METHYL BROMIDE CRITICAL USE NOMINATION FOR PREPLANT SOIL USE FOR FRUIT, NUT AND FLOWER NURSERIES 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 Fruit, Nut and Flower Nurseries ( Prepared in 2005)

NOMINATING PARTY CONTACT DETAILS Contact Person: John E. Thompson, Ph. D. Title: International Affairs Officer Address: Office of Environmental Policy U. S. Department of State 2201 C Street N. W. Room 4325 Washington, DC 20520 U. S. A. Telephone: ( 202) 647 9799 Fax: ( 202) 647 5947 E mail: ThompsonJE2@ state. gov Following the requirements of Decision IX/ 6 paragraph ( a)( 1), the United States of America has determined that the specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for this use would result in a significant market disruption.

Yes

No Signature Name Date Title: U. S. Fruit, Nut, & Flower Nursery ii CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Steve Knizner Title: Acting Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency Mail Code 7503C Washington, DC 20460 U. S. A. Telephone: ( 703) 305 6903 Fax: ( 703) 308 8090 E mail: knizner. steve@ epa. gov LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE LIST ALL PAPER AND ELECTRONIC DOCUMENTS SUBMITTED BY THE NOMINATING PARTY TO THE OZONE SECRETARIAT 1. PAPER DOCUMENTS: Title of Paper Documents and Appendices Number of Pages Date Sent to Ozone Secretariat 2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: Title of Electronic Files Size of File ( kb) Date Sent to Ozone Secretariat U. S. Fruit, Nut, & Flower Nursery iii TABLE OF CONTENTS PART A: SUMMARY ..................................................................................................................... 7 1. Nominating Party _________________________________________________________ 7 2. Descriptive Title of Nomination______________________________________________ 7 3. Crop and Summary of Crop System___________________________________________ 7 4. Methyl Bromide Nominated _________________________________________________ 8 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 9 6. Summarize Why Key Alternatives Are Not Feasible_____________________________ 10 7. Proportion of Crops Grown Using Methyl Bromide _____________________________ 10 8. Amount of Methyl Bromide Requested for Critical Use __________________________ 11 9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity Nominated for Each Region___________________________________________________________________ 12 WESTERN RASPBERRY NURSERIES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ................................................................................................................................................. 12 Western Raspberry Nurseries  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request _________________________________ 12 Western Raspberry Nurseries  11. Characteristics of Cropping System and Climate______ 12 Western Raspberry Nurseries. 12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested___________________ 15 WESTERN RASPBERRY NURSERIES. PART C: TECHNICAL VALIDATION........................................ 16 Western Raspberry Nurseries. 13. Reason for Alternatives Not Being Feasible __________ 16 Western Raspberry Nurseries. 14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: 18 Western Raspberry Nurseries  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _________________________________________ 19 Western Raspberry Nurseries  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 ___________________________________________________________ 19 Western Raspberry Nurseries  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? ______________ 21 Western Raspberry Nurseries  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _____________________________________ 21 Western Raspberry Nurseries  Summary of Technical Feasibility ____________________ 21 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ............................................................................................................. 22 California Deciduous Fruit & Nut Tree Growers  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request__________________ 22 California Deciduous Fruit & Nut Tree Growers  11. Characteristics of Cropping System and Climate __________________________________________________________________ 23 California Deciduous Fruit & Nut Tree Growers  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ________________________________________________________________________ 25 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  PART C: TECHNICAL VALIDATION....... 26 U. S. Fruit, Nut, & Flower Nursery iv California Deciduous Fruit & Nut Tree Growers  13. Reason for Alternatives Not Being Feasible __________________________________________________________________ 26 California Deciduous Fruit & Nut Tree Growers  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide:_________________________________________________________ 27 California Deciduous Fruit & Nut Tree Growers  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________ 27 California Deciduous Fruit & Nut Tree Growers  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested __________________________________________________ 28 California Deciduous Fruit & Nut Tree Growers  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? ________________________________________________________________________ 29 California Deciduous Fruit & Nut Tree Growers  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? ______________________ 30 California Deciduous Fruit & Nut Tree Growers  Summary of Technical Feasibility _____ 30 CALIFORNIA NURSERY ROSES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE .. 30 California Nursery Roses  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request _________________________________ 30 California Nursery Roses  11. Characteristics of Cropping System and Climate _________ 31 California Nursery Roses  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested___________________ 32 CALIFORNIA NURSERY ROSES  PART C: TECHNICAL VALIDATION.............................................. 33 California Nursery Roses  13. Reason for Alternatives Not Being Feasible_____________ 33 California Nursery Roses  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: 34 California Nursery Roses  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _____________________________________________ 35 California Nursery Roses  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 ___________________________________________________________ 35 California Nursery Roses  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? ______________ 40 California Nursery Roses  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _____________________________________ 40 California Nursery Roses  Summary of Technical Feasibility _______________________ 41 PART D: EMISSION CONTROL ..................................................................................................... 41 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 42 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 42 PART E: ECONOMIC ASSESSMENT............................................................................................... 43 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 43 22. Gross and Net Revenue___________________________________________________ 43 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 43 U. S. Fruit, Nut, & Flower Nursery v Summary of Economic Feasibility _____________________________________________ 44 PART F. FUTURE PLANS ............................................................................................................. 45 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 45 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 45 25. Additional Comments on the Nomination ____________________________________ 46 26. Citations ______________________________________________________________ 47 LIST OF TABLES Part A: Summary______________________________________________________________ 7 Table 4.1: Methyl Bromide Nominated ____________________________________________ 8 Table A. 1: Executive Summary __________________________________________________ 9 Table 7.1: Proportion of Crops Grown Using Methyl Bromide _________________________ 10 Table 8.1: Amount of Methyl Bromide Requested for Critical Use______________________ 11 Western Raspberry Nurseries  Part B: Crop Characteristics and Methyl Bromide Use _____ 12 Western Raspberry Nurseries  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request_________________________________________________________ 12 Western Raspberry Nurseries. Table 11.1: Characteristics of Cropping System____________ 13 Western Raspberry Nurseries. Table 11.2 Characteristics of Climate and Crop Schedule ____ 14 Western Raspberry Nurseries. Table 12.1 Historic Pattern of Use of Methyl Bromide_______ 15 WESTERN RASPBERRY NURSERIES. PART C: TECHNICAL VALIDATION _______________________ 16 Western Raspberry Nurseries. Table 13.1: Reason for Alternatives Not Being Feasible _____ 16 Western Raspberry Nurseries  Table 14.1: Technically Infeasible Alternatives Discussion __ 18 Western Raspberry Nurseries   Table 15.1: Present Registration Status of Alternatives _____ 19 Western Raspberry Nurseries   Table 16.1: Effectiveness of Alternatives   Diseases _______ 20 Western Raspberry Nurseries   Table C. 1: Alternatives Yield Loss Data Summary ________ 20 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS B  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _____________________________________________________ 22 California Deciduous Fruit & Nut Tree Growers  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request _________________________________________ 22 California Deciduous Fruit & Nut Tree Growers  Table 11.1: Characteristics of Cropping System_________________________________________________________________ 23 California Deciduous Fruit & Nut Tree Growers  Table 11.2 Characteristics of Climate and Crop Schedule___________________________________________________________ 24 California Deciduous Fruit & Nut Tree Growers  Table 12.1 Historic Pattern of Use of Methyl Bromide________________________________________________________________ 25 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  PART C: TECHNICAL VALIDATION _____ 26 California Deciduous Fruit & Nut Tree Growers   Table 13.1: Reason for Alternatives Not Being Feasible___________________________________________________________ 26 California Deciduous Fruit & Nut Tree Growers   Table 14.1: Technically Infeasible Alternatives Discussion ___________________________________________________ 27 California Deciduous Fruit & Nut Tree Growers   Table 15.1: Present Registration Status of Alternatives _____________________________________________________________ 27 U. S. Fruit, Nut, & Flower Nursery vi California Deciduous Fruit & Nut Tree Growers   Table 16.1: Effectiveness of Alternatives   Nematodes______________________________________________________________ 28 California Deciduous Fruit & Nut Tree Growers   Table C. 1: Alternatives Yield Loss Data Summary_______________________________________________________________ 29 California Nursery Roses  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _____ 30 California Nursery Roses  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request_________________________________________________________ 30 California Nursery Roses  Table 11.1: Characteristics of Cropping System ______________ 31 California Nursery Roses  Table 11.2 Characteristics of Climate and Crop Schedule _______ 31 California Nursery Roses  Table 11.3 One Year Rose Crop Schedule ___________________ 31 California Nursery Roses  Table 12.1 Historic Pattern of Use of Methyl Bromide _________ 32 CALIFORNIA NURSERY ROSES  PART C: TECHNICAL VALIDATION__________________________ 33 California Nursery Roses   Table 13.1: Reason for Alternatives Not Being Feasible________ 33 California Nursery Roses   Table 14.1: Technically Infeasible Alternatives Discussion _____ 34 California Nursery Roses   Table 15.1: Present Registration Status of Alternatives_________ 35 California Nursery Roses   Table 16.1: Effectiveness of Alternatives   Nematodes ________ 36 California Nursery Roses   Table 16.2: Effectiveness of Alternatives   Phytophthora_______ 37 California Nursery Roses   Table 16.3: Effectiveness of Alternatives   Stunt Nematode ____ 38 California Nursery Roses   Table 16.4: Effectiveness of Alternatives   Root Knot Nematode 39 California Nursery Roses   Table C. 1: Alternatives Yield Loss Data Summary____________ 40 PART D: EMISSION CONTROL ____________________________________________________ 41 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 42 PART E: ECONOMIC ASSESSMENT _________________________________________________ 43 Table 21.1: Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______ 43 PART F. FUTURE PLANS ________________________________________________________ 45 APPENDIX A. 2007 Methyl Bromide Usage Numerical Index ( BUNI)._________________ 49 U. S. Fruit, Nut, & Flower Nursery Page 7 Part A: Summary 1. NOMINATING PARTY:

The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Fruit, Nut and Flower Nurseries ( Prepared in 2005)

3. CROP AND SUMMARY OF CROP SYSTEM This nomination is based on requests for critical use of methyl bromide ( MB) by producers of nursery grown raspberry, roses, and deciduous tree planting material. Nursery producers must be able to provide stock plants that are pest free to allow the establishment of plantings that are of the highest initial quality and optimize the longevity of orchards or other producing plots. Nurseries provide plants used by commercial growers of fresh and processed raspberries, rose bushes, and such diverse fruit crops as apricots, peaches, prunes, nectarines, cherries, plums, apples, pears, Asian pears ( as well as ornamental pears), and nut crops such as almonds, walnuts, pistachios, pecans, and chestnuts. Approximately 95% of the trees are fruiting varieties sold to commercial producers ( although residential consumers are also a market); the other 5% are ornamental types used for landscaping. Nurseries are concentrated in areas conducive to early plant growth   deciduous trees are primarily produced in California in the Sacramento and San Joaquin valleys in a Mediterranean climate, many large raspberry nurseries are located in eastern San Joaquin valley and western Washington where pest free stock can be grown for markets in the cooler production areas of northern California and the Pacific Northwest.

Raspberry nurseries in the western U. S. provide raspberry stock to most of the growers in North America. Dry climates and soils make these areas ideal for production of high quality plant stock. Although there are relatively few raspberry nurseries, they provide all of the stock used by commercial growers, and therefore, have a large impact on raspberry production overall. MB is used on a total area of approximately 200 hectares of field beds. However there is a large return in the benefits of certified pest free stock to numerous commercial growers throughout the continent. The raspberry nursery industry uses flat fumigation techniques similar to that of the strawberry industry. Raspberry nursery stock is grown using a two year production cycle beginning with tissue culture and moving to foundation planting the first year. Winter dormant plants are replanted in commercial nurseries and harvested after one year.

Deciduous tree nurseries range from 15 to over 600 hectares in field beds. A typical operation in California ranges between 80 and 120 hectares. The climate and soil make this region an ideal area for tree nurseries ( as well as a major fruit and nut producing region). While some nurseries concentrate on specific tree crops, most nurseries grow and sell a variety of different trees. Nursery stock is grown on a cropping system that includes crop rotation or cover cropping between tree production cycles; therefore, not all of the nursery area is in tree production in a given year. The tree production cycle can be anywhere from a single year to several years U. S. Fruit, Nut, & Flower Nursery Page 8 depending on the type of tree crop being produced. Nursery production of trees takes from one to four years in the ground depending on the type being produced. Almonds take one year and walnuts take at least two years. Also, desired tree size determines how long it is grown in the nursery. The most common cycle is for the tree crop to be in the ground for either one or two years. A typical nursery cycle starts by digging the current tree crop ( to be sold) then planting a cover crop for one or two years, followed by replanting with a tree crop. In order to prepare the ground for planting, the fields are disked, deep ripped, leveled, and then fumigated to meet certification standards set by the California Department of Food and Agriculture ( CDFA, 1996). MB is applied by shank and treated area is usually covered with a high barrier tarp. The fumigation is carried out around August and September, and planting begins in October, and may continue through January. The deciduous nurseries are subject to mandates set forth by the CDFA, that trees must be pest free. This CUE request is for the portion of tree nurseries in California which are in areas where alternatives are either unsuitable for meeting certification standards or subject to regulatory restrictions.

Nursery roses are grown in open field plots. A typical crop rotation for a two year rose crop includes one year fallow, followed by one or two years of rotational crops, and then a two year rose crop. The two year rose crop cycle begins with land preparation ( removing the cover crop, deep cultivation, and fumigation with methyl bromide), followed by planting the rootstock and T bud grafting. In late winter of the first year, the rootstock tops are removed. The rose crop matures by the second autumn and is then harvested. This cycle varies depending on the type of rose crop being produced ( e. g., two year roses, one year minis and patio trees, or 18 month mini bushes).

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

2007 12,684 48 .* Includes research amount of 1,506 kgs. U. S. Fruit, Nut, & Flower Nursery Page 9 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE The U. S. Nomination is for nurseries where alternatives are not suitable, either because of legal restrictions, specific certification requirements, or physical features such as unacceptable soil moisture. Areas subject to quarantine and pre shipment exemption ( QPS) are not included. The deciduous fruit and nut tree nurseries in California, and the raspberry nurseries in the western states of California and Washington produce the majority of the stock for their respective industries; 95% of their sales are within California. Most of the sales go to commercial fruit growers and the remaining trees are flowering varieties sold primarily to landscapers. The nematode species of concern in the nursery industry in Washington and California are Meloidogyne spp., Pratylenchus spp., Trichodorus spp., Xiphinema spp., and Criconemelia spp. Various weed species and fungal pests are secondary pests in nurseries. Under California regulatory laws, nursery crops must be " free of especially injurious pests and disease symptoms" in order to qualify for a California Department of Food and Agriculture ( CDFA) Nursery Stock Certificate for Interstate and Intrastate Shipments ( CDFA, 1996). If a nursery grower uses MB or if allowed, 1,3 D, the crop is assumed to be " free of especially injurious pests and disease symptoms." However, if a grower fumigates with another alternative, or does not fumigate at all and there is history of nematode problems, the CDFA imposes nematode sampling requirements, which is at the expense of the grower. If nematodes are found stock will not be certified and grower will incur economic losses.

California nursery roses must meet certification requirements as well. Roses have deep roots, which require pest control to a depth of 1.5 meters. Rose growers may use 1,3 D if the following conditions are met: 1) the field has not been previously infested with nematodes, and 2) soil moisture levels are not higher than 12%, which implies that only sandy soils are approved. In addition, township caps in California restrict the amount of 1,3 D that can be used in a given area. This issue is especially important for nursery rose growers, as most production of this crop is concentrated in two townships where other crops that also use 1,3 D, such as almonds and carrots, are grown ( Trout, 2001).

TABLE A. 1: EXECUTIVE SUMMARY*

Region Western Raspberry Nurseries California Deciduous Fruit & Nut Tree Growers California Nursery Roses AMOUNT OF APPLICANT REQUEST 2007 Kilograms 53,416 43,998 22,680 AMOUNT OF NOMINATION 2007 Kilograms 10,952 0 227 U. S. Fruit, Nut, & Flower Nursery Page 10 6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

Nurseries must provide stock that is pest free in order to meet state mandated certification requirements for plant material ( CDFA, 1996). Where allowed by township cap regulation and where soil type and moisture are acceptable, use of products with 1,3 D can provide an effective alternative to MB for nematode control ( e. g., Schneider et al., 2004). Moisture restrictions for 1,3 D may be more limiting than township caps. Nurseries with heavy soils or moisture greater than 12% ( especially common in clay soils at depths of 1 to 1.5 meters) are not likely to receive certification of nursery stock, because of the inability to effectively reduce populations of nematodes or pathogens. In these situations MB is critically needed. What is of primary importance is pest free stock that is of sufficient quality to meet government standards and comply with standards for intra and interstate plant transit.

7. ( i) PROPORTION OF CROPS GROWN USING METHYL BROMIDE TABLE 7.1: PROPORTION OF CROPS GROWN USING METHYL BROMIDE REGION WHERE METHYL BROMIDE USE IS REQUESTED TOTAL CROP AREA 2001   2002 AVERAGE ( HA) PROPORTION OF TOTAL CROP AREA TREATED WITH METHYL BROMIDE (%) Western Raspberry Nurseries Not available Not available California Deciduous Fruit & Nut Tree Growers Not available Not available California Nursery Roses Not available Not available NATIONAL TOTAL: Not available Not available 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.

Nurseries must provide pest ( pathogens) free stock and rely on MB for certification requirements when the nematicide 1,3 D is not allowed because of soil conditions or township caps. Some areas with light, sandy soil types, appropriate soil moisture, and no legal restrictions should be able to replace MB with 1,3 D alternatives. U. S. Fruit, Nut, & Flower Nursery Page 11 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?

The critical need for MB exists for nurseries that are limited by state certification requirements or soil conditions where 1,3 D formulations are unacceptable.

8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE TABLE 8.1. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: Western Raspberry Nurseries California Deciduous Fruit & Nut Tree Growers California Nursery Roses YEAR OF EXEMPTION REQUEST 2007 2007 2007 KILOGRAMS OF METHYL BROMIDE 53,464 44,038 22,700 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Flat Fumigation Flat Fumigation Flat Fumigation FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 75: 25 98: 2 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( ha) 210 132 80 APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 255 334 284 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 25.5 33.4 28.4 * For Flat Fumigation treatment application rate and dosage rate may be the same. U. S. Fruit, Nut, & Flower Nursery Page 12 9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION:

The amount of MB nominated by the U. S. was calculated as follows:   The percent of regional hectares in the applicant's request was divided by the total area planted in that crop in the region covered by the request.   Hectares counted in more than one application or rotated within one year of an application to a crop that also uses MB were subtracted. There was no double counting in this sector.   Growth or increasing production ( the amount of area requested by the applicant that is greater than that historically treated) was subtracted.   Quarantine and pre shipment ( QPS) hectares is the area in the applicant's request subject to QPS treatments.   Only the hectares experiencing one or more of the following impacts were included in the nominated amount: moderate to heavy key pest pressure, regulatory impacts, and unsuitable terrain.

WESTERN RASPBERRY NURSERIES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE WESTERN RASPBERRY NURSERIES 10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST WESTERN RASPBERRY NURSERIES. TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY PESTS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Western Raspberry Nurseries Primarily pathogens: Phytophthora fragariae var. Rubi ( root rot), Verticillium spp. ( wilt), others including Pythium spp., Rhizoctonia spp. To meet certification requirements for sale of nursery stock.

WESTERN RASPBERRY NURSERIES 11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE Raspberry nurseries in the western U. S. provide raspberry stock to most of the growers in North America. Raspberry nurseries have a large impact on raspberry production overall. USDA organic standards specifically allow the use of nursery stock propagated using MB for organic production in recognition of the vital role vigorous planting stock plays in organic and integrated pest management systems. This further confirms that the use of MB in propagation nurseries reduces the need for MB, and other chemical inputs, in fruiting fields. MB use is concentrated within nurseries having a total area of approximately 200 hectares. U. S. Fruit, Nut, & Flower Nursery Page 13 According to this consortium, "  fallow is part of the two year cycle. The production of one acre of raspberry nursery is a 24 month process. It begins with land preparation in January of year 1. A cover crop is then grown during the winter, spring and early summer of year 1. In the summer the cover crop is incorporated into the soil and the land is prepared for fumigation. There is a brief fallow period in June of year 1 prior to fumigation. The field is fumigated in August of year 1. The planting beds are constructed in September of year 1. These beds lay " fallow" through the winter, until February of year 2. The planted crop will grow until harvest in November and December of year 2. Following the harvest we begin another cycle in January.

Although the nursery is a 24 month process, some land is fumigated each year to provide an annual supply of planting stock for our farmers. Therefore, the amount stated in the application refers to an annual usage."

WESTERN RASPBERRY NURSERIES. TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS WESTERN RASPBERRY NURSERIES CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Raspberry cane stock ANNUAL OR PERENNIAL CROP: (# of years between replanting) 2 3 TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) 1 year in foundation nursery, 1 year in commercial nursery. The raspberry nursery industry utilizes flat fumigation techniques similar to that of the strawberry industry. Raspberry nursery stock are grown using a two year production cycle beginning with tissue culture and moving to foundation nurseries the first year. Winter dormant plants are replanted in commercial nurseries and harvested after one year. Ten hectares of plants in a foundation nursery will serve to plant 100 hectares of a commercial nursery. A commercial nursery produces enough plants to provide 1200 hectares of commercial fields; therefore, pest infestation of nursery plants can impact significant areas of commercial fields.

SOIL TYPES: ( Sand, loam, clay, etc.) Typically light or medium FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once in 2 3 years OTHER RELEVANT FACTORS: None identified U. S. Fruit, Nut, & Flower Nursery Page 14 WESTERN RASPBERRY NURSERIES. TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA zones 8a, 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 * For Fresno, California.

WESTERN RASPBERRY NURSERIES 11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Soil moisture is an important determinant of capacity of 1,3 D efficacy ( 5). Moisture above 12% is common below 1 meter depth and reduction of 1,3 D nematicidal activity results at this moisture level; this is especially a problem with nurseries with heavier soils. It is critical that nurseries control pests in the top 1 meter of soil because the plant roots extend to this depth. U. S. Fruit, Nut, & Flower Nursery Page 15 WESTERN RASPBERRY NURSERIES 12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED WESTERN RASPBERRY NURSERIES. TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 83 103 111 103 131 150 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 21,313 26,671 26,937 24,188 30,570 37,714 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 ) Shank injected, with tarp Shank injected, with tarp Shank injected, with tarp Shank injected, with tarp Shank injected, with tarp Shank injected, with tarp APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 257 258 242 235 234 252 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 25.7 25.8 24.2 23.5 23.4 25.2 * For Flat Fumigation treatment application rate and dosage rate may be the same. U. S. Fruit, Nut, & Flower Nursery Page 16 WESTERN RASPBERRY NURSERIES. PART C: TECHNICAL VALIDATION WESTERN RASPBERRY NURSERIES 13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE WESTERN RASPBERRY NURSERIES. TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Chloropicrin Not sufficiently effective to meet standards for pest free nursery stock No 1,3 dichloropropene ( 1,3 D) In areas with moisture restrictions ( e. g., > 12% at 1 1.5 meters) ( or under township caps) would not be able to meet standards for pest free nursery stock; nurseries with no such restrictions should be able to use 1,3 D as an alternative Possibly, where soil conditions and township caps allow use Metam sodium Not sufficiently effective to meet standards for pest free nursery stock No Dazomet As with metam sodium, would not meet standards for nursery. The use of dazomet in combination with 1,3 D was examined in a study submitted by the applicant. The study showed that although weed populations were suppressed, nematode populations were not controlled, causing stock to be commercially unacceptable. When dazomet was used in combination with 1,3 D, nematode populations were 15 times greater when compared to that of a dual application of 1,3 D. No U. S. Fruit, Nut, & Flower Nursery Page 17 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

NON CHEMICAL ALTERNATIVES Containerized production A field is planted with tissue culture plugs. The wide, flat planting beds allow these plants to grow laterally in all directions and to produce long straight roots. The nursery is watered using overhead irrigation, this creates optimal growing conditions over the entire surface area of the beds.

At the end of the growing season when plants are dormant they are mowed to about 20 cm long. The canes are chopped into small pieces and later they are incorporated into the soil to increase the organic matter. Then the beds are " lifted" and shaken, this removes soil from the plants and makes it easier to pick the plants up and place them in a box for transfer to the trimming operation. This system is efficient because the crews can move up each row with a mower, then the lifter followed by several workers who transfer the plants into the bin for movement to the trimming operation ( Maybe add a sentence such as: Containerized production would change this efficient harvesting system and require different equipment.).

Plants are produced with long straight roots, which are trimmed from the canes. The trimmed roots provide the root planting material used by the growers. Generally, container grown plants produce shorter or curved roots. New canes are produced from adventitious root buds, it is likely that any reduction in surface area would reduce the number and/ or quality ( size, strength) of these new adventitious canes.

Nursery managers have observed that when raspberries are grown in pots, the south, or hot, side of the pot has a reduced or absent root system, which reduces yield and increases water demands. Some of the largest nurseries are located in the eastern San Joaquin Valley of California where temperatures can reach over 40 C in the summer. Roots are not as large or healthy as what is produced in field systems. No Virtually Impermeable Film ( VIF) May have a role in reducing MB use rates while maintaining efficacy due to reduced emissions ( Guillino et al., 2002; Martin, 2003). Ongoing studies may help assess value of VIF with MB and chemical alternatives ( VIF use is restricted in California). No U. S. Fruit, Nut, & Flower Nursery Page 18 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Biofumigation, solarization, steam heat, biological control, cover crops/ mulches, crop rotation, flooding and water management, grafting/ resistant rootstocks, organic amendments, sanitation, and resistant cultivars Some of these alternatives are important components of an IPM system and are currently employed by the industry. These practices include field sanitation to reduce inoculum, crop rotation to reduce hosts, and attempts to breed resistance to pathogens. However, these alternatives will not meet requirements of CDFA for nursery stock certification either individually or in combinations. Use of flooding is not practical because of the topographic features of many production areas and requirements for excessive water use. The use of steam also requires large quantities of water and is slow and expensive to perform, which would impact planting and production intervals for this industry. Use of solarization is not practical due to the depth of heating required to eliminate propagules; environmental constraints at high altitude nurseries, including high winds, are of concern. Biological control currently is not an effective alternative; studies done with biological control agents at Clemson University, South Carolina, in conjunction with University of California Riverside, have not shown sufficient efficacy to date to allow commercial use in 2007. No COMBINATIONS OF ALTERNATIVES ( 1,3 D) + chloropicrin In areas with moisture restrictions ( e. g., > 12% at 1 1.5 meters) ( or under township caps) would not be able to meet standards for pest free nursery stock; nurseries with no such restrictions should be able to use 1,3 D as an alternative Where soil conditions and township caps allow use ( 1,3 D) + metamsodium In areas with moisture restrictions ( e. g., > 12% at 1 1.5 meters) ( or under township caps) would not be able to meet standards for pest free nursery stock; nurseries with no such restrictions should be able to use 1,3 D as an alternative Metam sodium may be helpful where weeds are problems. Where soil conditions and township caps allow use * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

WESTERN RASPBERRY NURSERIES. 14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

WESTERN RASPBERRY NURSERIES  TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION As listed in Table 13.1 As listed in Table 13.1 U. S. Fruit, Nut, & Flower Nursery Page 19 WESTERN RASPBERRY NURSERIES  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

WESTERN RASPBERRY NURSERIES. TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE Present Registration Status REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Sodium azide No registration has been requested No Unknown Propargyl bromide No registration has been requested No Unknown Iodomethane Not registered in U. S. Yes Unknown WESTERN RASPBERRY NURSERIES  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 As with other nursery commodities, yield is not the only ( and possibly not the most important) factor in the production of raspberry nursery stock. What is of primary importance is pest free stock that is of sufficient quality to meet government standards and comply with standards for intra and interstate plant transit. Consequently, for nurseries restricted in their use of 1,3 D, there is a critical need for MB for 2007. U. S. Fruit, Nut, & Flower Nursery Page 20 WESTERN RASPBERRY NURSERIES. TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   DISEASES KEY PEST: DISEASES AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF TRIALS DISEASE (% OR RATING) # OF TRIALS ACTUAL YIELDS ( T/ HA) CITATION [ 1] MB ( 263 kg/ ha) + chloropicrin ( 129 kg/ ha) [ 2] chloropicrin ( 140 kg/ ha) [ 3] no fumigation No pests identified 12 reps Runners/ mother plant ( strawberry) [ 1] 18.0a [ 2] 15.7b [ 3] 7.9c Larson and Shaw, 2000 [ 1] MB ( 314 kg/ ha) + chloropicrin ( 78 kg/ ha) [ 2] chloropicrin ( 191 kg/ ha) [ 3] chloropicrin ( 303 kg/ ha) [ 4] no fumigation No pests identified 4 reps Runners/ mother plant ( strawberry) [ 1] 29.7a [ 2] 27.0a [ 3] 29.7a [ 4] 11.2b Larson and Shaw, 2000 [ 1] MB ( 263 kg/ ha) + chloropicrin ( 129 kg/ ha) [ 2] chloropicrin ( 157 kg/ ha) [ 3] chloropicrin ( 314 kg/ ha) [ 4] no fumigation No pests identified 24 reps Runners/ mother plant ( strawberry) [ 1] 18.8a [ 2] 16.7b [ 3] 18.9a [ 4] 10.3c Larson and Shaw, 2000 [ 1] MB ( 263 kg/ ha) + chloropicrin ( 129 kg/ ha) [ tarped, noble plow] [ 2] chloropicrin ( 168 kg/ ha) [ 3] chloropicrin ( 336 kg/ ha) [ 4] 1,3 D ( 134 kg/ ha) + chloropicrin ( 314 kg/ ha) [ 5] 1,3 D ( 361 kg/ ha) + chloropicrin ( 155 kg/ ha) [ 6] no fumigation No pests identified 12 reps ( MB trt, 11 reps) Runners/ mother plant ( strawberry) [ 1] 39.2a [ 2] 28.6bc [ 3] 33.8abc [ 4] 35.8ab [ 5] 33.0bc [ 6] 15.8d Larson and Shaw, 2000 N. B.: some studies were with strawberry research, a crop with similar pest problems and because of the large size of the industry, a greater resource for research data. WESTERN RASPBERRY NURSERIES. TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D ( 225 kg/ ha)+ chloropicrin ( 123 kg/ ha) ( fungal) pathogens ( strawberry nursery) 2 15% ( ref.: CDFA, 1996; Gullino et al., 2002) 14%

Chloropicrin ( 300 kg/ ha) ( fungal) pathogens ( strawberry nursery) 5 16% ( ref.: CDFA, 1996; Gullino et al., 2002) 9%

Metam sodium ( 350 kg/ ha) ( fungal) pathogens ( strawberry nursery) 13 57% ( Gullino et al., 2002) 30%

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 9% plus certification issues U. S. Fruit, Nut, & Flower Nursery Page 21 More important than yield for raspberry nurseries, as well as other nurseries, is their dependence on certification of stock as ` pest free' in order to meet state requirements to sell to commercial outlets.

WESTERN RASPBERRY NURSERIES  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

Raspberry nurseries have spent $ 100,000 on research, including $ 20,000 on screening resistance for Phytophthora and Verticillium, and over $ 60,000 over the last decade studying various alternatives in the large Watsonville, California area. Studies are also ongoing to discover how application methods can improve efficacy of chemical alternatives such as 1,3 D and metam sodium, and mixes of chemicals. Moisture constraints, both too much and too little, can reduce efficacy of effective chemicals such as 1,3 D, especially when soil textures are not optimal for their physical chemistry. Iodomethane is a potential replacement for MB, but it has not been registered in the U. S.

The use of virtually impermeable film ( VIF) may offer a means of reducing fumigant use rates while maintaining efficacy and production goals, although VIF use is currently restricted in California. There is also interest in examining the effects of certain fertilizer salts ( e. g., ammonium thiosulfate, see Gan and Yates, 1998), which may act as barriers to volatile compounds ( e. g., 1,3 D, MB) when applied to the soil surface, thus reducing emissions and improving efficacy.

WESTERN RASPBERRY NURSERIES 18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

Under some conditions ( where soils are appropriate and regulations do not prohibit use) alternative chemicals are used and research is ongoing to increase efficacy, as has been described above.

WESTERN RASPBERRY NURSERIES SUMMARY OF TECHNICAL FEASIBILITY The raspberry nursery industry faces the same problems that other nurseries face in their need to produce nearly pest free plant stock to their respective growers. Quality of stock plants may have a greater place in the requirements of the nursery managers than quantity since there can be an exponential increase in pest pressure when infested nursery stock is transferred to production fields. Therefore, the threshold for nurseries to manage pest problems is higher than might be for field production and critical need for effective pest management tools is paramount. Because locations of nurseries vary and soil, climate, and water situations are variable, alternatives such as 1,3 D, may be acceptable substitutes for MB under some conditions. Results of meta analyses ( Larson and Shaw, 2000; Shaw and Larson, 2000) of numerous research studies indicate that for the nurseries unable to use 1,3 D, other alternatives are not sufficiently effective to meet their production needs. U. S. Fruit, Nut, & Flower Nursery Page 22 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS. TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY PESTS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED California Deciduous Fruit & Nut Tree Growers Nuts: Nematodes   Pratylenchus vulnus ( root lesion), Meloidogyne spp. ( root knot), Helicotylenchus dihystera ( spiral), Xiphinema americanum ( dagger).

Stone Fruit: Nematodes   Helicotylenchus dihystera ( spiral), Tylenchus mexicanus ( Tylenchus), Tylenchorhynchus spp. ( stunt), Trichodorus spp. ( stubby root) Nurseries providing stock for orchards are required to provide the stock that is pest free ( and particularly nematode free). 1,3 D is an effective nematicide, but its use is restricted in California. Compounds producing methyl isothiocyanate ( MITC) have been tested as possible alternatives ( e. g., metam sodium and dazomet) but nematode control was not sufficient to meet certification requirements.

The goal in the orchard nursery industry is 99.9% control when sampled within 30 60 days after treatment, so certification can be met when stock is harvested 18 months later ( McKenry, 2000). Generally, less than 98% control in the 30 60 day sampling period will yield unacceptable stock plants. Field moisture is a carefully monitored factor. A site ( e. g., walnut nursery in Davis, California) with silty clay loam over sandy loam or clay loam has moisture differential with the lighter textured soils holding more moisture (> 12%), which can impede distribution of an alternative such as 1,3 D ( McKenry, 2000) and make it ineffective. In California deciduous tree nurseries, approximately 30% have silt or clay loam soils requiring MB. The remaining 70% have sand or sandy loam soils. Approximately one half of these areas have a critical need for MB due to moisture requirements. According to the applicant, approximately 65% of nursery soils in California have a critical need for MB. Township caps for 1,3 D may further limit the use of the best alternative. U. S. Fruit, Nut, & Flower Nursery Page 23 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE Deciduous tree nurseries range from 15 to over 600 hectares. The median operation in California ranges between 80 and 120 hectares. While some nurseries concentrate on specific tree crops, most nurseries grow and sell a variety of different trees. Nursery stock is grown on a cropping system that includes crop rotation or cover cropping between tree production cycles; therefore, not all of the nursery land is in production in a given year.

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Nursery tree stock ANNUAL OR PERENNIAL CROP: (# of years between replanting) Perennial ( 1 to 2 years in nursery)

TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) The tree production cycle can be anywhere from 1 year to several years depending on the type of tree crop. Nursery production of trees takes from 1 4 years. Almonds take one year, walnuts take at least two years. Also, desired tree size determines how long it is grown in the nursery. A typical cycle is for the tree crop to be in the ground for either 1 or 2 years. A typical nursery cycle starts by digging the current tree crop ( to be sold) then planting a cover crop for 1 or 2 years, followed by replanting with a tree crop. Fields are disked, deep ripped, leveled, and then fumigated to meet certification standards set by the California Department of Food and Agriculture ( CDFA, 1996). A shank is used to apply a fumigation of 75% MB and 25% chloropicrin, typically at a rate of 340 kg per hectare. The treated area is covered with a high barrier tarp. The fumigation is carried out around August and September, and planting begins in October, and may continue through January. The deciduous nurseries are subject to mandates set forth by the CDFA, that trees must be pest free.

SOIL TYPES: ( Sand, loam, clay, etc.) Mostly sandy loam ( also sandy clay loam, sandy loam, silt loam, clay loam); light soils ( 20%), medium ( 50%), heavy ( 30%) FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Typically once in 3 5 years, depending on crop OTHER RELEVANT FACTORS: Nursery stock is inspected by county agricultural commissioners through the California Department of Food and Agriculture ( CDFA). Stock must be " found free of especially injurious pests and disease symptoms" to qualify for the CDFA Nursery Stock Certificate for Interstate and Intrastate Shipments. MB is the only approved fumigant for fields with a known history of nematodes, unknown history, or moderate to heavy clay content soils. 1,3 D is a legally acceptable treatment where township restrictions and physical limitations ( e. g., moisture greater than 12% in many soils reduces efficacy of 1,3 D) do not prevent its use. U. S. Fruit, Nut, & Flower Nursery Page 24 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA zones 8a, 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 X PLANTING SCHEDULE X X X X * For Fresno, California.

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Soil moisture content of greater than 12% reduces efficacy of 1,3 D. Soils that are so dry are unusual at 1.5 meters ( the depth required to be nematode free) ( CDFA, 1996) especially with moderate to heavy subsoils. Approximately 65% of nurseries require MB to meet certification requirements ( especially in wet years). Areas with light soils and dry conditions generally have good results from 1,3 D ( where township caps allow its use) and combinations with chloropicrin and/ or metam sodium. ( See Section 10, above.) U. S. Fruit, Nut, & Flower Nursery Page 25 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED Approximately 30% of nursery soils are clay or silt loam and require MB, while one half of the remaining sand or sandy loam soils do not meet the moisture requirements of less than 12% for use of 1,3 D. Therefore, approximately 65% of the nurseries have a critical need for MB. MB, 1,3 D and some solarization treatments are the only approved fumigants for treatment of nematodes in nurseries to meet California Department of Food and Agriculture standards. However, MB is critical to the production of nematode free stock where 1,3 D is not feasible ( estimated by industry as approximately 65% of the area) because of incompatible soil moisture or soil type, or township cap limitations.

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 632 698 639 633 643 623 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 201,208 222,433 207,755 212,689 208,578 201,490 FORMULATIONS OF METHYL BROMIDE) 75: 25 75: 25 75: 25 75: 25 75: 25 75: 25 METHOD BY WHICH METHYL BROMIDE APPLIED ) Shank injected with tarp Shank injected with tarp Shank injected with tarp Shank injected with tarp Shank injected with tarp Shank injected with tarp APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 319 318 325 336 324 324 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 31.9 31.8 32.5 33.6 32.4 32.4 * For Flat Fumigation treatment application rate and dosage rate may be the same. U. S. Fruit, Nut, & Flower Nursery Page 26 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS. PART C: TECHNICAL VALIDATION CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS. TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Dazomet, metamsodium Not effective nematicides. The use of dazomet in combination with 1,3 D was examined in a study submitted by the applicant. The study showed that although weed populations were suppressed, nematode populations were not controlled, causing stock to be commercially unacceptable. When dazomet was used in combination with 1,3 D, nematode populations were 15 times greater when compared to that of a dual application of 1,3 D. No NON CHEMICAL ALTERNATIVES STANDARD NURSERY PRACTICES SEEK TO REDUCE PEST PROBLEMS WITH GENERAL IPM PROGRAMS. HOWEVER, FOR THIS SECTOR NON CHEMICAL ALTERNATIVES ARE NOT TECHNICALLY FEASIBLE BECAUSE OF CALIFORNIA CERTIFICATION REQUIREMENTS FOR NEMATODE FREE PLANT STOCK AND TOWNSHIP CAPS AND BUFFER ZONE RESTRICTIONS.

Virtually Impermeable Film ( VIF) May have a role in reducing fumigant use rates while maintaining efficacy ( Gullino et al., 2002; Martin, 2003). Studies are being conducted to assess film with MB and chemical alternatives, although there are legal restrictions to use of VIF in California. No Biofumigation, solarization, steam heat, biological control, cover crops/ mulches, crop rotation, flooding and water management, grafting/ resistant rootstocks, organic amendments, sanitation, and resistant cultivars. Some of these alternatives are important components of an IPM system and are currently employed by the industry. These practices include field sanitation to reduce inoculum, crop rotation to reduce hosts, and attempts to breed resistance to pathogens. However, these alternatives will not meet requirements of CDFA for nursery stock certification either individually or in combinations. Use of flooding is not practical because of the topographic features of many production areas and requirements for excessive water use. The use of steam also requires extremely large quantities of water and is very slow and expensive to perform which would impact planting and production intervals for this industry. Use of solarization is not practical due to the depth of heating required to eliminate viable weed seed and environmental constraints at high altitude nurseries including high winds. Biological control currently is not a feasible alternative; studies done with biological control agents at Clemson University, South Carolina, in conjunction with University of California Riverside, have not shown sufficient efficacy to date to expect commercial use in 2007. No COMBINATIONS OF ALTERNATIVES U. S. Fruit, Nut, & Flower Nursery Page 27 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

1,3 D + chloropicrin No 1,3 D + chloropicrin + metam sodium No 1,3 D + metamsodium No 1,3 D + dazomet In most affected areas, especially those with moderate to heavy soils or subsoils, moisture at depths of 1.5 meters ( depth required for nematode free certification) ( CDFA, 1996) is usually > 12%, which significantly reduces efficacy of 1,3 D. This situation might occur in 65% of affected soils. Research trials indicate that these alternatives can be effective in nematode control ( e. g., Schneider et al., 2002b, 2004; Westerdahl et al., 2002). For areas unable to use 1,3 D, there is a critical need for MB for 2007. According to one calculation ( Martin et al., 2003), overall in California 33% of the area previously fumigated with MB could not be treated with 1,3 D due to current township caps, regardless of efficacy. No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Discussed in Section 13 Discussed in Section 13 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Sodium azide No registration has been requested No Unknown Propargyl bromide No registration has been requested No Unknown Iodomethane Not registered in U. S. Yes Unknown U. S. Fruit, Nut, & Flower Nursery Page 28 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS. TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   NEMATODES.

KEY PEST: NEMATODES METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF TRIALS DISEASE (% OR RATING) CITATION [ 1] untreated [ 2] MB ( 568 kg/ ha) [ Tarped] [ 3] 1,3 D ( 272 kg/ ha) + chloropicrin ( 155 kg/ ha) [ Telone 35, Untarped] [ 4] 1,3 D ( 312 kg/ ha) + chloropicrin ( 177 kg/ ha) [ Telone 35, Tarped] [ 5] chloropicrin ( 400 kg/ ha) [ Untarped] [ 6] chloropicrin ( 455 kg/ ha) [ Tarped] Mean of 6 reps. in vine, tree, berry field nursery trial Rootknot nematode population/ cc soil sampled at 120 150 cm depth [ 1] 21.3a [ 2] 0b [ 3] 0b [ 4] 2.2b [ 5] 0b [ 6] 0b Schneider et al., 2002b [ 1] untreated [ 2] MB ( 285 kg/ ha) [ Tarped, Fall] [ 3] MB ( 285 kg/ ha) [ Tarped, Spring] [ 4] metam sodium ( 425 kg/ ha injected + 329 kg/ ha overlay rotovate) [ Tarped] [ 5] metam sodium ( 425 kg/ ha injected + 329 kg/ ha overlay rotovate) [ Untarped] 4 reps, trial Malin, Oregon, 2001; loamy sand; moisture 2% at surface, 19% at 1 meter) Percent control of citrus nematode ( bioindicator) compared to untreated:

[ 2] 93% ( some survival at 80 cm depth) [ 3] 93% ( some survival at 80 cm depth) [ 4] 81% ( survival at 65 80 cm depth) [ 5] 73% % ( survival below 5 cm depth) Westerdahl et al., 2002 [ 1] untreated [ 2] MB ( 455 kg/ ha) [ shank, Tarped] [ 3 1,3 D ( 445 kg/ ha) [ drip Telone II EC; Tarped] 4 reps, artificially inoculated soils with rootknot and citrus nematodes to depths of 30 cm, 90 cm, and 150 cm Percent control of citrus and rootknot nematodes compared to untreated:

[ 2] 100% ( at all depths) [ 3] significant nematode populations at 150 cm; control at 30 cm was " excellent" Schneider et al., 2003a U. S. Fruit, Nut, & Flower Nursery Page 29 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D ( 312 kg/ ha)+ chloropicrin ( 177 kg/ ha) Nematodes Not applicable Not applicable 1,3 D ( 312 kg/ ha) + chloropicrin ( 177 kg/ ha) + metam sodium ( 350 kg/ ha) Nematodes Not applicable Not applicable 1,3 D + metam sodium ( 350 kg/ ha) Nematodes Not applicable Not applicable OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS Not applicable; certification issues Yield is not a sufficient measure of critical need for MB for this industry or to determine economic feasibility in this sector since the issue is one of constraints due to the quality of the plant stock and the ability to have such stock certified as pest free in order to sell to commercial users.

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

Between 1999 and 2000, the California fruit, vine, and nut industries have spent $ 378,467 on numerous research projects. From 2002 2003, researchers were granted $ 262,002 by this industry. In addition, an equal amount of funding has been granted to these industries by government and universities.

Research for MB alternatives has been conducted by the nursery industry since at least 1990, initially to find alternatives to 1,3 D, whose registration had been cancelled ( Martin, 2003). Upon reinstatement in 1994, studies began to examine 1,3 D formulations that could provide acceptable nematode control under conditions ( especially critical moisture conditions) common to commercial nursery sites that would meet certification requirements and reduce or replace the use of MB ( Martin, 2003; McKenry, 2000). Successful treatment with 1,3 D depends on enough surface moisture to allow penetration into the soil, but less than 12% moisture.

Studies with new emulsifiable formulations of 1,3 D and chloropicrin , such as Inline, may improve efficacy by removing technical limitations of shank injected 1,3 D. However, township caps, buffer zones, and limitations due to physical characteristics of soils are still important issues to successful nursery production. U. S. Fruit, Nut, & Flower Nursery Page 30 CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

Nursery stock must meet pest free certification criteria. In situations where restrictions and conditions do not constrain use, 1,3 D is effective as a nematicide.

CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  SUMMARY OF TECHNICAL FEASIBILITY The primary concern for the deciduous tree nursery industry is their need to have their stock certified according to the strict standards set for inter and intrastate movement of plant material. According to the government oversight authorities ( CDFA, 1996) MB, and where allowed, 1,3 D, are the treatments that are recognized as able to satisfactorily control nematodes, the primary pest of deciduous tree nurseries. The issue with critical use of MB is the circumstance of many nurseries whose soil type or other conditions ( e. g., township caps, buffer zone limitations) precludes the use of 1,3 D formulations. Consequently, for 2007, MB is considered a critical tool to maintain production and market goals. In areas with appropriate soils, moisture, and no legal restrictions, 1,3 D formulations are effective in meeting certification requirements.

CALIFORNIA NURSERY ROSES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA NURSERY ROSES  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA NURSERY ROSES  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST 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 IS NEEDED California Nursery Roses ( primarily in the San Joaquin Valley   55% to 65% of U. S. rose plant production is located around Wasco, Kern County, CA) Root knot nematode ( Meloidogyne hapla); lesion nematode ( Pratylencus penetrans); pin nematode ( Paratylenchus hamatus); Verticillium dahlia; Pythium spp.; Agrobacterium tumefaciens; weeds ( including Cyperus spp.) California regulations state that nursery stock must be commercially clean with respect to established pests of general distribution. County agricultural officials may certify a crop based on the completion of a prescribed fumigation regime, such as the use of MB ( CDFA, 1996). U. S. Fruit, Nut, & Flower Nursery Page 31 CALIFORNIA NURSERY ROSES  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE CALIFORNIA NURSERY ROSES  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS CALIFORNIA NURSERY ROSES CROP TYPE: Transplant production ANNUAL OR PERENNIAL CROP: Perennial ( see below)

TYPICAL CROP ROTATION AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: Typically, crop rotation for a two year rose crop includes one year fallow, followed by one or two years of rotational crops, and then a two year rose crop. This rotation varies depending on the type of rose crop being produced ( i. e., two year roses, one year minis and patio trees, or an 18 month mini bush).

SOIL TYPES: Medium soil with 0 to 2% organic matter.

FREQUENCY OF METHYL BROMIDE FUMIGATION: Once every 4 to 5 years ( a typical grower fumigates and plants approximately 20 25% of the production area each year).

OTHER RELEVANT FACTORS: The perennial nature of the crop requires pest control to a depth of 1.5 meters. Certification requires commercially clean stock. In tree nursery production, there must be 99.9% nematode control in the first 30 to 60 days to meet this requirement ( McKenry, 2000).

CALIFORNIA NURSERY ROSES  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE+

MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA Plant Hardiness Zone 9a RAINFALL ( mm)* 16.0 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 Land prep X PLANTING SCHEDULE X X + The planting and fumigation schedule are for 1 year roses. The schedules vary for other rose crops. * Data for Jan Aug, 2003 and Sep Dec 2002 for Fresno, California.

For a particular parcel of land, the overall cycle is shown below ( Table 11.3). This schedule varies depending on the type of rose crop grown. For example, two year rose crops would be grown an additional year before harvesting.

CALIFORNIA NURSERY ROSES  TABLE 11.3 MULTI YEAR ROSE CROP SCHEDULE SPR* SUM FAL WNT SPR SUM FAL WNT SPR SUM FAL WNT SPR SUM FAL WNT FUMIGATION SCHEDULE X PLANTING SCHEDULE X HARVEST SCHEDULE X X FALLOW X X X X COVER CROP X X X X X * spr = spring; sum = summer; fal = fall; wnt = winter U. S. Fruit, Nut, & Flower Nursery Page 32 CALIFORNIA NURSERY ROSES   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Restrictions due to soil moisture or structure.

CALIFORNIA NURSERY ROSES  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA NURSERY ROSES  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 600 609 647 645 584 570 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation Flat Fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 201,803 204,933 217,588 219,938 183,396 161,624 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 98: 2 98: 2 98: 2 98: 2 98: 2 98: 2 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Shanked 10 inches deep and tarped Shanked 10 inches deep and tarped Shanked 10 inches deep and tarped Shanked 10 inches deep and tarped Shanked 10 inches deep and tarped Shanked 10 inches deep and tarped APPLICATION RATE [ ACTIVE INGREDIENT] ( kg/ ha*) 336 336 336 341 314 284 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 33.6 33.6 33.6 34.1 31.4 28.4 * For Flat Fumigation treatment application rate and dosage rate may be the same. U. S. Fruit, Nut, & Flower Nursery Page 33 CALIFORNIA NURSERY ROSES  PART C: TECHNICAL VALIDATION CALIFORNIA NURSERY ROSES  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA NURSERY ROSES   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 Dichloropropene 1,3 D is technically feasible in some situations, such as areas with sandy soils where the soil moisture can be reduced to 12 percent or less. According to California certification regulations, this alternative and MB are acceptable soil treatments ( CDFA, 1996).

In a tree nursery study, nematodes were controlled at deeper depths with 1,3 D and its combinations. Control is comparable to MB in sandier soils because the soil moisture can be reduced to 12 percent or less ( McKenry, 2000; McKenry, 2001). In a nursery rose trial, 1,3 D with chloropicrin ( Telone C 35) was comparable to MB ( Schneider et al, 2004). Results with 1,3 D may be inconsistent when pests other than nematodes are major problems ( Karlick et al, 1998).

Township caps are in place for 1,3 D. California nursery growers are located within two townships in one county, and rose growers compete for the use of 1,3 D with growers of almonds, carrots, and other crops ( Trout, 2001). Buffer zones reduce the amount of land that can be treated with 1,3 D. Possibly, if no restrictions apply; U. S. nomination is for areas where 1,3 D is not effective.

Dazomet ( Basamid) In a rose trial, dazomet did not adequately control target pests at the required depth in the soil ( Schneider et al, 2002a). Dazomet and metam sodium are both MITC generating substances and the inability of MITC to penetrate deep enough at the maximum allowed application rate is problematic for dazomet. No.

Metam sodium Metam sodium is not a technically feasible alternative alone because it results in nursery rose shipments that are not certifiable. Research indicates that a non certifiable crop occurs because metam sodium did not move deep enough into the soil ( at the 1.2 to 1.5 meter depth metam sodium did not control the nematodes) ( Schneider et al, 2002a; McKenry, 1999; Karlick et al, 1998). No. U. S. Fruit, Nut, & Flower Nursery Page 34 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

NON CHEMICAL ALTERNATIVES Solarization, Steam Sterilization, Biological Control Under proper climatic conditions, solarization will control pests to a depth of 30 cm. However, control is necessary to a depth of 1.5 meters ( Pizano, 2001; Braun and Supkoff, 1994). No.

General IPM, Grafting/ Resistant Rootstock/ Plant Breeding, Physical Removal/ Sanitation, Resistant Cultivars Although these " not in kind" alternatives are being used by nursery rose growers to reduce pest pressure, in general, by themselves and in combination, each have not been successful at achieving adequate pest control. No.

Substrates/ Plug Plants Use of " plug plants" is not feasible for nursery growers because virtually all production is by grafting onto resistant rootstock, not by the use of cuttings.

Bareroot shipments are usually in temperature controlled trucks of approximately 20,000 roses per truck. Container roses ship at approximately 2,000 roses per truck, resulting in a significant economic burden.

Substrate production in CA is not acceptable for two reasons. One, roses are a deep rooted crop. Rose rootstock is grown for 18 months ( called 1 year by the market) or 2 years resulting in root systems of 3 feet. The containers do not allow full development of the root systems, which then reduces the vigor of the plant. Second, production in CA is technically infeasible based on the scale of production. Research will have to be conducted to determine the commercial feasibility of a change of this scale to soilless culture. No.

COMBINATIONS OF ALTERNATIVES 1,3 Dichloropropene + chloropicrin and/ or metam sodium See the regulatory and technical limitations for 1,3 D above. Possibly, if no restrictions apply; U. S. nomination is for areas where 1,3 D is not effective. * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

CALIFORNIA NURSERY ROSES  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

CALIFORNIA NURSERY ROSES   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Iodomethane + chloropicrin This alternative is not registered in the U. S. U. S. Fruit, Nut, & Flower Nursery Page 35 CALIFORNIA NURSERY ROSES  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

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

Iodomethane Not registered Yes Unknown Sodium azide Registration package not submitted No Unknown Propargyl bromide Registration package not submitted No Unknown CALIFORNIA NURSERY ROSES  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 Perennial Crop Nurseries   Performance of Methyl Bromide Alternatives in the Field ( Schneider et al, 2004). " Rootknot nematode was found in the roots of plants grown in the untreated plots and in plots treated with MIDAS [ iodomethane, 30% and chloropicrin, 70% @ 448 kg/ ha drip applied], untarped Telone C35, chloropicrin [ 224 kg/ ha, split application], metam sodium, and Iota [ bacterial suspension]. Treatments resulting in nematode infested roots are not acceptable for certified nursery use. The largest plants were in plots treated with methyl bromide or tarped Telone C35".

Evaluation of Alternatives to Methyl Bromide for Roses ( Schneider et al, 2002a; Schneider et al, 2003b). Preliminary data from a study by the Agricultural Research Service, USDA were submitted. Nematodes were sampled in 250 cc soil at the following depths: 0 0.3 meters, 0.3 0.6 meters, 0.6 0.9 meters, 0.9 1.2 meters, and 1.2 1.5 meters. Stunt nematode ( Tylenchorhynchus spp.) was predominantly found at the site, but populations of root knot nematode ( Meloidogyne spp.) and stubby root nematode ( Paratrichodorus spp.) were also present at low levels. The only alternatives that provided control to the lowest depth ( 1.2 to 1.5 meters) were MB and iodomethane drip applications, although these results were not statistically different from many of the other alternatives. The following year, additional data were collected, including weed ratings. MB had the best weed rating of all the alternatives. Additional data, including summer/ fall nematode and fungal populations in the soil and plant quality at harvest, are yet to be collected. The results are shown in Tables 16.3 and 16.4.

Jackson and Perkins Fumigant Tests, 2003. Preliminary data submitted by Jackson and Perkins Operation, Inc. showed yield losses of 2   8% for metam sodium ( Vapam HL, 701 L/ ha), yield losses of 5% for 1,3 D ( Telone II, 309 L/ ha), and for MB ( 336 kg/ ha) yield gains of up to 10% to yield losses of 6% The data submitted gave yields compared to historic yields for numerous rose varieties. The first year results indicated that there was no nematode pressure in the trials. There was no statistical analysis on the results. U. S. Fruit, Nut, & Flower Nursery Page 36 Other studies submitted were conducted on orchard and vineyard crops. Some the results are included in the tables below. These studies demonstrate that the alternatives do not provide the same level of nematode control as MB to the depth required.

CALIFORNIA NURSERY ROSES   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   NEMATODES KEY PEST: NEMATODES AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS TOTAL # NEMATODES AT A DEPTH ACROSS ALL REPLICATES ( The results have been added across the 4 replicates   there is no statistical analysis on these results). METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF REPLICATIONS DEPTH # OF NEMATODES MB + CP ( 75/ 25) 535 lb/ ac ( 599 kg/ ha), tarped 4 0 1 feet ( 0 0.3 meters) 1 2 feet ( 0.3 0.6 meters) 2 3 feet ( 0.6 0.9 meters) 3 4 feet ( 0.9 1.2 meters) 4 5 feet ( 1.2 1.5 meters) 0 0 0 2 15 Dual application Telone C 35 @ 65 gpa ( 608 L/ ha) or approx. 650 lb/ acre ( 728 kg/ ha) 4 0 1 feet ( 0 0.3 meters) 1 2 feet ( 0.3 0.6 meters) 2 3 feet ( 0.6 0.9 meters) 3 4 feet ( 0.9 1.2 meters) 4 5 feet ( 1.2 1.5 meters) 2 1 0 2 47 1,3 D ( 330 lb/ ac ( 370 kg/ ha)) then metam sodium drench ( 110 lb/ ac ( 123 kg/ ha)) 4 0 1 feet ( 0 0.3 meters) 1 2 feet ( 0.3 0.6 meters) 2 3 feet ( 0.6 0.9 meters) 3 4 feet ( 0.9 1.2 meters) 4 5 feet ( 1.2 1.5 meters) 5 0 1 40 103 1,3 D ( 330 lb/ ac ( 370 kg/ ha)) then Basamid drench ( 200 lb/ ac ( 224 kg/ ha)) 4 0 1 feet ( 0 0.3 meters) 1 2 feet ( 0.3 0.6 meters) 2 3 feet ( 0.6 0.9 meters) 3 4 feet ( 0.9 1.2 meters) 4 5 feet ( 1.2 1.5 meters) 0 0 0 2 16 Non treated check 4 0 1 feet ( 0 0.3 meters) 1 2 feet ( 0.3 0.6 meters) 2 3 feet ( 0.6 0.9 meters) 3 4 feet ( 0.9 1.2 meters) 4 5 feet ( 1.2 1.5 meters) 98 455 416 836 216 McKenry, 2000 ( this study was conducted on tree nurseries). U. S. Fruit, Nut, & Flower Nursery Page 37 CALIFORNIA NURSERY ROSES   TABLE 16.2: EFFECTIVENESS OF ALTERNATIVES   PHYTOPHTHORA KEY PEST: PHYTOPHTHORA CITRICOLA AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS TOTAL NUMBER OF COLONIES FORMED OUT OF 10 INOCULUM PIECES PLATED AT CERTAIN DEPTHS ACROSS ALL REPLICATES ( max # is 40   4 reps x10 pieces. No statistical analysis on these results) METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF REPLICATIONS DEPTH # OF COLONIES MB + CP ( 75/ 25) 535 lb/ ac ( 599 kg/ ha), tarped 4 0.5 feet ( 0.2 meters) 2.0 feet ( 0.6 meters) 4.0 feet ( 1.2 meters) 0 10 40 Dual application Telone C 35 @ 65 gpa ( 608 L/ ha) or approx. 650 lb/ acre ( 728 kg/ ha) 4 0.5 feet ( 0.2 meters) 2.0 feet ( 0.6 meters) 4.0 feet ( 1.2 meters) 0 0 20 1,3 D ( 330 lb/ ac ( 370 kg/ ha)) then metam sodium drench ( 110 lb/ ac ( 123 kg/ ha)) 4 0.5 feet ( 0.2 meters) 2.0 feet ( 0.6 meters) 4.0 feet ( 1.2 meters) 5 20 38 1,3 D ( 330 lb/ ac ( 370 kg/ ha)) then Basamid drench ( 200 lb/ ac ( 224 kg/ ha)) 4 0.5 feet ( 0.2 meters) 2.0 feet ( 0.6 meters) 4.0 feet ( 1.2 meters) 0 0 40 Non treated check 4 0.5 feet ( 0.2 meters) 2.0 feet ( 0.6 meters) 4.0 feet ( 1.2 meters) 37 30 30 McKenry, 2000 ( This study was conducted on tree nurseries). U. S. Fruit, Nut, & Flower Nursery Page 38 CALIFORNIA NURSERY ROSES   TABLE 16.3: EFFECTIVENESS OF ALTERNATIVES   STUNT NEMATODE KEY PEST: STUNT NEMATODE Disease (% or rating) Mean of 6 replications METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF REPS 0   0.3 METERS ( 0 12 INCHES) 0.6 0.9 METERS ( 24 36 INCHES) 1.2   1.5 METERS ( 48 60 INCHES)

Untreated 6 1.0 b* 29.8 a 5.8 ab Methyl bromide   350 lb/ acre ( 392 kg/ ha), tarped   noble plow 6 0.0 b 0.0 b 0.0 c 30% Iodomethane 70% Chloropicrin   400 lb/ acre ( 448 kg/ ha), tarped   noble plow 6 0.0 b 0.0 b 0.4 bc Telone C35   48 gal/ acre ( 449 L/ ha)   noble plow 6 0.0 b 0.9 b 6.2 ab Telone C35   48 gal/ acre ( 449 L/ ha); untarped   telone rig 6 0.0 b 0.3 b 3.5 abc Inline   50 gal/ acre ( 468 L/ ha), drip 6 0.0 b 0.3 b 2.4 abc Telone EC   35 gal/ acre ( 327 L/ ha), drip 6 0.0 b 0.9 b 6.9 ab Chloropicrin   200 lb/ acre ( 224 kg/ ha), drip 6 0.0 b 3.0 b 13.3 a Chloropicrin   400 lb/ acre ( 448 kg/ ha), drip 6 0.0 b 1.4 b 4.8 abc Chloropicrin   200 + 200 lb/ acre ( 224 + 224 kg/ ha), drip 6 0.0 b 0.0 b 4.2 abc 30% Iodomethane 70%  400 lb/ acre ( 448 kg/ ha), drip 6 0.0 b 0.0 b 0.0 c 50% Iodomethane 50% Chloropicrin   300 lb/ acre ( 336 kg/ ha), drip 6 0.2 b 0.0 b 0.0c Metam sodium   75 gal/ acre ( 701 L/ ha) ( 42% a. i.), drip 6 0.2 b 0.0 b 10.0 a Iota ( a bacterial suspension from FUSION 360, Turlock, CA) 6 5.5 a 47.8 a 7.9 ab Schneider et al, 2002b * Statistical analysis conducted on log transformed ( ln ( n+ 1)) data. Data presented are the antilogs of the means. Stunt Nematode Populations per 250cc soil sampled at planting in a commercial rose trial. Results at other depths ( 12 24 inches ( 0.3 0.6 meters) and 36 48 inches ( 0.9 1.2 meters) are also available in the study. U. S. Fruit, Nut, & Flower Nursery Page 39 CALIFORNIA NURSERY ROSES   TABLE 16.4: EFFECTIVENESS OF ALTERNATIVES   ROOT KNOT NEMATODE KEY PEST: ROOT KNOT NEMATODE ROOT KNOT NEMTAODE POPULATIONS PER 100 CC SOIL SAMPLED AT PLANTING IN A COMMERCIAL ROSE TRIAL MARCH 2003 DISEASE (% OR RATING) # OF NEMATODES ( SOIL SAMPLED TO A DEPTH OF 0.6 METERS ( 24 INCHES) METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF REPS MEAN RANGE Untreated 6 18.0 a 0 805 Methyl bromide   350 lb/ acre ( 392 kg/ ha), tarped   noble plow 6 0 c 0 0 30% Iodomethane 70% Chloropicrin   400 lb/ acre ( 448 kg/ ha), tarped   noble plow 6 0 c 0 0 Telone C35   48 gal/ acre ( 449 L/ ha)   noble plow 6 0.8 bc 0 32 Telone C35   48 gal/ acre ( 449 L/ ha); untarped   telone rig 6 6.4 ab 0 354 Inline   50 gal/ acre ( 468 L/ ha), drip 6 0 c 0 0 Telone EC   35 gal/ acre ( 327 L/ ha), drip 6 0 c 0 0 Chloropicrin   200 lb/ acre ( 224 kg/ ha), drip 6 0 c 0 0 Chloropicrin   400 lb/ acre ( 448 kg/ ha), drip 6 0 c 0 0 Chloropicrin   200 + 200 lb/ acre ( 224 + 224 kg/ ha), drip 6 0 c 0 0 30% Iodomethane 70%  400 lb/ acre ( 448 kg/ ha), drip 6 0 c 0 0 50% Iodomethane 50% Chloropicrin   300 lb/ acre ( 336 kg/ ha), drip 6 0 c 0 0 Metam sodium   75 gal/ acre ( 701 L/ ha) ( 42% a. i.), drip 6 0.5 bc 0 12 Iota ( a bacterial suspension from FUSION 360, Turlock, CA) 6 10.8 a 0 213 Schneider et al, 2003b Statistical analyses conducted on log transformed ( log ( n+ 1)) data. Data presented are antilogs of the means, as well as the range of values. Means followed by the same letter are not significantly different at the P= 0.05 level. U. S. Fruit, Nut, & Flower Nursery Page 40 CALIFORNIA NURSERY ROSES   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS See paragraph below. Nematodes Not applicable Not applicable OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS Not applicable; certification issues Although yield and quality losses may occur due to key pests, the only studies for nursery roses are ongoing. Because these studies are in progress and the crop is perennial, yield losses have not been determined. However, the crop must meet certification requirements or the stock will not be accepted. The pests must be controlled or the growers will not be able to sell their product.

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

The industry is developing technologies to improve efficacy of alternatives such as deep injection methods, soil moisture management by improving drip technologies, experience with virtually impermeable films to increase efficacy and decrease emissions. Between 2001 and 2003, $ 60,000 was devoted to nursery rose alternatives research at USDA and on farm research. A rose nursery trial ( Schneider et al., 2004) conducted for two years resulted in rootknot nematode control comparable to MB with use of tarped Telone C35. However, soil moisture and township caps will limit use of 1,3 D, and cost of tarping can significantly increase prices of nursery stock.

CALIFORNIA NURSERY ROSES  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

1,3 D may be an acceptable alternative to MB where restrictions do not apply. However, nurseries unable to use 1,3 D will have a critical need for MB in 2007. Some growers are able to control pests thus avoiding crops and weeds that are hosts to nematodes. However, re infestation is always a threat through contaminated irrigation water, runoff water, or weeds. In addition, the income from the rotational crops, often cereal crops, is about a third of that received for roses. U. S. Fruit, Nut, & Flower Nursery Page 41 CALIFORNIA NURSERY ROSES  SUMMARY OF TECHNICAL FEASIBILITY Although 1,3 D with chloropicrin has been demonstrated as an effective alternative in some situations, it is not available for use in all nurseries. In soils with moisture levels above 12%, 1,3 D does not provide control of nematodes. In addition, 1,3 D does not control Verticillium dahilae, Pythium spp., or weeds. There are regulatory limitations to the use of 1,3 D, yet growers must meet certification requirements. Township caps may limit the availability of this alternative to growers, especially since nursery roses are primarily produced in two townships, where other crops that use 1,3 D are also grown. Other alternatives, such as metam sodium and dazomet do not provide consistent control of target pests to a depth of 1.5 meters.

PART D: EMISSION CONTROL U. S. Fruit, Nut, & Flower Nursery Page 42 19. TECHNIQUES THAT HAVE AND WILL BE USED TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS IN THE PARTICULAR USE TABLE 19.1: TECHNIQUES TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS TECHNIQUE OR STEP TAKEN VIF OR HIGH BARRIER FILMS METHYL BROMIDE DOSAGE REDUCTION INCREASED % CHLOROPICRIN IN METHYL BROMIDE FORMULATION LESS FREQUENT APPLICATION WHAT USE/ EMISSION REDUCTION METHODS ARE PRESENTLY ADOPTED? Currently some growers use HDPE tarps. VIF might be a feasible means of reducing emissions if physical properties of VIF can be improved, especially the ability to successfully and consistently roll the film over beds without breakage and ability to glue the material. There are restrictions for use of VIF in California. Most nurseries have reduced MB amounts to lower rate formulations. Between 1997 and 2001, the U. S. has achieved a 36% reduction in use rates. From 2% to 33% or 25% ( for some nurseries) No 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 Research is underway to develop use of a 50% MB formulation where pest pressure allows. Research is underway to develop use of a 50% MB formulation where pest pressure allows. Not likely OTHER MEASURES ( please describe) Unidentified Unidentified Unidentified Fumigation once every 2   3 years 20. IF METHYL BROMIDE EMISSION REDUCTION TECHNIQUES ARE NOT BEING USED, OR ARE NOT PLANNED FOR THE CIRCUMSTANCES OF THE NOMINATION, STATE REASONS Technologies to reduce emissions are being addressed by this sector. For example, VIF, use of advanced delivery techniques, such as deep injection, to make alternative chemicals more effective at deeper soil levels, and reduction in use rate of MB to 50: 50. While new mixtures and formulations can be effective at controlling target pests, especially at low pest pressure, the long term efficacy of these mixtures is unknown, especially where pest free standards are in force. U. S. Fruit, Nut, & Flower Nursery Page 43 PART E: ECONOMIC ASSESSMENT 21. COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD TABLE 21.1: COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD This table is not included since none of the alternatives are technically feasible. See Summary of Economic Feasibility below.

22. GROSS AND NET REVENUE TABLE 22.1: YEAR 1 GROSS AND NET REVENUE TABLE 22.2: YEAR 2 GROSS AND NET REVENUE TABLE 22.3: YEAR 3 GROSS AND NET REVENUE These tables are not included since none of the alternatives are technically feasible. See Summary of Economic Feasibility below.

MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES WESTERN RASPBERRY NURSERIES  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA DECIDUOUS FRUIT & NUT TREE GROWERS  TABLE E. 2: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA NURSERY ROSES  TABLE E. 3: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES These tables are not included since none of the alternatives are technically feasible. See Summary of Economic Feasibility below. U. S. Fruit, Nut, & Flower Nursery Page 44 SUMMARY OF ECONOMIC FEASIBILITY An economic analysis was not done because most of the losses cannot be quantified because there are no data to substantiate the magnitude of these losses.

Certification requirements. The requested amount of MB in the U. S. nomination includes only those areas where 1,3 D would not meet the certification requirements or would be limited by township caps. The requirement that the nursery stock be certified as pest free is what makes the alternatives economically infeasible. Under California regulatory laws, nursery crops must be " free of especially injurious pests and disease symptoms" in order to qualify for a CDFA Nursery Stock Certificate for Interstate and Intrastate Shipments ( CDFA, 1996). If an approved fumigation is not used in the nursery, a costly nematode sampling procedure is imposed by CDFA, and if nematodes are found all nursery stock in an area should be destroyed resulting in a complete loss. MB meets the certification guidelines. Also, in certain soil conditions, 1,3 D meets certification guidelines; however, California township caps imposed by the CDPR ( California Department of Pesticide Regulation) may limit the use of 1,3 D.

If an approved fumigation is not used and a nematode sampling procedure is imposed by CDFA, it is likely that nematodes would be found because:   1,3 D is less effective in soil conditions where 1,3 D does not meet the certification guidelines, or   There is no effective nematicide if 1,3 D cannot be used due to California township caps.

If nematodes are found and the nursery stock cannot be certified " free of especially injurious pests and disease symptoms", then a total loss is likely because the nursery stock:   Would not qualify for a CDFA Nursery Stock Certificate for Interstate and Intrastate Shipments,   Would probably not be marketable, since resale for planting is severely restricted by the CDFA.   Should be destroyed to prevent further infestation.

Yield loss. It is likely that yield losses would also occur where soil conditions are not ideal, but little data are available. The yield loss could be 100% if the nursery stock cannot be certified as pest free.

Reduced pesticide use. An effective fumigation results in a growth response that allows an initial growth spurt. This growth response helps maintain a healthy plant, which is able to better handle the stress induced by pathogens and pests. A healthier plant consequently requires a fewer number of pesticide sprays during the season.

Beyond the nursery. Healthier plants and trees provide benefits beyond the nursery in terms of higher yields of fruit and nuts and reduced infestations. One hectare of nursery stock provides these benefits to many hectares producing fruits and nuts. U. S. Fruit, Nut, & Flower Nursery Page 45 PART F. FUTURE PLANS 23. WHAT ACTIONS WILL BE TAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS CROP?

There is ongoing development of technologies to improve efficacy of alternatives, such as deep injection methods, soil moisture management by improving drip technologies, experience with VIF to increase efficacy and decrease emissions, all while allowing reasonable cost effectiveness. Even where MB is considered critical, an improvement in efficient delivery techniques will result in reduction of MB use requirements and application rates. For roses, future research is planned for nematodes, Pythium and weeds. For 2001 2003, $ 60,000 was devoted to alternatives research at USDA and on farm research. Raspberry nurseries have spent $ 100,000 on research, including $ 20,000 on screening resistance for Phytophthora and Verticillium, and over $ 60,000 over the last decade studying various alternatives in the large Watsonville, California area. Between 1999 and 2000, the California fruit, vine, and nut industries have spent $ 378,467 on numerous research projects. From 2002 2003, $ 262,002 were granted to researchers by this industry. In addition, an equal amount of funding has been granted to these industries by government and universities. The amount of MB requested for research purposes is considered critical for the development of effective alternatives. Without MB for use as a standard treatment, the research studies can not address the comparative performance of alternatives.

24. ARE THERE PLANS TO MINIMIZE THE USE OF METHYL BROMIDE FOR THE CRITICAL USE IN THE FUTURE?

As stated in Section 23, minimizing use of MB can be achieved through the development of technologies to improve efficacy of alternatives. Plans to develop VIF, deep injection, 1,3 D efficacy, and reduction of MB use rates are all ongoing. Transferring these technologies to field situations requires additional time. This consortium are developing timelines for this transition. However, for 2007, MB will be critical for nurseries unable to use effective alternatives. U. S. Fruit, Nut, & Flower Nursery Page 46 25. ADDITIONAL COMMENTS ON THE NOMINATION?

This critical use exemption nomination has been reviewed by the U. S. government and meets the guidelines of The Montreal Protocol on Substances That Deplete the Ozone Layer. The nomination for MB is for nurseries that are unable to use effective alternatives to MB to attain certification for nursery plant material. For raspberry, rose, and deciduous tree nurseries that can not use 1,3 D due to legal restrictions or physical limitations, MB use will be critical for 2007. The loss of MB under these circumstances would result in a significant market disruption. U. S. Fruit, Nut, & Flower Nursery Page 47 26. CITATIONS Braun, A. L. and D. M. Supkoff, 1994. Options to Methyl Bromide for the Control of Soil Borne Diseases and Pests in California with Reference to the Netherlands. Pest Management Analysis and Planning Program, California Department of Pesticide Regulation.

California Department of Food and Agriculture. 1996. Approved treatment and handling procedures to ensure against nematode pest infestation of nursery stock. California Code of Regulations, Title 3, Section 3060, et seq. Nursery Inspection Procedures Manual, Item # 12. 18 pp.; http:// www. cdfa. ca. gov/ phpps/ pe/ nipm_ pdfs/ nipm_ 7. pdf Federal Register, February 5, 1998, 40 CFR, part 82. Control of methyl bromide emissions through use of tarps. http:// frwebgate5. access. gpo. gov/ cgibin waisgate. cgi? WAISdocID= 826484320000+ 6+ 0+ 0& WAISaction= retrieve.

Gan, J. and Yates, S. R. 1998. Ammonium thiosulfate fertilizer reduces methyl bromide emissions from soil. Methyl Bromide Alternatives, USDA, ARS. vol 4 ( 3), July, 1998. http:// www. ars. usda. gov/ is/ np/ mba/ july98/ ammonium. htm Gullino, M. L., Minuto, A., Camponogara, A., Minuto, G., and Garibaldi, A. 2002. soil disinfestations in Italy: status two years before the phase out of methyl bromide. Annual International Research Conference on Methyl Bromide Alternatives ( 2002). http:// mbao. org/

Jackson and Perkins Operations, Inc. 2003. in house trials.

Karlick, J., J. Becker, U. Schuch, G. Browne, 1998, Beyond Methyl Bromide: Development and Implementation of Integrated Bare Root Rose Production Systems.

Larson, K. D. and Shaw, D. V. 2000. Soil fumigation and runner plant production: A synthesis of four years of strawberry nursery field trials. HortScience 35: 642 646.

Martin, F. N. 2003. Development of alternative strategies for management of soilborne pathogens currently controlled with methyl bromide. Annual Review of Phytopathology 41: 325 350.

McKenry, M. V. 2000. Evaluation of alternatives to methyl bromide for soil fumigation at commercial fruit and nut tree nurseries. Contractor for California Association of Nurseryman. Prepared for California Department of Pesticide Regulation. ( See CUE 03 0035 request package of California Fruit and Nut Growers Consortium.)

McKenry, M. 2001. Performance of metam sodium drenched to six different replant sites. Annual International Research Conference on Methyl Bromide Alternatives ( 2001). http:// mbao. org/ U. S. Fruit, Nut, & Flower Nursery Page 48 McKenry, M. V. 1999. The replant problem and its management. Contractor for California Association of Nurseryman. Prepared for California Department of Pesticide Regulation. Catalina Publishing, Fresno, California, USA. ( See CUE 03 0035 request package of California Fruit and Nut Growers Consortium.)

Pizano, M. 2001. Floriculture and the Environment: Growing Flowers without Methyl Bromide, United Nations Environment Programme.

Schneider, S., T. Trout, J. Gerik, and H. Ajwa. 2004. Perennial crop nurseries   performance of methyl bromide alternatives in the field. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions ( 2004). www. mbao. org Schneider, S., E. Rosskopf, J. Leesch, D. Chellemi, C. Bull, and M. Mazzola. 2003a. United States Department of Agriculture   Agricultural Research Service Research on Alternatives to Methyl Bromide: Pre plant and Post harvest, Pest Management Science 59: 814 826.

Schneider, S., T. Trout, J. Gerik, D. Ramming, and H. Ajwa. 2003b. Methyl Bromide Alternatives for Perennial Field Nurseries   1st and 2nd Year Performance, Proceeding from the 2003 Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. www. mbao. org Schneider, S., J. Gerik, Trout, T. 2002a. Evaluation of Alternatives to Methyl Bromide for Roses ( Presentation), USDA ARS Parlier.

Schneider, S., Trout, T., Gerik, J. and Ajwa, H. 2002b. Methyl bromide alternatives for tree, vine, and rose field nurseries. Annual International Research Conference on Methyl Bromide Alternatives ( 2002). http:// mbao. org/

Schneider, S., Ajwa, H., Trout, T., and Sims, J. 2000. Alternatives for vineyard replant and grapevine nurseries. Annual International Research Conference on Methyl Bromide Alternatives ( 2000). http:// mbao. org/

Shaw, D. V. and Larson, K. D. 2000. A meta analysis of strawberry yield response to preplant soil fumigation with combinations of methyl bromide   chloropicrin and four alternative systems.

Trout, T. 2001. Impact of Township Caps on Telone Use in California. ( See CUE 04 0028 request package of California Rose Nurseries.)

Westerdahl, B. B., Buchner, R. P., Loftus, R., and Loftus, T. 2002. Tarped metam sodium for nematode and weed control in nurseries. Annual International Research Conference on Methyl Bromide Alternatives ( 2002). http:// mbao. org/ U. S. Fruit, Nut, & Flower Nursery Page 49 APPENDIX A. 2007 Methyl Bromide Usage Numerical Index ( BUNI).

Methyl Bromide Critical Use Exemption Process 2001 & 2002 Average Requested %

Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha)

10,952 47 235 227 1 280

11,178 48 235 91% 89% 16%

Low EPA High Low High Low High Low High Low High Low High Low HIGH LOW 235 235 0 0 0 0 100 100 0 0 0 0 0 0 100% 100%

280 280 0 0 0 0 100 100 44 31 0 0 0 0 100% 100%

314 314 0 0 0 0 100 100 0 0 0 0 0 0 100% 100%

Strip Bed Treatment Currently Use Alternatives? Research /

Transition Plans Tarps /

Deep Injection Used Pest

free Cert.

Requirement Change from Prior CUE Request (+/) Verified Historic MeBr Use /

State Loss per Hectare (

US$/

ha) Loss per Kilogram of MeBr (

US$/

kg) Loss as a %

of Gross Revenue Loss as a %

of Net Revenue No No Yes Tarp Yes + Yes No Yes Yes Tarp Yes  Yes No No Yes Tarp Yes 0 Yes Conversion Units: 1 Pound = Kilograms Hectare Most Likely Impact Value: High 24% Low 77% not available % of Average Hectares Requested:

11,178 90% Not Available Regional Hectares** Research Amount ( kgs)

1,506 Other Issues MOST LIKELY IMPACT VALUE Regulatory Issues (%) Unsuitable Terrain (%)

Economic Analysis 91%

22% Combined Impacts (%)

Cold Soil Temp (%)

91%

0.453592 1 Acre = 0.404686 Frequency of Treatment 2 3x/ 1yr 3 5x/ 1yr Not included as there is no technically feasible alternative.

Marginal Strategy Quality/ Time/ Market Window/ Yield Loss (%)

Western Raspberry Nursery Consortium CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers 3 5x/ 1yr CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers REGION REGION Western Raspberry Nursery Consortium CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers Other Considerations Adjustments to Requested Amounts REGION Western Raspberry Nursery Consortium CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers Dichotomous Variables ( Y/ N)

Use Rate ( kg/ ha) (%) Karst ( Telone) (%) 100 ft Buffer Zones (%) Key Pest Distribution % Reduction from Initial Request 0% 0% 22% 91%

94,057 11,178 11,178 Nomination Amount 120,094 120,094 94,057 43,998

43,998    16,427 10,952 10,952 22,680    22,453 227 227 53,416  26,037

2007 Request () Double Counting () Growth () Use Rate Adjustment () QPS HIGH LOW 2007 Nomination Options Subtractions from Requested Amounts ( kgs) Combined Impacts Adjustment ( kgs)

437,274 1,374 318 TOTAL OR AVERAGE 120,094 426 282 43,998 134 329 201,678 616 338 99%

642 314 100%

22,680 81 280 208,217 Western Raspberry Nursery Consortium 53,416 212 252 117 235 Kilograms ( kgs) Use Rate ( kg/ ha) Kilograms ( kgs) 27,379 FRUIT, NUT, & FLOWER NURSERY Hectares ( ha) Use Rate ( kg/ ha)

REGION * USEPA has recently been informed that a larger proportion of methyl bromide use falls under QPS therefore EPA has reduced the request to adjust for this new information.

Date: 1/ 28/ 2005 Average Hectares in the US:

2007 Amount of Request 2001 & 2002 Average Use* Quarantine and Pre Shipment Hectares ( ha)

2007 Methyl Bromide Usage Numerical Index ( BUNI) Sector: U. S. Fruit, Nut, & Flower Nursery Page 50 Footnotes for Appendix A: Values may not sum exactly due to rounding. 1. Average Hectares in the US   Average Hectares in the US is the average of 2001 and 2002 total hectares in the US in this crop when available. These figures were obtained from the USDA National Agricultural Statistics Service. 2. % of Average Hectares Requested  Percent (%) of Average Hectares Requested is the total area in the sector's request divided by the Average Hectares in the US. Note, however, that the NASS categories do not always correspond one to one with the sector nominations in the U. S. CUE nomination ( e. g., roma and cherry tomatoes were included in the applicant's request, but were not included in NASS surveys). Values greater than 100 percent are due to the inclusion of these varieties in the U. S. CUE request that were not included in the USDA NASS: nevertheless, these numbers are often instructive in assessing the requested coverage of applications received from growers. 3. 2007 Amount of Request   The 2007 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. 4. 2001 & 2002 Average Use   The 2001 & 2002 Average Use is the average of the 2001 and 2002 historical usage figures provided by the 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. Adjustments are made when necessary due in part to unavailable 2002 estimates in which case only the 2001 average use figure is used. 5. Quarantine and Pre Shipment   Quarantine and pre shipment ( QPS) hectares is the percentage (%) of the applicant's request subject to QPS treatments. 6. Regional Hectares, 2001 & 2002 Average Hectares   Regional Hectares, 2001 & 2002 Average Hectares is the 2001 and 2002 average estimate of hectares within the defined region. These figures are taken from various sources to ensure an accurate estimate. The sources are from the USDA National Agricultural Statistics Service and from other governmental sources such as the Georgia Acreage estimates. 7. Regional Hectares, Requested Acreage %  Regional Hectares, Requested Acreage % is the area in the applicant's request divided by the total area planted in that crop in the region covered by the request as found in the USDA National Agricultural Statistics Service ( NASS). Note, however, that the NASS categories do not always correspond one to one with the sector nominations in the U. S. CUE nomination ( e. g., roma and cherry tomatoes were included in the applicant's request, but were not included in NASS surveys). Values greater than 100 percent are due to the inclusion of these varieties in the U. S. CUE request that were not included in the USDA NASS: nevertheless, these numbers are often instructive in assessing the requested coverage of applications received from growers. 8. 2007 Nomination Options   2007 Nomination Options are the options of the inclusion of various factors used to adjust the initial applicant request into the nomination figure. 9. Subtractions from Requested Amounts   Subtractions from Requested Amounts are the elements that were subtracted from the initial request amount. 10. Subtractions from Requested Amounts, 2007 Request   Subtractions from Requested Amounts, 2007 Request is the starting point for all calculations. This is the amount of the applicant request in kilograms. 11. Subtractions from Requested Amounts, Double Counting  Subtractions from Requested Amounts, Double Counting is the estimate measured in kilograms in situations where an applicant has made a request for a CUE with an individual application while their consortium has also made a request for a CUE on their behalf in the consortium application. In these cases the double counting is removed from the consortium application and the individual application takes precedence. 12. Subtractions from Requested Amounts, Growth or 2002 CUE Comparison  Subtractions from Requested Amounts, Growth or 2002 CUE Comparison is the greatest reduction of the estimate measured in kilograms of either the difference in the amount of methyl bromide requested by the applicant that is greater than that historically used or treated at a higher use rate or the difference in the 2007 request from an applicant's 2002 CUE application compared with the 2007 request from the applicant's 2003 CUE application. 13. Subtractions from Requested Amounts, QPS  Subtractions from Requested Amounts, QPS is the estimate measured in kilograms of the request subject to QPS treatments. This subtraction estimate is calculated as the 2007 Request minus Double Counting, minus Growth or 2002 CUE Comparison then U. S. Fruit, Nut, & Flower Nursery Page 51 multiplied by the percentage subject to QPS treatments. Subtraction from Requested Amounts, QPS = ( 2007 Request   Double Counting   Growth)*( QPS %) 14. Subtraction from Requested Amounts, Use Rate Difference   Subtractions from requested amounts, use rate difference is the estimate measured in kilograms of the lower of the historic use rate or the requested use rate. The subtraction estimate is calculated as the 2007 Request minus Double Counting, minus Growth or 2002 CUE Comparison, minus the QPS amount, if applicable, minus the difference between the requested use rate and the lowest use rate applied to the remaining hectares. 15. Adjustments to Requested Amounts   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. 16. (%) Karst topography   Percent karst topography 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 topography. 17. (%) 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. 18. (%) 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. 19. 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. 20. 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. 21. 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. 22. 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 topography, 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 topography. 23. Qualifying Area  Qualifying area ( ha) is calculated by multiplying the adjusted hectares by the combined impacts. 24. Use Rate  Use rate is the lower of requested use rate for 2007 or the historic average use rate. 25. CUE Nominated amount  CUE nominated amount is calculated by multiplying the qualifying area by the use rate. 26. Percent Reduction  Percent reduction from initial request is the percentage of the initial request that did not qualify for the CUE nomination. 27. Sum of CUE Nominations in Sector  Self explanatory. 28. Total US Sector Nomination  Total U. S. sector nomination is the most likely estimate of the amount needed in that sector. 29. 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. 30. Strip Bed Treatment   Strip bed treatment is ` yes' if the applicant uses such treatment, no otherwise. 31. 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. U. S. Fruit, Nut, & Flower Nursery Page 52 32. Research/ Transition Plans   Research/ Transition Plans is ` yes' when the applicant has indicated that there is research underway to test alternatives or if applicant has a plan to transition to alternatives. 33. 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. 34. Pest free cert. Required  This variable is a ` yes' when the product must be certified as ` pest free' in order to be sold 35. Other Issues. Other issues is a short reminder of other elements of an application that were checked 36. Change from Prior CUE Request This variable takes a `+' if the current request is larger than the previous request, a ` 0' if the current request is equal to the previous request, and a `` if the current request is smaller that the previous request. 37. Verified Historic Use/ State This item indicates whether the amounts requested by administrative area have been compared to records of historic use in that area. 38. 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. 39. Economic Analysis   provides summary economic information for the applications. 40. Loss per Hectare   This measures the total loss per hectare when a specific alternative is used in place of methyl bromide. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 41. Loss per Kilogram of Methyl Bromide   This measures the total loss per kilogram of methyl bromide when it is replaced with an alternative. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 42. Loss as a % of Gross revenue   This measures the loss as a proportion of gross ( total) revenue. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 43. Loss as a % of Net Operating Revenue  This measures loss as a proportion of total revenue minus operating costs. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. This item is also called net cash returns. 44. Quality/ Time/ Market Window/ Yield Loss (%)   When this measure is available it measures the sum of losses including quality losses, non productive time, missed market windows and other yield losses when using the marginal strategy. 45. Marginal Strategy  This is the strategy that a particular methyl bromide user would use if not permitted to use methyl bromide.