.	No

Substrates/plug plants grown hydroponically	Substrates/plug plants are
currently being produced and sold in the southeast and to a limited
extent in California, but this method alone does not provide pest
control and would fail to produce a pest free product.  Furthermore,
this method would require extensive retooling by the nursery industry,
and would be costly to change to this technology—not likely, prior to
the 2008 use season.	No

Combinations of Alternatives

1,3-D + chloropicrin	Inconsistent efficacy on nutsedge (Locascio 1997 &
1999); level of disease and nematode control required by state
certification programs might be problematic throughout the 1 m deep root
zone under some conditions; may be the best alternative, especially
where nutsedge is not a problem (50% of production area in Southeastern
U.S.).

This combination provides good nematode and disease control, but
inconsistent weed control.  A 30.5 meter (100 feet) 1,3-D buffer
requirement, to mitigate area resident exposure, would be particularly
constraining on smaller fields in predominantly urban fringe areas,
which is typical for the Southeastern U.S. growers.  Personal Protective
Equipment (PPE) requirements also limit operations that require workers
in the field, particularly given the high temperatures which occur in
the southeast, which are exacerbated by high humidity.  Workers wearing
the required PPE become at risk for possible heat exhaustion or heat
stroke.  For example, PPE may require applicators to wear fully sealed
suits with respirators.  Such suits do not have refrigeration
components, and under conditions of high heat and humidity, can become
unbearable for a typical applicator.  Growers believe that the
requirements for buffers and PPE may make it impractical to adopt 1,3-D.
 The buffer requirements, especially for the small farms in the
Southeastern U.S., eliminate significant growing areas around the
perimeter of a field.  	No

1,3-D + chloropicrin + metam-sodium	For land nominated for MeBr critical
use, weed, disease and nematode control are not sufficient as required
by state certification programs for nursery areas nominated.  Research
with tarps and other combination strategies may improve efficacy (e.g.,
Ajwa et al., 2003), but these need to be sufficiently developed for
commercial use.  1,3-D is a good nematicide and chloropicrin is a good
fungicide.  Metam sodium provides moderate, but in some situations,
inconsistent disease, nematode, and weed control, dependent on soil
conditions.

Metam sodium degrades in the soil to form methylisothiocyanate, which
has activity against nematodes, fungi, insects, and weeds.  MeBr has a
higher vapor pressure than metam sodium, therefore can penetrate and
diffuse throughout the soil more effectively than metam sodium.  In
addition, the effectiveness of metam sodium is dependent on the organic
matter and moisture content of the soil.  Studies to evaluate best
delivery systems for metam sodium are being conducted.  Some studies
have shown that soil injections and drenches are more effective than
drip irrigation.  Research trials show that incorporation of metam
sodium with a tractor-mounted tillovator provides good results, but most
growers do not have this equipment.

A 3-week time interval before planting is required to avoid phytotoxic
levels.  This can cause delays in production schedules that could lead
to missing specific market windows, thus reducing profit or causing a
loss for a grower.

The combination of the three chemicals would likely require a companion
herbicide or hand weeding.  Failure to control the full spectrum of
weeds could lead to increased disease pressure over time because the
weeds can be reservoirs for disease or harbors insect vectors of
disease.  Also, because strawberry fruit growers require pest free
strawberry root stock, nursery growers who do not supply this type of
product will be forced out of the market.	No

1,3-D + metam-sodium	1,3-D and metam-sodium possess inconsistent control
of nutsedge (Webster et. al. 2001).  Research examining protocols for
combination treatments have the best chance for effective pest control,
but strategies must be developed so they are ready for commercial
applications.

The combination of 1,3-D and metam sodium is not feasible for the
nominated areas because it does not consistently control pests and
diseases to the level required by various state laws.  1,3-D is a good
nematicide and metam sodium provides very good to poor (i.e.,
unpredictable) disease, nematode, and weed control, most likely due to
irregular distribution through the soil.  The combination of these
chemicals would likely require a companion herbicide or hand weeding.
Failure to control the weed seed in soil would most likely lead to
increased disease pressure over time.  In strawberry fruit production,
there is demand for pest free strawberry root stock and nursery growers
who do not supply this type of product will be forced out of the market.

Personal Protective Equipment (PPE) requirements may be problematic for
worker comfort in the hot or humid climates of California or the
southeastern U.S.  In addition, the buffer requirement of 90 meters (300
feet) would be particularly constraining on smaller fields in
predominantly urban fringe areas.  For small strawberry nursery
operations in the southeastern U.S., the 1,3-D buffer requirements
eliminate a large area around the field perimeter, which impacts the
total area available for strawberry nursery production.

Sequential application of each one of these chemicals requires
significantly more time than using MeBr alone since growers must wait
longer after fumigation to put the strawberry root stock in the ground.
Growers have a greater planting delay for several weeks, which will
extend their production schedule.  This delay directly impacts cultivar
options, Integrated Pest Management practices, timing of planting and
harvest for strawberry fruit production, marketing window options, land
leasing decisions, and subsequent crop rotation schedules.  Since
growers will require rootstock at a fixed time during the year, the
nursery plants could be of lower grade and quality (smaller) causing
loss to both the nursery grower and the fruit grower. 	No

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

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

Southeastern States – Table 14.1: Technically Infeasible Alternatives
Discussion  TC "Southeastern States – Table 14.1: Technically
Infeasible Alternatives Discussion" \f F \l "1"

Name of Alternative	Discussion

Other fungicides, herbicides, or nematicides.	In addition to chemical
alternatives already discussed, researchers are testing halosulfuron for
control of nutsedges.

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

Southeastern States – Table 15.1: Present Registration Status of
Alternatives  TC "Southeastern States – Table 15.1: Present
Registration Status of Alternatives" \f F \l "1"

Name of Alternative	Present Registration Status

	Registration being considered by national authorities? (Y/N)	Date of
possible future registration:

Iodomethane	Not registered for any crop uses in the U.S.	Yes	Unknown

Propargyl bromide	Registration in the U.S. has not been requested. 	No
Unknown

Sodium azide	Registration in the U.S. has not been requested.  	No
Unknown

Halosulfuron	Not registered for strawberry	No	Unknown

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

The following study was conducted in the southeastern U.S. but with
methyl iodide (MI) as the principal treatment comparing to 1,3-D with
35% chloropicrin (Telone C-35) and an untreated control.  Based on
researchers’ opinions from numerous studies, MI when used as a soil
fumigant generally provides yields and levels of pest control comparable
to MB.  Accordingly, we assumed that the results of the available study
are representative of previous studies and can be relied upon for
assessing the comparative value of the best available alternative (1,3-D
+ 35% chloropicrin).

Given the soil types present in production areas the root zone required
to be protected is generally as deep as 1 m.  Although several of the
alternatives provided adequate levels of pest control at shallower
depths, none consistently provided suitable control levels at 1 m.
Failure to provide levels of pest control at the required depth will
result in inadequate levels of control, which will result in rejection
of the plants produced under these conditions (100% loss in affected
fields).  Accordingly, the maximum loss estimate is listed as 100%
because the various state certification requirements, which equate to a
zero tolerance for disease symptoms and nematodes.

Southeastern States – Table 16.1: Effectiveness of
Alternatives—weeds  TC "Southeastern States – Table 16.1:
Effectiveness of Alternatives –Weeds 1" \f F \l "1"

Treatment	Application Rate

(kg/ha)	% MeBr Pest Control 	% MeBr Yield	Comments

Nem.	Dis.	Weeds

Methyl Iodide (100%)	263	NQ	NQ	Assume 100%	Assume 100%	No MeBr tested

Methyl Iodide/Chloropicrin (75:25)	263/66	NQ	NQ	92%	81%

	1,3-D/Chloropicrin (Telone C-35)	254/139	NQ	NQ	87%	73%

	Source:  Gilreath, J.P., E.B. Poling, J.W. Noling, 2001, unpublished
study

Key to Table Abbreviations: NQ = not quantified (too low and
non-uniform); Nem. = nematodes; Dis. = diseases

Methyl iodide yield was statistically higher than the combination with
chloropicrin and the 1,3-D/chloropicrin treatments.  There was no
statistical difference between these two treatments, however, they both
provided statistically higher yields than the untreated controls.  The
weeds were hairy galinsoga (Galinsoga cillata), carpetweed (Mollugo
verticillata), and purslane (Portulaca oleracea).  The most difficult
weed to control was hairy galinsoga, with methyl iodide providing the
highest levels of control of this weed, as well as the other weeds.  The
post treatment disease and nematode incidence data were too variable and
too low in any of the plots to formulate any conclusions.  The yield
benefit exhibited by methyl iodide is likely to be a combination of weed
control plus control of other unidentified microbial pests.  The
comparative weed control percentages are based solely on control of
hairy galinsoga.

Southeastern States – Table C.1: Alternatives Yield Loss Data Summary
TC "Southeastern States – Table C.1: Alternatives Yield Loss Data
Summary" \f F \l "1"

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3-D/chloropicrin (Telone C-35)	Weeds

(see above table) 	0-27%	10%

Metam Sodium	Weeds

(see above table)	0-50%	10%

Overall Loss Estimate for All Alternatives to Pests	10%

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

Methyl iodide (iodomethane) is in a pending registration status and is
being evaluated as an alternative.  It is generally considered to be as
effective as MeBr for many preplant crop uses and pests.  Growers might
readily transition to this alternative.

Dazomet is also in a pending registration status as a nematicide on
strawberries.  The efficacy in the southeastern U.S. is unclear.

Southeastern States - 18. Are There Technologies Being Used to Produce
the Crop which Avoid the Need for Methyl Bromide  TC "Southeastern
States - 18. Are There Technologies Being Used to Produce the Crop which
Avoid the Need for Methyl Bromide" \f C \l "2"

For 2008, MeBr is critical for strawberry nurseries in the southeastern
U.S. because of the strict requirements of producing pest-free nursery
stock.  The technology changeover costs for adopting soilless culture
techniques are high.  Although yields reportedly obtained through
greenhouse production are higher than that of the best conventional
growers, capitalization for this and other sectors makes the alternative
not feasible as a near term strategy to reduce reliance on MB.  No
information was presented on the long-term viability of this option.
Conventional and organic strawberry fruit growers are dependent on
MB-treated transplants to enable them to grow strawberries by starting
with pest-free transplants.

Southeastern States - Summary of Technical Feasibility  TC "Southeastern
States - Summary of Technical Feasibility" \f C \l "2"

For the area being nominated for 2008, alternatives have not been
sufficiently developed to provide acceptable control of major pests in
commercial strawberry nurseries in the southeastern U.S.  The use of
alternatives will require further study before growers can be confident
that they are able to effectively control major pests, which are
limiting factors in nursery production in this area.  The consortium is
currently developing a timeline to describe the transition from MeBr to
alternatives.  Research has been cited from California (e.g., Kabir et
al., 2003) of the potential for MeBr replacement or reduction for this
sector, but the need for MeBr for these nurseries for 2008, is critical
until methods are developed for commercial strawberry nursery
operations-.

Key alternatives are 1,3-D/chloropicrin,
1,3-D/chloropicrin/metam-sodium, and 1,3-D/metam-sodium.  Dazomet is
also a possible alternative probably in combination with chloropicrin
and/or 1,3-D.  These chemicals, in addition to developing strategies for
use of tarps, such as virtually impermeable films, may ultimately reduce
or replace MB.  However, after long-term MeBr use, strategies for new
treatments must be researched and transferred for commercial
applications.

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

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

California - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request  TC "California - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request" \f F \l "1"

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide needed

California	Diseases: Phytophthora Crown and Root Rots (Phytophthora
spp.);

Red Stele (Phytophthora fragariae); Verticillium Wilt (Verticillium
dahliae); Anthracnose (Colletotrechum acutatum)

Nematodes:

Root-knot (Meloidogyne spp.);

sting (Belonolaimus spp.);

dagger (Xiphinema spp.);

lesion (Pratylenchus spp.);

foliar (Aphelenchoides spp.);

needle (Longidorus spp.);

stem (Ditylenchus spp.)

Weeds: numerous weeds listed (e.g., annual bluegrass, bur clover,
carpetweed, chickweed, field bindweed, goat grass, hairy nightshade,
lambsquarter, malva, nutsedge, pig weed, portulaca, prostate spurge,
puncture vine, purslane, vetch)	The state certification program has
strict requirements for control of diseases and nematodes (CDFA, 2003).
Given the growing situations encountered over the course of the 5-year
transplant production cycle (a different growing location is used each
year), in situations where 1,3-D is not effective, no other alternatives
have been shown to provide pest control acceptable for state
certification.

There is research being conducted that indicates potential for
acceptable alternatives in the future (e.g., Kabir et al., 2003) but,
for 2008, there is a critical need for MB.

Methyl iodide may prove to be an effective alternative, but it is
currently not registered in the U.S.

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

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

Characteristics	California

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

Annual or Perennial Crop: (# of years between replanting) 	Annual crop,
only planted in the same location once every three years

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	The principal rotational crops are endive,
garlic, onion, horseradish, mint, alfalfa, sugarbeets, and potatoes.

Soil Types:  (Sand, loam, clay, etc.)	80% light soils, 10% medium soils
and 10% heavy soils; 70% with 2% or less organic matter

Frequency of methyl bromide Fumigation: (e.g. every two years)	Every
year

Other relevant factors:	No

California  (low elevation areas; years 3 & 4) -Table 11.2
Characteristics of Climate and Crop Schedule  TC " California - Table
11.2 Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	6a, 6b, 7a, 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

X

Planting

Schedule

	X	X

harvest schedule

	X

	*For Fresno, California.

California  (high elevation areas; year 5) -Table 11.3 Characteristics
of Climate and Crop Schedule  TC " California - Table 11.3
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	6a, 6b, 7a, 9a, 9b

Fumigation Schedule

X	X

	Planting

Schedule

X

harvest schedule

	X	X	X

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

Legal restrictions of some alternatives and certain soil moisture
conditions can have an impact on use.

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

California - Table 12.1 Historic Pattern of Use of Methyl Bromide  TC
"California - Table 12.1 Historic Pattern of Use of Methyl Bromide" \f F
\l "1"

For as many years as possible as shown specify:	1999	2000	2001	2002	2003
2004

Area Treated (hectares)	1,267	1,283	1,295	1,477	1,550	1,683

ratio of flat fumigation methyl bromide use to strip/bed use if strip
treatment is used	All Flat fumigation	All Flat fumigation	All Flat
fumigation	All Flat fumigation	All Flat fumigation	All Flat fumigation

Amount of methyl bromide active ingredient used

(total kg)	341,230	337,604	341,022	389,069	408,523	443,432

formulations of methyl bromide 	67:33	67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied 	Soil injection	Soil injection
Soil injection	Soil injection	Soil injection	Soil injection

Application rate of formulations in kg/ha*	404	395	395	395	395	395

Application rate of methyl bromide in kg/ha*	269	263	263	263	263	263

Actual dosage rate of formulations (g/m2)*	40.4	39.5	39.5	39.5	39.5	39.5

Actual dosage rate of methyl bromide (g/m2)*	26.9	26.3	26.3	26.3	26.3
26.3

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

California - Part C: Technical Validation  TC "California - Part C:
Technical Validation" \f F \l "1"    TC "California - Part C: Technical
Validation" \f C \l "1"

California - 13. Reason for Alternatives Not Being Feasible  TC
"California - 13. Reason for Alternatives Not Being Feasible" \f C \l
"2"

California – Table 13.1: Reason for Alternatives Not Being Feasible
TC "Southeastern States – Table 13.1: Reason for Alternatives Not
Being Feasible" \f F \l "1"

Please see the description above under the Southeastern U.S.
(Southeastern U.S. Table 13.1).

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

California – Table 14.1: Technically Infeasible Alternatives
Discussion  TC "Southeastern States – Table 14.1: Technically
Infeasible Alternatives Discussion" \f F \l "1"

Please see the description in the Southeastern U.S. above (Southeastern
U.S. Table 14.1).

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

California – Table 15.1: Present Registration Status of Alternatives
TC "California – Table 15.1: Present Registration Status of
Alternatives" \f F \l "1"

Name of Alternative	Present Registration Status

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

Iodomethane	Not registered for any crop uses in the U.S.  	Yes	Unknown

Sodium Azide	Not submitted for registration.  	No	Unknown

Propargyl bromide	Not submitted for registration.   	No	Unknown

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

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

Numerous studies have been referenced (see section 26) in the two
applications (Southeastern States [Maryland, North Carolina, Tennessee],
and California).  Several studies suggest that alternatives (most likely
combination of alternatives) have potential as MeBr replacements, but
would not be acceptable for the 2008 season.  This is because protocols
for alternative treatments have to go through a multi-season process of
research and development before they are commercially available.  This
is especially true for managing pest requirements of nursery
certification programs.  For the 2008 season nomination, MeBr is
considered critical for the strawberry nursery sector, in situations
where 1,3-D cannot be used because of regulations or lack of efficacy
for attaining certification.  Consortia are currently developing
timelines to detail their schedules for transition from MeBr to
alternatives.

However, research from California (e.g., Kabir et al., 2003) (see Tables
16.5a and 16.5b, below), suggests promising alternatives to MeBr in the
future.  Small scale research results suggested that the use of
chloropicrin followed by dazomet produced yields (during some years of
the study) at least as high as MeBr treated soil.  The issues of
consistency and scale-up to commercial size are still outstanding, and
this study did not evaluate specific pests, use of tarps, or consider
California certification requirements.  Therefore, there is a critical
need for MeBr for the 2008 use season, until the efficacy of alternative
treatments can be confirmed.

Inconsistency in performance of the alternatives results from the
application methods, application rates, formulations of alternatives,
soil and weather conditions, and pest species and levels present in
tests.  Experience with techniques in application of alternatives, and
interactions of several alternatives, should improve efficacy.

The root zone to be protected is as deep as 1 m.  Although several of
the alternatives provide adequate levels of pest control at shallower
depths, alternative chemicals do not consistently provide suitable
control levels at 1 m.  Failure to provide levels of pest control at the
required depth will result in inadequate levels of control, which will
result in rejection of the plants produced under these conditions (100%
loss in affected fields).

California – Table 16.1: Effectiveness of Alternatives – Chemical
Alternatives to Methyl Bromide Fumigation – How Well Do They Work?  TC
"California – Table 16.1: Effectiveness of Alternatives – Chemical
Alternatives to Methyl Bromide Fumigation – How Well Do They Work?" \f
F \l "1"

Treatment	Application Method & Rate (kg/ha)	Pest Control

(% of MB)	Yield

(% of MB)	Comments

Nem	Dis.

MB/CP (67:33)	MB: 246kg/ha; CP: 121 kg/ha; chisel injection & tarped	+	+
100

	1,3-D/CP (70:30)	1,3-D: 361 kg/ha; CP: 155 kg/ha; chisel injection &
tarped	+	+	96

	Chloropicrin (CP)	95-189; and 190 and higher; chisel injection & tarped
+	+	89 (< 190kg/ha);

103 (>190 kg/ha)	Evaluated both low and high dosage rates

Metam Sodium	950 kg/ha; surface drench and tarped	+	+	92

	Dazomet 	340 kg/ha; broadcast, tilled into soil, and tarped	+	+	95

	Enzone

(sodium tetra thiocarbonate)	2.85 kg/ha tarped	+	+	80	Not registered for
use on strawberries

Untreated

+	+	70

	Source:  Gubler, W.D., J.M. Duniway, and N. Welch. 1996. Chemical
Alternatives to Methyl Bromide Fumigation – How Well Do They Work?

Key to Abbreviations: 1,3-D = 1,3-dichloropropene; MB = methyl bromide;
CP = chloropicrin; MS = metam sodium; Nem. =  nematodes; Dis. = diseases

Watsonville, CA 1993 study using large-scale plots; low levels of
Phytophthora crown and root rots, Verticillium wilt, and nematodes;
one-year evaluation only

California – Table 16.2: Effectiveness of Alternatives Chloropicrin
Effect on Weed Seed Viability.  TC "California – Table 16.2:
Effectiveness of Alternatives Chloropicrin Effect on Weed Seed
Viability." \f F \l "1"

Control Measures Evaluated	Application Method & Rate (kg/ha)	Weed
Control

(% of MB)	Comments

MB/CP

(67:33)	MB: 225 kg/ha

CP: 111 kg/ha; soil injection	100	Very good control of 3 weeds; no
control of 2 weeds (mallow & filaree)

Metam Sodium (MS)	MS: 197 kg/ha; drip irrigation	Comp.	Very good
control of 3 weeds; no control of 2 weeds (mallow & filaree)

MS plus CP	MS: 197kg /ha drip irrigation; CP: 83 – 220 kg/ha soil
injection	Very Comp.	produced a slight increase in weed control over MS
alone = best available treatment for the weed species present

Chloropicrin (CP)	CP: 83 – 220 kg/ha soil injection	Comp.	good
control of 3 weeds at the higher rates; no control of 2 weeds (mallow &
filaree)

Untreated

none

	Source: Haar, M.J., S.A. Fennimore, H.A. Ajwa, C.Q. Winterbottom. 2003.
Chloropicrin Effect on Weed Seed Viability.

Key to Abbreviations: CP = chloropicrin; MB = methyl bromide, MS = metam
sodium; 1,3-D = 1,3-dichloropropene; Comp = comparable.

The study was conducted over two years near Santa Maria, CA.  Primary
weed pests: Polygonum aviculare (knot-grass), Portulaca oleracea (common
purslane) and Malva parviflora (little mallow) were introduced in both
years, whereas, Stellaria media (chickweed) and Erodium cicutarium
(red-stem filaree) were introduced in the second year; similar weed seed
sensitivity for CP and MS; no yield data obtained.

California – Table 16.3: Effectiveness of Alternatives - Soil
Fumigation and Runner Plant Production.  TC "California – Table 16.3:
Effectiveness of Alternatives - Soil Fumigation and Runner Plant
Production." \f F \l "1"

Treatment	Application Method & Rate (kg/ha)	Yield (% of MB)	Comments

Methyl bromide	Chisel	100 (4 trials)

	Chloropicrin	140-191 kg/ha , chisel	73-92 (3 trials)

	Chloropicrin	(300 kg/ha, Chisel;	86 – 100 (4 trials)	Appeared to be
the best of the alternatives evaluated

1,3-D/Chloropicrin (70:30)	Chisel;	84 (1 trial)	Did not rank very high
as an alternative due to reduced plant growth and runner production

1,3-D/Chloropicrin (30:70)	Chisel	91 (1 trial)	Appeared to perform
similar to the high rate of chloropicrin

Untreated	Not Applicable	38-55 (4 trials)

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

Key to Abbreviations: 1,3-D = 1,3-dichloropropene.

This study was conducted on former strawberry nursery soils, however,
other crops were planted in these soils prior to initiating this study;
fumigants chiseled into soil at a 36 cm depth and covered with a tarp
for 7 days; pest types and pressures uncertain, however, Verticillium
wilt (V. albo-atrum) was detected in some locations and roots were
examined for decay and discoloration, with the untreated plants
exhibiting most of the disease symptoms; nematodes were not considered
to be a problem in any of the test locations.  The main focus of this
study was to evaluate yield responses and that quantification of the
various pest organisms was beyond the scope of this study.

California – Table 16.4: Effectiveness of Alternatives - Evaluation of
Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit
and Nut Tree Nurseries  TC "California – Table 16.4: Effectiveness of
Alternatives - Evaluation of Alternatives  to Methyl Bromide for Soil
Fumigation at Commercial Fruit and Nut Tree Nurseries" \f F \l "1"

Treatment	Application Method & Rate (kg/ha)	Nematode Control

(% of MB)

Methyl bromide /chloropicrin (75:25)	MB: 448 kg/ha;

 CP: 151 kg/ha	100

1,3-D/CP	1,3-D: 518 kg/ha;

CP: 283 kg/ha 	83-100

1,3-D + Metam Sodium	Sequential application; 1,3-D: 518 kg/ha;

MS: (?) kg/ha.	16-100

1,3-D/dazomet

	Sequential application; 396 kg/ha; 224 kg/ha DZ	28-100

Source: McKenry, M.V., 2001. Evaluation of Alternatives to Methyl
Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries,
California Department of Pesticide Regulation (Contract # 99-0218).

Key to Abbreviations: 1,3-D = ; CP = chloropicrin ; MB = methyl bromide;
DZ = dazomet; Prominent nematode pests present: lesion (Pratylenchus
spp.), spiral (Helicotylenchus dihystera), dagger (Xiphinema americanum)
and some root-knot (Meloidogyne spp.)

California – Table 16.5a and 16.5b: Effectiveness of Alternatives -
Evaluation of Alternatives to Methyl Bromide for the Control of Soil
Pests: Strawberry as a Model System  TC "California – Table 16.5a and
16.5b: Effectiveness of Alternatives - Evaluation of Alternatives  to
Methyl Bromide for the Control of Soil Pests" \f F \l "1"

Table 16.5a.  Fruit yield (grams per plant) of strawberry at
Watsonville, CA in 2002. [The ‘nursery’ column indicates the
treatment of nursery plants grown in 2001; the ‘field’ column
indicates the fumigation treatment in the field.]  TC "California –
Table 16.5a: Fruit yield (grams per plant) of strawberry at Watsonville,
CA in 2002" \f F \l "1"

Nursery treatment

(high elevation, MacDoel, CA)	Field treatment

(Watsonville)	Marketable yield

(g/plant) 	Unmarketable yield

(g/plant)	Total yield

(g/plant)

control	Pic	1301.7	535.6	1837.3

MB/Pic	Pic	1235.8	550.9	1786.6

MI/Pic	Pic	1278.2	525.0	1803.3

Pic followed by dazomet	Pic	1388.4	575.1	1963.4

Telone C35 followed by dazomet	Pic	1346.4	553.3	1899.7

control	MB/Pic	1520.3	600.1	2120.4

MB/Pic	MB/Pic	1474.0	596.3	2070.3

MI/Pic	MB/Pic	1526.8	625.0	2151.8

Pic followed by dazomet	MB/Pic	1634.5	640.6	2275.1

Telone C35 followed by dazomet	MB/Pic	1434.1	634.0	2068.1

ANOVA

-------------------------P values----------------------

Nursery

0.04*	0.24	0.07

Field

<0.0001*	<0.0001*	<0.0001*

Nursery (field)

0.47	0.74	0.73

* indicates significance

Source: Kabir, Z., Fennimore, S., Martin, F., Ajwa, H., Duniway, J.,
Browne, G., Winterbottom, C., Westerdahl, B., Goodhue, R., Guerrero, L.,
Haar, M. 2003. Alternative[s] Fumigants for the Control of Soil Pests:
Strawberry as a Model System. Methyl Bromide Alternatives Conference
(2003). www.mbao.org.

Key to Abbreviations: For nursery treatments: control= no fumigation;
methyl bromide/chloropicrin (MB/Pic) = 57:43, 450 kg/ha; methyl
iodide/chloropicrin (MI/Pic) = 50:50, 392 kg/ha; 1,3-D/chloropicrin
(Telone C35) (300 liters/ha) followed by dazomet (280 kg/ha);
chloropicrin (Pic) (336 kg/ha) followed by dazomet (280 kg/ha).

For field treatments:  control= no fumigation; MB/Pic, 67:33 (392
kg/ha); Pic (224 kg/ha).

Table 16.5b.  Fruit yield (grams per plant) of strawberry at
Watsonville, CA in 2003.  [The ‘nursery’ column indicates the
treatment of nursery plants grown in 2002; the ‘field’ column
indicates the fumigation treatment in the field.]  TC "California –
Table 16.5b: Fruit yield (grams per plant) of strawberry at Watsonville,
CA in 2003" \f F \l "1"

Nursery treatment

(high elevation, MacDoel, CA)	Field treatment

(Watsonville)	Marketable yield

(g/plant) 	Unmarketable yield

(g/plant)	Total yield

(g/plant)

control	Pic	1270.2	1092.5	2362.7

MB/Pic	Pic	1244.2	1070.5	2314.7

MI/Pic	Pic	1153.7	992.9	2146.6

Pic followed by dazomet	Pic	1324.6	1059.4	2384.0

Telone C35 followed by dazomet	Pic	1220.2	1069.7	2289.9

control	MB/Pic	1177.2	1216.1	2393.3

MB/Pic	MB/Pic	1132.2	1179.8	2311.9

MI/Pic	MB/Pic	1050.8	1106.2	2157.0

Pic followed by dazomet	MB/Pic	1166.9	1249.2	2416.0

Telone C35 followed by dazomet	MB/Pic	1111.0	1176.9	2287.9

ANOVA

-------------------------P values----------------------

Nursery

0.001*	0.003*	0.0001*

Field

<0.0001*	<0.0001*	0.70

Nursery (field)

0.92	0.60	0.99

* indicates statistical significance

Source: Kabir, Z., Fennimore, S., Martin, F., Ajwa, H., Duniway, J.,
Browne, G., Winterbottom, C., Westerdahl, B., Goodhue, R., Guerrero, L.,
Haar, M. 2003. Alternative[s] Fumigants for the Control of Soil Pests:
Strawberry as a Model System. Methyl Bromide Alternatives Conference
(2003). www.mbao.org.

Key to Abbreviations: For nursery treatments: control= no fumigation;
methyl bromide/chloropicrin (MB/Pic) = 57:43, 450 kg/ha; methyl
iodide/chloropicrin (MI/Pic) = 50:50, 392 kg/ha; 1,3-D/chloropicrin
(Telone C35) (300 liters/ha) followed by dazomet (280 kg/ha);
chloropicrin (Pic) (336 kg/ha) followed by dazomet (280 kg/ha).

For field treatments:  control= no fumigation;  MB/Pic, 67:33 (392
kg/ha);  Pic (224 kg/ha).

This strawberry yield research study was conducted at three strawberry
runner nurseries.  Plants were grown for three years at two high
elevation nurseries (HEN) or for two years at a low elevation nursery
(LEN).  Plants were then placed in two different field locations
(Watsonville and Oxnard) for marketable yield assessments.  Plants
received various fumigation treatments at both nursery and field
locations (results from two trials, conducted in 2002 and 2003, are
presented in Tables 16.5a and 16.5b, above).

Pests were not identified and only yields were evaluated.  In the 2002
test, “…fruit yield was significantly greater under the on-site
MBPic treatment than in Pic treatment alone” (Table 16.5a).  The
fumigants used at the nursery had “…positive carryover effects on
marketable fruit yield when the treatment was Pic [followed by]
Basamid”.

The results at the Watsonville location for the 2003 test showed
“…marketable fruit yield was increased (9%) in on-site Pic
treatments compared to MBPic treatments.  In contrast, non-marketable
fruit yield was significantly greater (4%) under MBPic than under Pic
(Table 16.5b).  The authors again noted that the nursery treatments had
significant carryover effects on the fruit yield.  They “…suggest
that application of Pic fb [followed by] Basamid [dazomet] at the HEN
increased runner plant production, which eventually improved fruit yield
with Pic in the fruiting field.  Pic could be a viable alternative to
MBPic”.  No interaction was found between the fumigations at the
nursery and field, therefore, the effects were considered additive.

California – Table C.1: Alternatives Yield Loss Data Summary  TC
"California – Table C.1: Alternatives Yield Loss Data Summary" \f F \l
"1"

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3-D/Chloropicrin  	Various weeds	0-22%	10%

1,3-D + Metam Sodium	Various weeds	---	13%

Overall Loss Estimate for All Alternatives to Pests	10-13%

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

Iodomethane is not registered, but is reported to be a potential
suitable alternative for all key pests.

Dazomet has a pending registration as a nematicide on strawberries and
may be an effective alternative, especially when combined with other
treatments (e.g., Kabir et al., 2003).

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

Because of strict requirements for pest free nursery stock (CDFA, 2003),
only certain areas can be certified as pest-free without the use of MB,
or in some instances, 1,3-D.  A shift to soilless cultivation would
require a major shift in production and would result in a significant
market disruption for the near term.

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

Strict requirements for pest free nursery plants will make MeBr a
critical tool for nursery growers, for the 2008 season.  Protocols for
effective use of the alternatives that were discussed above, have not
been sufficiently developed at this time to provide sufficient control
of such major pests as nematodes and root rot pathogens in commercial
strawberry nurseries in California.  The use of these alternatives will
require further study before growers can adopt them for nursery plant
production.  Research from California (e.g., Kabir et al., 2003)
suggests possible MeBr alternatives, but these results are preliminary,
and require scale-up efforts.  Timelines are being developed to outline
the industry’s transition to alternatives.

Key alternatives are 1,3- D/chloropicrin,
1,3-D/chloropicrin/metam-sodium, and 1,3-D/metam-sodium.  Dazomet is
also a possible alternative probably in combination with chloropicrin
and/or 1,3-D.  These chemicals, in addition to developing strategies for
use of tarps, such as VIF, may ultimately reduce or replace MB.
Currently, some high barrier films are in use in California and have
helped to reduce the rates of MB.  VIF use is restricted in California
and there are concerns about acceptable off-gassing rates.  Strategies
for new treatments must be researched and transferred for commercial
applications.

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

19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use
and Emissions in the Particular Use  TC "19. Techniques That Have and
Will Be Used to Minimize Methyl Bromide Use and Emissions in the
Particular Use" \f C \l "2"

Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions  TC
"Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions" \f
F \l "1"

Technique or Step Taken	VIF or High Barrier Films	methyl bromide dosage
reduction	Increased % chloropicrin in methyl bromide formulation	Less
frequent application

What use/emission reduction methods are presently adopted?	Currently,
most growers use HDPE tarps; VIF is restricted in California.	Between
1997 and 2002 the dosage rate of methyl bromide has dropped by one
eighth.  	All use 67:33	For certification of nursery stock, fumigation
must occur prior to every planting

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Research is underway to develop use in
commercial production systems 	Possible changeover from broadcast to
raised bed band treatments,	Unidentified	For certification of nursery
stock, fumigation must occur prior to every planting

Other measures (please describe)	Examination of promising but presently
unregistered alternative fumigants with non-chemical methods.
Unidentified	Unidentified	For certification of nursery stock, fumigation
must occur prior to every planting

20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used,
or Are Not Planned for the Circumstances of the Nomination, State
Reasons  TC "20. If Methyl Bromide Emission Reduction Techniques Are Not
Being Used, or Are Not Planned for the Circumstances of the Nomination,
State Reasons" \f C \l "2"

Tarpaulins (high density polyethylene, and mostly experimental use of
virtually impermeable film) are used to minimize use and emissions of
MB.  In addition, practices such as deep injection are used by
strawberry nursery growers to reduce the MeBr rates required for growing
nursery stock.

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

The cost of MeBr and alternatives are given in Table 21.1.  This is
followed in Table 22.1 by a listing of net and gross revenues by
applicant.  Expected losses with use of MeBr alternatives are then
estimated in Tables E1 and E2.

For this analysis, net revenue is calculated as gross revenue minus
operating costs.  This is a good measure of the direct losses of income
that may be suffered by the users.  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
often difficult to measure and verify.

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

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

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

Southeastern States	Methyl Bromide	100	 $        30,245 	 $
30,245 	 $        30,245

	Metam Sodium	50	 $        29,927 	 $        29,927 	 $        29,927

	1,3-P+Pic	90	 $        31,513 	 $        31,513 	 $        31,513

California	Methyl Bromide	100	 $        37,831 	 $        37,831 	 $
   37,831

	1,3-D+Metam Sodium	87	 $        40,157 	 $        40,157 	 $
40,157

	1,3-D+Pic	90	 $        37,664 	 $        37,664 	 $        37,664

* As percentage of typical or 3-year average yield, compared to methyl
bromide

Southeastern States-22. Gross and Net Revenue  TC "Southeastern
States-22. Gross and Net Revenue" \f C \l "2"

Southeastern States-Table 22.1: Years 1, 2, and 3 Gross and Net Revenue
TC "Southeastern States-Table 22.1: Years 1, 2, and 3 Gross and Net
Revenue" \f F \l "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	 $           42,008 	 $        11,763

Metam Sodium	 $           21,004 	 $       (8,923)

1,3-D+pic	 $           37,807 	 $          6,294

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

California-Table 22.1: Years 1, 2, and 3 Gross and Net Revenue  TC
"California-Table 22.1: Years 1, 2, and 3 Gross and Net Revenue" \f F \l
"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	 $           47,741 	 $        9,909

1,3-D+ Metam Sodium	 $           41,773 	 $        1,616

1,3-D+ Pic  	 $           42,967 	 $        5,303

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

Southeastern States	Methyl Bromide	Alternative  Metam	Alternative
1,3-d+pic

Yield Loss (%) 	0%	50%	10%

   Yield per Hectare  (plants)	         211,715 	            105,857
      190,543

* Price per Unit (us$)	 $           0.20 	 $              0.20 	 $
     0.20

= Gross Revenue per Hectare (us$)	 $        42,008 	 $           21,004
 $        37,807

- Operating Costs per Hectare (us$)	 $        30,245 	 $
29,927 	 $        31,513

= Net Revenue per Hectare (us$)	 $        11,763 	 $            (8,923)
$          6,294

Loss Measure

1. Loss per Hectare (us$)	$0	 $           20,686 	 $          5,469

2. Loss per Kilogram of Methyl Bromide (us$)	$0	 $             50.15 	 $
         13.26

3. Loss as a Percentage of Gross Revenue (%)	0%	49%	13%

4. Loss as a Percentage of Net Revenue (%)	0%	176%	46%

California - Table E.2: Economic Impacts of Methyl Bromide Alternatives
TC "California - Table E.2: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"

California	Methyl Bromide	Alternative 1,3-d Metam	Alternative 1,3-d+pic

Yield Loss (%) 	0%	13%	10%

   Yield per Hectare  (boxes)	               796 	                  696
             716

* Price per Unit (us$)	 $          60.00 	 $             60.00 	 $
 60.00

= Gross Revenue per Hectare (us$)	 $        47,741 	 $           41,773
 $      42,967

- Operating Costs per Hectare (us$)	 $        37,831 	 $
40,157 	 $      37,664

= Net Revenue per Hectare (us$)	 $          9,909 	 $             1,616
 $        5,303

Loss Measures

1. Loss per Hectare (us$)	$0	 $             8,293 	 $        4,606

2. Loss per Kilogram of Methyl Bromide (us$)	$0	 $             31.49 	 $
       17.49

3. Loss as a Percentage of Gross Revenue (%)	0%	17%	10%

4. Loss as a Percentage of Net Revenue (%)	0%	84%	46%

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

The economic assessment of feasibility for pre-plant uses of MeBr
included an evaluation of economic losses from three basic sources: (1)
yield losses, referring to reductions in the quantity produced, (2)
quality losses, which generally affect the price received for the goods,
and (3) 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.

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

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

(2) Absolute losses 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.

(3) Losses per kilogram of MeBr requested.  This measure indicates the
value of MeBr to crop production but is also useful for structural and
post-harvest uses.

(4) Losses as a percent of net revenues.  We define net 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.

These measures represent differ MeBr users, who are forest seedling
producers in this case.  Because producers (suppliers) represent an
integral part of any definition of a market, we interpret the threshold
of significant market disruption to be met if there is a significant
impact on commodity suppliers using MB.  The economic measures provide
the basis for making that determination.

The economic analysis compared the costs of MeBr alternative control
scenarios for the Southeastern Strawberry Consortium and the California
Strawberry Growers Association to the baseline costs for MB.  The
economic estimates were first calculated in pounds and acres and then
converted to kilograms and hectares.  The costs for the alternatives are
based on market price for the control products multiplied by the number
of pounds of active ingredient that would be applied.  The baseline
costs were based on the average number of applications to treat
strawberry plants (boxes) with MeBr per year.  The loss per hectare
measures the value of MeBr based on changes in operating costs and
changes in yield.  The loss expressed as a percentage of the gross
revenue is based on the ratio of the loss to the gross revenue using MB.
 Likewise for the loss as a percentage of net revenue.  These losses are
shown in Tables E.1 and E.2.

The values to derive gross revenue and the operating costs for each
alternative were derived from the baseline MeBr costs compared to the
costs of changes under two fumigation scenarios in the Southeastern
States: 1) metam sodium; and 2) 1,3-D + chloropicrin.

For California, the baseline MeBr costs were compared to two scenarios:
1) 1,3-D + metam sodium; and 2) 1,3-D + chloropicrin.  The differences
in the cost of production were primarily attributable to changes in
fumigation costs.

The major production issue facing nursery growers is that customers of
nursery stock require pest-free transplants.  If there are incidences of
disease, weeds, or insect infestation, nursery growers will not be able
to market their seedlings.  Fruit producers are not willing to purchase
plants that have any visual symptoms of disease and may hold the nursery
responsible for any disease that shows up during fruiting in the field
in the first weeks after planting.  A small infestation of nursery stock
will be multiplied many times as plants are placed in fields for fruit
production.  Nearly a billion plants are produced by California
strawberry nurseries each year, with world-wide distribution.  There are
approximately 13 seedling/runner producers in California that must
manage disease incidence over the 4-year production cycle of the
strawberry stock.

Part F. Future Plans  TC "Part F. Future Plans" \f F \l "1"    TC "Part
F. Future Plans" \f C \l "1"

23. What Actions Will Be Taken to Rapidly Develop and Deploy
Alternatives for This Crop?  TC "23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?" \f C \l "2"

Results of ongoing research suggest that there are treatments for
strawberry nurseries that have the potential to replace MB.  However,
because nursery stock is so important to the strawberry fruit industry,
effective alternatives will be difficult to implement.  The industry
supports research to identify and implement the most effective methods
to treat soil, and as noted, some are promising (e.g., Kabir et al.,
2003).  After possibly five years of research trials, scale-up trials on
a commercial level will be done to confirm the most effective treatments
found in research trials.  Combinations of several chemical and
non-chemical controls are likely to be the most effective alternative to
MB.

The amount of MeBr requested for research purposes is considered
critical for the development of effective alternatives.  The U.S.
government estimated that strawberry nurseries research will require 454
kg per year of MeBr for 2005 and 2006.  This figure will be revised for
use after that time.  The requested research use of MeBr is in addition
to the amounts requested in the submitted CUE applications.

24. How Do You Plan to Minimize the Use of Methyl Bromide for the
Critical Use in the Future?  TC "24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?" \f C \l "2"

As described in Section 23.

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

The MeBr critical use exemption nomination for Strawberry Nurseries for
the 2008 use season has been reviewed by the U. S. Environmental
Protection Agency and the U. S. Department of Agriculture and meets the
guidelines of The Montreal Protocol on Substances That Deplete the Ozone
Layer.  This use is considered critical because there are conditions in
some nurseries with high pest pressure where no feasible alternatives or
substitutes are currently effective.  While some research trials
indicated treatments that could offer an alternative to MeBr under some
circumstances, the high production nursery industry demands a consistent
and reliable pre-plant fumigation treatment that can allow production
goals to be met.  Currently MeBr is the only consistent provider of this
requirement.  The loss of MB, therefore, would result in a significant
market disruption in providing clean transplants to the industry.  The
effort to avoid market disruption provides the basis for nomination of
this sector for critical use exemption of MB.

26. Citations referenced in this report  TC "26. Citations" \f C \l "2"

Ajwa, H.A., Fennimore, S., Kabir, Z., Martin, F., Duniway, J., Browne,
G., Trout, T., Goodhue, R., and Guerrero, L. 2003. Strawberry yield
under reduced application rates of chloropicrin and Inline in
combination with metam sodium and VIF. Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions
(2003). www.mbao.org.

Ajwa, H.A., T. Trout, J. Mueller, S. Wilhelm, S. Nelson, R. Soppe, D.
Shatley. 2002. Application of Alternative Fumigants Through Drip
Irrigation Systems. Phytopath 92(12):1349-1355.

Ajwa, H., T. Trout. 2000. Distribution of Drip Applied Fumigants Under
Various Conditions. 2000 Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions.

Ajwa, H., T. Trout. 2000. Strawberry Growth and Yield with Three Years
of Drip Fumigation. 2000 Annual International Research Conference on
Methyl Bromide alternatives and Emissions Reductions.

Arbel, A., Siti, M., Barak, Katan, J., and Gamliel, A. 2003. Innovative
plastic films enhance solarization efficacy and pest control. Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions (2003). www.mbao.org.

Braun, A. L., D. M. Supkoff. 1994. Options to Methyl Bromide for the
Control of Soil Borne Diseases and pests in California. Pest Management
Analysis and Planning Program.

Browne, G. T., H.E. Becherer, M. R. Vazuesq, S. A. McGlaughlin, R.J.
Wakeman, C. Q. Winterbottom, J.M. Duniway, S. A. Fennimore. 2001.
Outlook for Managing Phytophthora Diseases on California Strawberries
without Methyl Bromide. Report to DPR.

Browne, G.T., H.E. Becherer, S.T. McLaughlin, R.J. Wakeman. 2002.
Strategies for Management of Phytophthora on California Strawberries.
Report to California Strawberry commission, March 2002. 2 pgs.

Burgos, N.R., and R.E. Talbert. 1996a. Weed control and sweet corn (Zea
mays vir. Rugosa) response in a no-till system with cover crops.  Weed
Sci. 44:355-361.

Burgos, N.R., and R.E. Talberty. 1996b. Weed Control by spring cover
crops and imazethapyr in no-till southern pea (Vigna unguiculata).  Weed
Technol. 10; 893-899.

CDFA (California Department of Food and Agriculture). 2003. Summary of
California Laws and Regulations Pertaining to Nursery Stock.
http://www.cdfa.ca.gov/phpps/pe/nipm.htm

Carpenter, J., L. Lynch. 1999. Impact of 1,3-D Restrictions in
California after a Ban on Methyl Bromide. From EPA Website.

Carpenter, J. L. Lynch, T. Trout. 2001. Township limits on 1,3-D will
impact adjustment to methyl bromide phase-out. California Agricultural.
55(3):12-18.

Culpepper, A. S. 2002. Commercial Vegetables - Weed Control. 2002
Georgia Pest Control Handbook. Cooperative Ext. Ser. University of
Georgia, Athens, GA. Pp. 247-256.

Duniway, J. M., D. M. Dopkins, J. J. Hao. 2002. Chemical and Cultural
alternatives to Methyl Bromide Fumigation of Soil for Strawberry:
Research Progress Report. California Strawberry Commission Pink Sheet.

Duniway, J.M. 2002. Status of Chemical Alternatives to Methyl Bromide
for Pre- Plant Fumigation of Soil. Phytopath 92(12):1337-1343.

Duniway, J.M., J.J. Hao, D.M. Dopkins, H. Ajwa, G.T. Browne. 2000. Some
chemical, cultural, and Biological alternatives to Methyl Bromide
Fumigation of soil for Strawberry. 2000 Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.

EPA. 2002. Replacing Methyl Bromide for Preplant Soil fumigation with
Telone, Chloropicrin and Tillam Combination Treatments. EPA Website. 6
pgs.

Fennimore, S.A. J. M. Duniway. Alternative fumigants for control of soil
pests: strawberry as a Model System. Report to California Department of
Pesticide Regulations.

Fennimore, S.A., M.J. Haar. 2003. Weed Control in Strawberry Provided by
Shank and Drip applied Methyl Bromide Alternative Fumigants. HortSci.
38(l):55-61

Fennimore, S.A., M.J. Haar, H. Ajwa. 1999. Weed Control Options in
California Strawberry without Methyl Bromide. 1999 Annual International
Research Conference on Methyl Bromide alternatives and Emissions
Reductions.

Galloway, B.A., and L.A. Weston.  1996.  Influence of cover crop and
herbicide treatment on weed control and yield in no-till sweet corn (Zea
mays L).and pimpkin (Cucurbita maxima Dutch).  Weed Technol. 7: 425-430

Gilreath, J.P., E.B. Poling, J.W. Noling. 2001. unpublished study.

Goodhue, R.E., S.A. Fennimore, H. Ajwa. 2003. Economic Feasibility of
Methyl Bromide Alternatives: Field-Level Cost Analysis. California
Strawberry Commission, Pink Sheet 03-07. 2 pgs.

Gordon, R.R. S. Kirkpatrick, D. Shaw, K.D. Larson. 2002. Differential
Infection of Mother and Runner Plant Generation-s by Verticillium
dahliae in a High Elevation Strawberry Nursery. HortScience
37(6):927-931.

Gordon, T.R., K.D. Larson, D.V. Shaw. 2002. Management of Verticillium
Wilt in High elevation Strawberry Nurseries. Report to California
Strawberry Commission. Monterey Bay Academy field Day.

Gordon, T.R., K.D. Larson, D.V. Shaw. 1999. Summary of Recent Research
on Verticillium wilt in High elevation Strawberry Nurseries. Report to
California Strawberry Commission. 2 pgs.

Gubler, W.D., J.M. Duniway, N. Welch. 1996. Chemical Alternatives to
Methyl Bromide fumigation - How Well Do They Work?

Haglund, W. 1999. Metam Sodium and Metam Combinations a Viable
Replacement for Methyl Bromide. 1999 Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.

Haar, M.J., S.A. Fennimore, H.A. Ajwa, C.Q. Winterbottom. 2003.
Chloropicrin effect on Weed Seed Viability. CropProtection 22:109-115.

Hochmuch, R.D., T. Crocker, L.L. Davis. 1999. Comparison of Bare-Root
and Plug Strawberry Transplants in Soilless Culture in North Florida,
98-04. University of Florida. 5 pgs.

Johnson, G. A., M. S, Defelice, and A. R. Heisel. 1993k Cover crop
management and weed control in corn (Zea mays). Weed Technol. 7:
425-430.

Kabir, Z., Fennimore, S., Martin, F., Ajwa, H., Duniway, J., Browne, G.,
Winterbottom, C., Westerdahl, B., Goodhue, R., Guerrero, L., and Haar,
M. 2003. Alternative[s] Fumigants for the Control of Soil Pests:
Strawberry as a Model System. Methyl Bromide Alternatives Conference
(2003). www.mbao.org.

Keddy, C.O., I. Klaus, N. Jensen, S.M. Harris. 1997. Results of
alternative Applications on Weed Control in a Strawberry Nursery. 1997
Annual International Research Conference on Methyl Bromide Alternatives
and Emissions Reductions.

Lamberti, F. 2000. 1,3-D, A Valid Alternative to Methyl Bromide for the
control of Plant Parasitic Nematodes. 2000 Annual International Research
Conference on Methyl Bromide alternatives and Emissions Reductions.

Larson, K. 1997. Nursery Soil Fumigation Regime Affects Strawberry
Transplant Production, Transplant Size, and Subsequent Fruit Yield. 1997
Annual International Research Conference on Methyl Bromide Alternatives
and Emissions Reductions.

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

Locascio, S.J., J.P. Gilreath, D.W.Dickson, T.A. Kucharek, J.P. Jones,
and J.W. Noling. 1997. Strawberry production with alternatives to methyl
bromide fumigation.  1997 Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions.

Locascio, S.J., S.M. Olson, C.A. Chase, T.R. Sinclair, D.W.Dickson, D.J.
Mitchell, and D.O. Chellemi. 1999. Strawberry production with
alternatives to methyl bromide fumigation.  1999 Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions.

Martin, F., C.T. Bull, 2002. Biological Approaches for Control of Root
Pathogens of Strawberry. Phytopath 92(12):1356-1362.

Martin, F. 2000. Management of Root Diseases in Strawberry. 2000 Annual
,International Research Conference on methyl Bromide alternatives and
Emissions Reductions.

Martinez, C., S. Fennimore, H. Ajwa. 2000. Strawberry Production with
Methyl Bromide alternatives: A Farmers Perspective. 2000 Annual
International Research Conference on methyl Bromide alternatives and
Emissions Reductions.

Maryland Department of Agriculture. 2002. Summary of Plant Protection
Regulations.

McKenry, M. 2001. Evaluation of Alternatives to Methyl Bromide for soil
Fumigation at Commercial Fruit and Nut Tree Nurseries. California
Department of Pesticide Regulation. Contract #99-0218. 29 pgs.

McKenry, M. 1999. The Replant Problem and Its Management. Catalina
Publishing. 124 pgs.

Miles, J. E., Kawabata, 0., and Nishimot. R. 2002. Modeling purple
nutsedge sprouting under soil solarization. Weed Sci. 50: 64-71.

Minuto, A., G. Gilardi, L. Bacci, P. Titone, M.L. Gullino. 1999.
Application of Chloropicrin and 1,3 dichloropropene Through soil
Injection In Northern Italy. 1999 Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.

Motis, T.N. and J.P. Gilreath. 2002Stimulation of nutsedge emergence
with chloropicrin.  2002 Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions.

Noling, J.W. 2002. The Practical Realities of Alternatives to Methyl
Bromide: Concluding Remarks.  Phytopath 92(12) 1373-1375.

Noling, J.W. Reducing Methyl Bromide Field Application Rates with
Plastic Mulch Technology. University of Florida. 6 pgs.

Norsworthy, J. 2002. Allelopathic affects of wild radish on cotton.
Clemson University. Unpublished data.

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

Paulus, A., M. Vilchez, M. Coffey. 1998. Alternatives to Methyl Bromide
for Soil fumigation. California Strawberry Commission Pink Sheet 98-1. 1
pg.

Sances, F. 2000. Plug Plant and Soil Amendment Technology as
Alternatives to Methyl Bromide Fumigation on California Strawberries.
Report for California Department of Pesticide Regulation. Contract no.
98-0283. 14pgs.

Shaw, D.V., K.D. Larson. 1999. A Meta-analysis of Strawberry Yield
Response to Preplant Soil Fumigation with Combinations of Methyl
Bromide-chloropicrin and Four Alternative Systems. HortSci 34(5):
839-845.

Shaw, D.V., T.R. Gordon, K.D. Larson. 2002. Runner Plant Cold Storage
Reduces Verticillium dahliae Infection of Nursery Origin in Strawberry.
HortScience 37(6):932-935.

Stapleton, S., C.Q. Chandler, D.E. Legard, J.F. Price, J.C. Sumier.
Transplant Source Affects Fruiting Performance and Pests of 'Sweet
Charlie' Strawberry in Florida. University of Florida. 5 pgs.

Subbarao, K. 2002. Methyl Bromide Alternatives - Meeting the Deadlines.
Phytopathology 92(12):1334-1336.

Tennessee Summary of Plant Protection Regulations. Apr. 2000.  Tennessee
Department of Agriculture.

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California Strawberry Commission Pinksheet 01-09. 4pgs.

Trout, T. H. Ajwa. 1999. Strawberry Response to Fumigants Applied by
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Welch, N. 1991  'Soil Fumigation using Telone. California Strawberry
Commission Pink Sheet. 2 pgs.

Westerdahl, B., B. Haglund, M. McKenry. 2002. Unpublished data from on
going research trial with Shasta Nursery.

APPENDIX A.  2008 Methyl Bromide Usage Newer Numerical Index (BUNNI).

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

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.

Dichotomous Variables – dichotomous variables are those which take one
of two values, for example, 0 or 1, yes or no.  These variables were
used to categorize the uses during the preparation of the nomination.

Strip Bed Treatment – Strip bed treatment is ‘yes’ if the
applicant uses such treatment, no otherwise.

Currently Use Alternatives – Currently use alternatives is ‘yes’
if the applicant uses alternatives for some portion of pesticide use on
the crop for which an application to use methyl bromide is made.

Tarps/ Deep Injection Used – Because all pre-plant methyl bromide use
in the US is either with tarps or by deep injection, this variable takes
on the value ‘tarp’ when tarps are used and ‘deep’ when deep
injection is used.

Pest-free cert. Required - This variable is a ‘yes’ when the product
must be certified as ‘pest-free’ in order to be sold

Other Issues.- Other issues is a short reminder of other elements of an
application that were checked

Frequency of Treatment – This indicates how often methyl bromide is
applied in the sector.  Frequency varies from multiple times per year to
once in several decades.

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

Most Likely Combined Impacts (%) – Adjustments to requested amounts
were factors that reduced to total amount of methyl bromide requested by
factoring in the specific situations were the applicant could use
alternatives to methyl bromide.  These are calculated as proportions of
the total request.  We have tried to make the adjustment to the
requested amounts in the most appropriate category when the adjustment
could fall into more than one category.

(%) Karst geology – Percent karst geology is the proportion of the
land area in a nomination that is characterized by karst formations.  In
these areas, the groundwater can easily become contaminated by
pesticides or their residues.  Regulations are often in place to control
the use of pesticide of concern.  Dade County, Florida, has a ban on the
use of 1,3D due to its karst geology.

(%) 100 ft Buffer Zones – Percentage of the acreage of a field where
certain alternatives to methyl bromide cannot be used due the
requirement that a 100 foot buffer be maintained between the application
site and any inhabited structure.

(%) Key Pest Impacts - Percent (%) of the requested area with moderate
to severe pest problems.  Key pests are those that are not adequately
controlled by MB alternatives.  For example, the key pest in Michigan
peppers, Phytophthora spp. infests approximately 30% of the vegetable
growing area.  In southern states the key pest in peppers is nutsedge.

Regulatory Issues (%) - Regulatory issues (%) is the percent (%) of the
requested area where alternatives cannot be legally used (e.g., township
caps) pursuant to state and local limits on their use.

Unsuitable Terrain (%) – Unsuitable terrain (%) is the percent (%) of
the requested area where alternatives cannot be used due to soil type
(e.g., heavy clay soils may not show adequate performance) or terrain
configuration, such as hilly terrain. Where the use of alternatives
poses application and coverage problems.

Cold Soil Temperatures – Cold soil temperatures is the proportion of
the requested acreage where soil temperatures remain too low to enable
the use of methyl bromide alternatives and still have sufficient time to
produce the normal (one or two) number of crops per season or to allow
harvest sufficiently early to obtain the high prices prevailing in the
local market at the beginning of the season.

Total Combined Impacts (%) - Total combined impacts are the percent (%)
of the requested area where alternatives cannot be used due to key pest,
regulatory, soil impacts, temperature, etc.  In each case the total area
impacted is the conjoined area that is impacted by any individual
impact.  The effects were assumed to be independently distributed unless
contrary evidence was available (e.g., affects are known to be mutually
exclusive).   For example, if 50% of the requested area had moderate to
severe key pest pressure and 50% of the requested area had karst
geology, then 75% of the area was assumed to require methyl bromide
rather than the alternative.  This was calculated as follows: 50%
affected by key pests and an additional 25% (50% of 50%) affected by
karst geology.

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

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

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

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

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

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

2008 Amount of Request – The 2008 amount of request is the actual
amount requested by applicants given in total pounds active ingredient
of methyl bromide, total acres of methyl bromide use, and application
rate in pounds active ingredient of methyl bromide per acre.  U.S. units
of measure were used to describe the initial request and then were
converted to metric units to calculate the amount of the US nomination.

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

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

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

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

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

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

APPENDIX B. California Strawberry Nursery Narrative  TC "Appendix B.
California Strawberry Nursery Narrative, 2005" \f F \l "1"    TC
"Appendix B. California Strawberry Nursery Narrative, 2005" \f C \l "1"

California Strawberry Nursery Narrative 2005

Introduction

The strawberry plant nursery stock produced annually in California
represents one of the largest and most widely distributed nursery
products in the world.  Nearly a billion plants are produced by the
California strawberry nursery system each year, and plants are annually
distributed from California to every continent with a temperate climate
suitable for strawberry fruit production.  In addition, many nursery
systems in other parts of the United States and throughout the world
rely on California strawberry stock as a source for their propagation
systems.  The integrity of California strawberry nursery systems
directly influences the global success of strawberry fruit as a viable
crop.

Description of Strawberry Nursery Production System

Due to the complex genetic structure of the modern strawberry, plants do
not replicate true to type from seed, and must be asexually propagated
by rooting runners produced from source plants.  The California
strawberry nursery industry is responsible for providing genetically
pure and clean planting material essential to the success of strawberry
fruit growers and other nursery systems.  Strawberry nurseries annually
plant source stocks in fumigated fields, root the runners that form, and
harvest these runner plants as a final product.

The strawberry nursery industry is a very complex system.  A typical
nursery system includes both high and low elevation nursery locations,
chosen to provide a cold site for October harvest which provides fresh
plants for fruit production systems, and a warmer site for December -
January harvest which provides frigo plants for nursery stock and frigo
plants for fruit production systems.

The high elevation nurseries are located in Northern California and
Southern Oregon at elevations of 3,200 to 4,200 feet, and produce the
plants used for October and November plantings for fruit production in
California, throughout the United States, and internationally.

Low elevation nurseries (below 600 feet) are located in the Sacramento
and northern San Joaquin valleys of California.  These low elevation
nurseries produce plants for both propagation and fruit plantings.  The
propagation stock is used by nurseries in California, throughout the
United States, and internationally.  The balance of the low elevation
production is stored for distribution through the spring and summer
months as frigo plants, and supplies fruit production systems throughout
the world.

The typical strawberry nursery system is diagrammed in (Figure 1).  This
shows that nurseries must propagate plants in the field for multiple
years before the plants are sold to customers.  Guidelines established
and enforced by the California Department of Food and Agriculture must
be followed by all strawberry nurseries.

The nursery stock regulations include fumigation standards, as well as
standards for virus, pathogen and insect control.

Figure 1.  Overall California Nursery System

Year 1	Plants are grown in a screenhouse as nuclear stock.  The source
plants have been heat treated and meristemed in order to insure a virus
and disease free stock for this first cycle of nursery production.
Nurserymen may heat treatment and meristem stock in their own
facilities, or may purchase meristem stock plants from the Foundation
Plant Material Services located at the University of California, Davis,
California.

Year 2	Meristemed stock is planted in an enclosed screenhouse structure,
designed to exclude insect vectors preventing plant contamination.
These plants are planted into fumigated soil or media.  The plants
produce about 100 daughter plants per mother plant.  CDFA
inspectorsexamine, and laboratory test screenhouse stocks to insure that
the plants are virus and nematode free.  They closely inspect for other
possible insect and disease pressures.  There is no tolerance for virus,
nematodes, and plant diseases in screenhouse propagation.  The
screenhouses are generally located in low elevation nursery sites.

Year 3	Plant increases harvested from screenhouses are planted in low
elevation nursery fields. The increase ratio at this level is about
50:1.  These low elevation fields are called Foundation increases, and
are planted outside in carefully fumigated soils.  The CDFA samples
these fields for nematodes and virus intrusion, and inspects carefully
for full control of insect and disease levels.  There is no tolerance
for nematodes and virus in foundation plantings.

Year 4	Plants from the Foundation are planted into low elevation fields
that have been fumigated.  Fields at this level are referred to as
Registered increases.  The increase ratio at this level is about 50:1.
These fields are inspected by the CDFA and are sampled for nematode
infection.  Diseases and insects are also carefully monitored at this
level. There is a zero tolerance for nematodes and virus symptoms at
this level.   These plants are often sold worldwide as propagative
stocks to nursery systems and to fruiting systems with critical needs
for pathogen control.

Year 5	Plants from the Registered Fields are planted into high and low
elevation fields that have been fumigated.  Propagation at this level
can be registered as Certified Field increases.  Plants in certified
fields are increased at a level of about 30:1.  The CDFA inspections
make sure that the fields are clean of nematode and virus infections,
and evaluate insect and disease pressures for phytosanitary clearances.
These plants are sold and planted for fruit production both domestically
and internationally.

About 70% of the ground used for strawberry nursery production is owned
by the nursery grower, and the other 30% is leased.  Nurseries need
sandy loam soils to allow for the deep rooting pattern produced by
strawberry plants.  Strawberry roots may grow three feet or more into
the soil during a growing season and therefore the fumigant used for
nursery production needs to be able to penetrate deeply into the soil.
There are a few heavier soils used in the strawberry nursery industry
which are more difficult to manage.

The total high elevation nursery acreage averages 3,200 acres per year,
and the low elevation acreage averages 1,000 acres per year.  The
locations where strawberry nurseries are grown are dry and hot in the
summer months and cold in the winter months.  Rainfall averages about 20
inches per year in the high elevation locations and 30 inches per year
in the low elevation locations.

Strawberry nursery fields are planted in the spring, and may be
fumigated in the previous fall (August and September) on fallow ground,
or may be fumigated in the spring (March and April) prior to planting.
The majority of the fumigation is done in the fall (60%), but the spring
fumigation is a very important option to provide the flexibility to
adjust acreage based on a later projected demand.  While some of the
nursery growers fumigate their own fields, about 65% of the growers have
contract fumigators apply the material.

Strawberry nursery culture is labor intensive.  Nurseries maintain a
sizeable permanent staff, and hire thousands of workers on a seasonal
basis.

Nursery fields are spring planted using crews on four row mechanical
transplanters.  In high elevation nurseries, about 12,000 plants are
placed per acre, and low elevation fields with longer growing seasons
are planted with about 6,000 plants per acre.   As the plants grow,
runners are produced and are set by hand.  Field weeds that survive
fumigation are also removed by hand.  This is an important part of the
viral disease prevention program as some of the weeds found in nursery
areas harbor virus that can be transmitted to strawberry plants.  During
the season, the runners produced form a solid canopy of leaf cover over
the field.  Before the plant canopy fills in, tractors can be used in
the field to spray if necessary.  Overhead sprinkler irrigation systems
are used to irrigate, as well as to fertigate the fields as necessary.
As the canopy fills in, tractors are no longer able to drive through the
field, and chemicals are also be applied through the overhead sprinkler
system when necessary.  A few nurseries are now using drip irrigation
instead of the standard sprinkler irrigation.

High elevation fields are harvested starting in late September when the
temperatures begin to fall and the strawberry plants begin to go
dormant.  High elevation harvests continue through late October at which
time the plants should be fully dormant.  Low elevation plants are
harvested in December or January after the plants are fully dormant.
Several pieces of equipment are used during the harvest process.  The
strawberry plant leaves are removed with a mulching mower, and
interconnecting runners are broken apart with a mechanical rake.  The
strawberry harvester is a custom designed machine that undercuts the
plants, lifts the plants from the soil, and shakes remaining soil free
from the root system.  Plants are placed in burlap bags or bin
containers on the back of the harvesters, and are loaded for transport.

During this process, about 50% of the crop biomass is left in the field.
 This remaining biomass consists mainly of leaf tissue, root tissue, and
crowns of smaller plants.  Several nurseries are now leaving the
original mother plants in the field as well as the leaf tissue which
further reduces the amount of biomass removed from the field.  This
remaining biomass is plowed back into the field before the field during
the rotation cycle.

Harvested plants are removed from the field, placed in pre-cooled trucks
and transported promptly from the field to the trim shed.  At the trim
shed, the plants are held briefly in cold storage and then trimmed and
graded by large processing crews.  This stage requires a large amount of
skilled and qualified labor to achieve reasonable production output
rates and a high quality product.

The hand-trimmed plants are graded for quality based on crown size and
root development, and are packed into boxes containing 1,000 to 1,500
plants.  Only plants that meet the quality grade standards are packed,
and the other plants are discarded.  The packed boxes are placed back
into cold storage (28 - 32 degrees F) for final cooling, and are shipped
on pre-cooled trucks, refrigerated ocean containers, or by fast air
shipments to customers worldwide.

Nursery fields are rotated out of strawberries and into cover crops for
an average of two years between strawberry planting cycles.  The cover
crops used are generally grains, and may be harvested, but are primarily
used to increase the organic matter in the soil.  Other cover crops
include endive, garlic, onions, horseradish, and mint.

Fumigation and Pathogen, Nematode and Weed Control in Strawberry
Nurseries

Methyl Bromide/Chloropicrin fumigation currently used at the strawberry
nursery controls soil borne pathogens, nematodes, and weeds.  Deep,
uniform fumigation is necessary to provide the nursery with a strong
base for producing clean planting stock.  Methyl bromide is an ideal
fumigant due to the small molecular size of the gas, which allows the
fumigant to move easily through the soil and penetrate deeply into the
soil profile.

The combination of Methyl Bromide and Chloropicrin thoroughly and
completely sterilizes the soil from the surface to beyond the penetrable
depth of the nursery crop root system.   There are over 60 identified
fungal diseases and seven major nematode groups that infect strawberry,
and the Methyl Bromide/Chloropicrin combination is highly effective
against all of them.  There are many weed types common to strawberry
nursery growing areas, and Methyl Bromide is by far the most effective
soil treatment to eliminate them in nursery plantings. Some of the most
important nematode, disease, and weed pests are listed and discussed
below.

The major soil born diseases that are a problem in strawberries and are
controlled by methyl bromide at the nursery level are shown in Table 1.
Methyl Bromide readily kills pathogens in plant debris left in the field
after harvest as well as common soil borne diseases.

Table 1.  Major problem diseases in Strawberry Nursery Production

Disease	Causal Organism

Red Stele	Phytophthora fragariae

Crown Rot	Phytophthora cactorum

Root Rot	Phytophthora citricola

Anthracnose	Colletotrichum acutatum

Verticillium wilt	Verticillium dahliae

Powdery Mildew	Sphaerotheca macularis

Angular Leaf Spot	Xanthomonas fragariae

Common Leaf Spot	Ramularia tulasneii

Black Root Rot	Pythium, Rhizoctonia, Cylindrocarpon

Fumigation is also used to control nematodes (Table 2).  Because
fumigation is used in strawberry nurseries, nematodes have not been a
problem in nurseries or production fields since the 1960's when Methyl
Bromide fumigations were first used.  The effectiveness of Methyl
Bromide/Chloropicrin mixture in controlling nematodes contributed to the
adoption of the California Nursery Stock Regulations.  These regulations
do not permit nursery stock infested with nematodes to be shipped from
the nursery.  All certified nursery plantings are sampled parasitic
nematodes, and if any are found, the infected area is rejected for
harvest.

Table 2.  Nematodes controlled in Strawberry Nursery Production

Common Name	Scientific Name

Root Knot Nematode	Meloidogyne hapla

Sting Nematode	Belonolaimus longicaudatus

Dagger Nematode	Xiphinema americanum

Stem Nematode	Ditylenchus dipsaci

Root Lesion Nematode	Pratylenchus penetrans

Needle Nematode	Longidorus elongatus

Foliar Nematode	Aphelenchoides ritzemabosi

Fumigation is also used to control weeds (Table 3) found in California
strawberry nurseries. Several of the weeds types in California
strawberry nurseries areas are classified as noxious weeds by the state
of California.  It is important to use a fumigant that can effectively
control weeds to prevent spread of seed adhering to soil particles on
plants that are shipped both domestically and internationally by
strawberry nursery growers.  Weeds are also hosts for viruses that can
be spread to strawberry plants by vectors present at the nursery.

An additional benefit is the complete control of strawberry seed from
previous plantings that might germinate in a nursery field.  If
strawberry seed germinates in a nursery planting, variety mixes are
created rendering the planting unsaleable.

Table 3.  Common weeds present in Strawberry Nurseries

Common Name	Scientific Name

Annual bluegrass	Poa annua

Bur clover	Medicago hispida

Carpetweed	Mollugo verticillata

Chickweed	Stellaria media

Field bindweed	Convolvulus arvensis *

Filaree	Erodium botrys

Goat Grass	Aegilops triuncialis

Hairy Nightshade	Solanun villosum*

Lambsquarter	Chenopodium album

Malva	Malva parviflora

Nutsedge	Cyperus rotundus*

Pig Weed	Amaranthus retroflexus

Portulaca	Oleracae

Prostrate Spurge	Euphorbia humistrata

Puncture vine	Tribulus terrestris*

Purslane	Portulaca oleracea

Vetch	Vicia sativa

*Considered noxious weeds by the California Department of Food and
Agriculture.

Methyl Bromide and Strawberry Nursery Culture

The challenges in strawberry nursery production are considerable.  All
customers for strawberry stock depend on the nurseries to provide stock
free of pests and pathogens for planting.  Since the nurseries have the
plants for multiple production cycles before the plants are sent to the
fruit growers and nursery customers, any tiny problem or minute
infection that occurs in the nursery system can be multiplied many
times, and over several years before the plants are sold (Table 4).

Table 4.  Amplification Schedule for Short Day and Day Neutral Cultivars

Approx. amplification numbers

Year	Nursery Locations	Short Day Cultivars	Day Neutral Cultivars

0	Low Elevation - Meristem Plant	1	1

1	Low Elevation - Screenhouse	100	100

2	Low Elevation - Foundation Field	50	35

3	Low Elevation - Registered Field	50	35

4	High Elevation - Certified Field	25	20

	Total Increase Ratio	6,250,000	2,450,000

The challenge in growing clean strawberry nursery stock is easy to
visualize from Table 4.  From the usual four-year process, a single
plant placed in a screenhouse increase on year 1 can be increased to as
many as six million plants by the end of year 4.  The tiniest
contamination level in years 1 and 2 can have a very broad effect on the
general cleanliness status of the nursery in years three and four.  Even
if diseases did not spread to other plants in a field, an infection on
year one could yield six million infected plants by harvest in year 4.
Unfortunately, spread rates in field conditions for fungal diseases are
very high, and any minute disease intrusion in propagation years 1 and 2
will lead to a general infection in production stock.  Because of rapid
spread rates, even minute disease intrusion into propagation in year 3
will introduce considerable disease exposure in propagation in year 4.

The challenge is even larger when the disease organisms affecting
strawberry are considered.  In referring to table 4, most of the fungal
diseases affecting strawberry are capable of multiplying as many times
per day as we might expect to multiply in plant numbers for the year.
The diseases can be asymptomatic on the strawberry plants and therefore
very difficult or impossible to detect until environmental conditions
are conducive for disease development.  Most of the nematode pests can
multiple themselves weekly by what could be multiplied annually in
plants numbers.

The challenge is thus defined.  A strawberry nursery must increase stock
in the system over a four year period, and end the process with
uncontaminated stock.  To do this, a strawberry nursery must do more
than manage disease pressure.  To be successful, the strawberry nursery
must very effectively manage disease incidence.  Apparent plant health
and acceptable disease thresholds are not part of the language of
successful strawberry nursery culture.  A strawberry nursery is
successful only if major plant disease incidences are controlled.  The
success of the nursery product provided to customers is directly related
to the nursery's ability to exert this control.

As mentioned, the California strawberry nurseries produce around one
billion plants annually, and production distribution is worldwide.  In
addition, propagation in strawberry in many countries depends on