METHYL BROMIDE CRITICAL USE NOMINATION FOR PREPLANT SOIL USE FOR STRAWBERRIES GROWN FOR FRUIT IN OPEN FIELDS ON PLASTIC TARPS 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 STRAWBERRIES GROWN FOR FRUIT IN OPEN FIELDS ON PLASTIC TARPS 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.

X Yes

No CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Tina E. Levine, Ph. D. Title: Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs ii U. S. Environmental Protection Agency Mail Code 7503C Washington, DC 20460 U. S. A. Telephone: ( 703) 308 3099 Fax: ( 703) 308 8090 E mail: levine. tina@ 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 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 ___________________ 8 6. Summarize Why Key Alternatives Are Not Feasible______________________________ 9 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 California  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ______________ 13 California  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request______________________________________________ 13 California  11. Characteristics of Cropping System and Climate _____________________ 14 California  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 15 CALIFORNIA  PART C: TECHNICAL VALIDATION ____________________________________ 16 California  13. Reason for Alternatives Not Being Feasible _________________________ 16 California  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide ____________ 18 California  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 19 California  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 20 California  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 21 California  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 22 California  Summary of Technical Feasibility ___________________________________ 22 Eastern US  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _____________ 22 Eastern US  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request______________________________________________ 22 Eastern US  11. Characteristics of Cropping System and Climate ____________________ 23 Eastern US  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 24 EASTERN US  PART C: TECHNICAL VALIDATION____________________________________ 25 Eastern US  13. Reason for Alternatives Not Being Feasible ________________________ 25 Eastern US  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 27 Eastern US  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 28 iv Eastern US  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 Eastern US  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 29 Eastern US  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 29 Eastern US  Summary of Technical Feasibility __________________________________ 29 Florida  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE_________________ 30 Florida  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 30 Florida  11. Characteristics of Cropping System and Climate _______________________ 30 Florida  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested __________________________________ 32 FLORIDA  PART C: TECHNICAL VALIDATION_______________________________________ 33 Florida  13. Reason for Alternatives Not Being Feasible ___________________________ 33 Florida  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _______________ 35 Florida  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 36 Florida  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 ___ 36 Florida  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 37 Florida  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _______________________________________________________ 37 Florida  Summary of Technical Feasibility______________________________________ 37 PART D: EMISSION CONTROL ___________________________________________________ 38 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 38 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 39 PART E: ECONOMIC ASSESSMENT________________________________________________ 40 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 40 22. Gross and Net Revenue___________________________________________________ 41 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 42 Summary of Economic Feasibility _____________________________________________ 43 PART F. FUTURE PLANS _______________________________________________________ 47 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 47 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 51 25. Additional Comments on the Nomination ____________________________________ 54 26. Citations ______________________________________________________________ 56 Citations Reviewed but Not Applicable _________________________________________ 58 v APPENDIX B. SUMMARY OF NEW APPLICANTS ___________ Error! Bookmark not defined.

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 California  Table 8.1: Amount of Methyl Bromide Requested for Critical Use ____________ 11 Eastern US  Table 8.2: Amount of Methyl Bromide Requested for Critical Use ___________ 11 Florida  Table 8.3: Amount of Methyl Bromide Requested for Critical Use ______________ 12 Table A. 2: 2006 Sector Nomination   Strawberries__________________________________ 13 CALIFORNIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE_________________ 13 California  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request__ 13 California  Table 11.1: Characteristics of Cropping System___________________________ 14 California  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 14 California  Table 12.1 Historic Pattern of Use of Methyl Bromide _____________________ 15 CALIFORNIA  PART C: TECHNICAL VALIDATION ______________________________________ 16 California   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 16 California   Table 14.1: Technically Infeasible Alternatives Discussion _________________ 18 California   Table 15.1: Present Registration Status of Alternatives _____________________ 19 California   Table 16.1: Effectiveness of Alternatives   Key Pest 1 _____________________ 20 Table 16.2. Effects of Soil Fumigation with Methyl Bromide/ Chloropicrin ( MB/ CP) vs. Dichloropropene/ Chloropicrin ( DP/ CP) on Yields ( grams/ plant) of Strawberry in 10 Studies _______________________________________________________________________ 21 California   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 21 EASTERN US  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ________________ 22 Eastern US  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request_ 22 Eastern US  Table 11.1: Characteristics of Cropping System__________________________ 23 Eastern US  Table 11.2 Characteristics of Climate and Crop Schedule __________________ 23 Eastern US  Table 12.1 Historic Pattern of Use of Methyl Bromide ____________________ 24 EASTERN US  PART C: TECHNICAL VALIDATION ______________________________________ 25 Eastern US   Table 14.1: Technically Infeasible Alternatives Discussion ________________ 27 Eastern US   Table 15.1: Present Registration Status of Alternatives ____________________ 28 Eastern US   Table C. 1: Alternatives Yield Loss Data Summary _______________________ 28 FLORIDA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________ 30 Florida  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ____ 30 Florida  Table 11.1: Characteristics of Cropping System _____________________________ 30 Florida  Table 11.2 Characteristics of Climate and Crop Schedule _____________________ 31 Florida  Table 12.1 Historic Pattern of Use of Methyl Bromide________________________ 32 FLORIDA  PART C: TECHNICAL VALIDATION _________________________________________ 33 Florida   Table 15.1: Present Registration Status of Alternatives _______________________ 36 Florida   Table C. 1: Alternatives Yield Loss Data Summary __________________________ 36 PART D: EMISSION CONTROL ____________________________________________________ 38 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 38 PART E: ECONOMIC ASSESSMENT _________________________________________________ 40 vi Table 21.1: Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______ 40 Table 22.1: Year 1 Gross and Net Revenue ________________________________________ 41 Table 22.2: Year 2 Gross and Net Revenue ________________________________________ 41 Table 22.3: Year 3 Gross and Net Revenue ________________________________________ 41 California  Table E. 1: Economic Impacts of Methyl Bromide Alternatives _______________ 42 Eastern US  Table E. 2: Economic Impacts of Methyl Bromide Alternatives ______________ 42 Florida  Table E. 3: Economic Impacts of Methyl Bromide Alternatives _________________ 42 PART F. FUTURE PLANS ________________________________________________________ 47 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI)._________________ 60 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 Strawberries Grown for Fruit in Open Fields On Plastic Tarps 3. CROP AND SUMMARY OF CROP SYSTEM This nomination covers methyl bromide use in three major strawberry production areas   California, Florida, and states in the Eastern US ( Alabama, Arkansas, Georgia, Illinois, Kentucky, Louisiana, Maryland, New Jersey, North Carolina, Ohio, South Carolina, Tennessee, West Virginia and Virginia).

California. California produces more than 80 percent of the fresh market and processed strawberries grown in the U. S. California produces about 20 percent of the world's strawberries. Most strawberries exported from California go to Canada, Japan, and Mexico.

California has two distinct strawberry production areas. The southern region produces both fresh ( 63 percent) and processed ( 37 percent) strawberries. The northern region includes both rotated and non rotated strawberry production regimes, with each producing fresh ( 84 percent) and processed ( 16 percent) strawberries. The majority of growers are farming between 4 and 20 hectares of land with strawberry fields in rotation. Because strawberry production in California is concentrated in a small geographic location due to optimal growing conditions, factors that affect this small area can be significant. An example of this, which is discussed later in this chapter, is the regulatory limit on the amount of 1,3 dichloropropene ( Telone) that can be used in each township ( i. e., 36 square mile area, approximately 95 square km) in California.

Depending on the region, California strawberries are planted in the Summer or Fall. Prior to planting, fumigation is typically performed on flat ground over the entire surface of the field. Immediately after fumigation the field is covered with plastic. At the end of the fumigation period, the plastic is removed and planting beds are formed and covered with fresh plastic. Strawberry plants are transplanted about two weeks after fumigation to ensure that no phytotoxic levels of methyl bromide remain. Harvest begins about 2 to 3 months later. At the end of the first harvest, the strawberry plants are removed and the field is readied for the next crop. Rotational crops that are planted after strawberries, and that benefit from the previous use of methyl bromide include broccoli, celery, lettuce, radish, leeks, and artichokes.

Florida. Florida is the second largest strawberry producing state with 12 percent of the total U. S. production. Nearly all of the domestically produced strawberries harvested in the winter are grown in Florida. Page 8 Strawberries are grown as an annual crop in Florida using a raised bed system. Methyl bromide in combination with chloropicrin is applied to the soil during construction of the raised beds approximately two weeks prior to planting transplants. Immediately after application, the bed is covered with plastic mulch. Drip or overhead irrigation is used to help establish plants, irrigate plants, and to protect the plants from frost. Many strawberry growers utilize the beds and drip tubes to grow a second crop, such as cucurbits or solanaceous crops.

Eastern U. S. The Eastern U. S. strawberry industry is highly de centralized and primarily consists of small family farms with several hectares of strawberries that are directly marketed through U pick, ready pick, roadside stands, and farmers markets Strawberry production in the eastern states differs from that in Florida because of soils type ( Florida typically has sandy soils; eastern soils are heavier); topography ( Florida has much karst topography; much less common in other states), climate ( very mild winters in Florida), farm size ( farms are larger in Florida), and marketing practices ( Florida is typically commercial compared to small U pick operations) In the Eastern U. S., the vast majority of the strawberry farms use an annual cropping plasti culture production system where the berries are grown on raised beds similar to Florida strawberry production. Planting time is similar to Florida, but the production peak occurs later in the season, between April and May. About 50 percent of the soils have textures finer than sandy loam. Nutsedge is a primary pest on about 40 percent of the land that typically has coarse textured soils. Some double cropping of beds occurs.

4. METHYL BROMIDE NOMINATED TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG) NOMINATION AREA ( HA) 2006 1,615,339 8,680 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE The US nomination is only for those areas where the alternatives are not suitable. In US strawberry fruit production there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible for use in strawberry fruit production.  geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the US is only nominating a CUE for strawberry fruit where the key pest pressure is moderate to high such as nutsedge in the Southeastern US.  regulatory constraints: e. g., telone use is limited in California due to townships caps and in Florida due to the presence of karst geology.  delay in planting and harvesting: e. g., the plant back interval for telone+ chloropicrin is two weeks longer than methyl bromide+ chloropicrin. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices. Page 9  unsuitable topography: e. g., alternatives that must be applied with drip irrigation may not be suitable in areas with rolling or sloped topography due to uneven distribution of the fumigant.

The United States ( U. S.) nomination for strawberry fruit field is a critical need for an amount of methyl bromide ( MB) in areas with moderate to severe pest pressure, because currently there are no feasible alternatives and farmers would face severe economic hardships in the absence of MB. Where there is moderate to severe pest pressure, the suggested alternatives for strawberry fruit production fail to provide the necessary degree of pest control or their use is not easily adoptable due to state imposed restrictions. The nomination also notes that applying alternatives is further complicated when plant back restrictions prevent farmers from meeting marketing windows ( e. g., winter or early spring) when strawberry sale prices are as much as 100% higher than during the rest of the year ( see Market Window Information). The nomination notes significant progress in adopting emission reduction technologies and changing formulations and application rates to reduce MB dosage rates to some of the lowest in the world, and that further trials are being conducted to evaluate new alternatives, and to test ways of overcoming constraints in further lowering MB formulations and adopting even more impermeable barriers.

TABLE A. 1: EXECUTIVE SUMMARY Region California Eastern US Florida AMOUNT OF NOMINATION 2006 Kilograms 1,086,777 230,332 295,853 Application Rate ( kg/ ha) 196 151 185 Area ( ha) 5,552 1,528 1,600 AMOUNT OF APPLICANT REQUEST 2006 Kilograms 1,632,931 350,534 579,691 Application Rate ( kg/ ha) 202 151 202 Area ( ha) 8,094 2,317 2,873 ECONOMICS FOR NEXT BEST ALTERNATIVE Marginal Strategy 1,3 D+ PIC 1,3 D+ PIC 1,3 D+ PIC Yield Loss (%) 14 14 25 Loss per hectare ( US$/ ha) 11,817 9,319 14,447 Loss per kg Methyl Bromide ( US$/ kg) 58.57 62.05 77.72 Loss as % of Gross Revenue (%) 16 18 20 Loss as % of Net Revenue (%) 87 42 52 6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

Despite use of many alternatives, many of which have already been incorporated into standard strawberry production systems, methyl bromide is believed to be the only currently available treatment that consistently provides reliable control of nutsedge species, nematodes and the disease complex affecting strawberry production. Only acreage with moderate to high pest pressure is included in this nomination. Page 10 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 (%) California 11,109 74 Eastern US Not available Not available Florida 2,873 94 NATIONAL TOTAL*: 19,486 65 * National total includes other regions not requesting methyl bromide.

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.

  California has requested enough methyl bromide to treat about 75 85% of the state's strawberry crop with methyl bromide.

  Southeastern states consortium claims that 90% of the total acreage grown in this area is treated with methyl bromide.

  Total acreage grown is 6900 acres and Florida has requested 7100 acres to be treated with methyl bromide.

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?

California has proposed to rigorously test alternatives and is committed to finding alternatives to methyl bromide. The other regions have not proposed reduction in use, however, these regions use significantly less methyl bromide than does California. Page 11 8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE CALIFORNIA  TABLE 8.1: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: CALIFORNIA California YEAR OF EXEMPTION REQUEST 2006 KILOGRAMS OF METHYL BROMIDE 1,632,931 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Flat Fumigation FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 8,094 APPLICATION RATE* ( KG/ HA) FOR THE ACTIVE INGREDIENT 202 DOSAGE RATE* ( G/ M 2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE * For Flat Fumigation treatment application rate and dosage rate may be the same.

EASTERN US  TABLE 8.2: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: EASTERN UNITED STATES Eastern U. S. YEAR OF EXEMPTION REQUEST 2006 KILOGRAMS OF METHYL BROMIDE 350,534 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 2,317 APPLICATION RATE* ( KG/ HA) FOR THE ACTIVE INGREDIENT 151 DOSAGE RATE* ( G/ M 2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 30.2 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 151 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 15 * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 12 FLORIDA  TABLE 8.3: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: FLORIDA Florida YEAR OF EXEMPTION REQUEST 2006 KILOGRAMS OF METHYL BROMIDE 579,691 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT* Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE** 98: 2 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 2,873 APPLICATION RATE* ( KG/ HA) FOR THE ACTIVE INGREDIENT 202 DOSAGE RATE* ( G/ M 2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 14 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 206 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 142 * Florida states maximum bed width is 3 feet with 10,100 linear bed feet/ acre, which totals 69% of acre treated. ** Florida states that growers use 98: 2 formulation for sting nematode control.

9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION The amount of methyl bromide nominated by the US was calculated as follows:

  The percent of regional hectares in the applicant's request was divided by the total area planted in that crop in the region covered by the request. Values greater than 100 percent are due to the inclusion of additional varieties in the applicant's request that were not included in the USDA National Agricultural Statistics Service surveys of the crop.   Hectares counted in more than one application or rotated within one year of an application to a crop that also uses methyl bromide were subtracted. There was no double counting in this sector.   Growth or increasing production ( the amount of area requested by the applicant that is greater than that historically treated) was subtracted. The three applicants that included growth in their request had the growth amount removed.   Quarantine and pre shipment ( QPS) hectares is the area in the applicant's request subject to QPS treatments. Not applicable in this sector.   Only the acreage experiencing one or more of the following impacts were included in the nominated amount: moderate to heavy key pest pressure, regulatory impacts, karst topography, buffer zones, and unsuitable terrain. Page 13 TABLE A. 2: 2006 SECTOR NOMINATION   STRAWBERRIES*

2006 Strawberries Sector Nomination California Eastern US Florida Requested Hectares ( ha) 8,094 2,317 2,873 Requested Application Rate ( kg/ ha) 202 151 202 Applicant Request for 2006 Requested Kilograms ( kg) 1,632,931 350,534 579,691 Nominated Hectares ( ha) 5,552 1,528 1,600 Nominated Application Rate ( kg/ ha) 196 151 185 CUE Nominated for 2006* Nominated Kilograms ( kg) 1,086,777 230,332 295,853 Overall Reduction (%) 37 2006 U. S. CUE Nomination ( kg) 1,612,962 Research Amount ( kg) 2,377 2006 Sector Nomination Totals Total 2006 U. S. Sector Nominated Kilograms ( kg) 1,615,339 * See Appendix A for complete description of how the nominated amount use calculated.

CALIFORNIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA  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 Diseases: Black root rot ( Rhizoctinia and Pythium spp.), crown rot ( Phytophthora cactorum),

California Nematodes: root knot nematode ( Meloidogyne spp.) Sting nematode ( Belonolaimus spp.)

California Weeds: Yellow nutsedge ( Cyperus esculentus), purple nutsedge ( Cyperus rotundus), ryegrass, and winter annual weeds. At moderate to severe pest pressure only MB can effectively control the target pests found in California. Uses of alternatives are limited by regulatory restrictions such as the township caps on the amount of 1,3 dichloropropene that can be used. MB applications in strawberries are typically made using 67: 33 or, where feasible, 57: 43 mixtures with chloropicrin under plastic mulch. Related dosage rates of 202 kg/ ha are below the threshold in the MBTOC 2002 Report, making further reduction difficult to achieve without compromising pest management. Page 14 CALIFORNIA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE CALIFORNIA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS CALIFORNIA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Fruiting plants grown from transplants ANNUAL OR PERENNIAL CROP: (# of years between replanting) Cultured as annual TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Vegetables ( e. g. broccoli, celery, lettuce, radish, leeks, cauliflower, artichokes) SOIL TYPES: ( Sand, loam, clay, etc.) Light and medium soils FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Yearly OTHER RELEVANT FACTORS: None Identified CALIFORNIA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE JUL AUG SEPT OCT NOV DEC JAN FEB MAR APR MAY JUN CLIMATIC ZONE 9 B RAINFALL ( mm) trace 1.0 trace 0 44.7 56.9 9.9 30.5 16 72.1 17.3 0 OUTSIDE TEMP. ( ° C)* 30.3 27.4 25.1 18.4 13.4 9.6 10.3 10.6 14.4 14.8 20.8 25.7 FUMIGATION SCHEDULE X PLANTING IN NORTH** X X PLANTING IN SOUTH** X * For Fresno, California. ** In Northern California the crop is planted in September/ October and harvested from December through June/ July. In Southern California the crop is planted in the summer, generally in July, and harvested from September thru December. The rotational crop, often celery, is grown from March thru May. Average farm size in this area is about 30 acres, 100% of which is treated. Rotational crops include lettuce, celery, and broccoli. In Northern California planting occurs in October/ November and harvesting occurs from April thru October; average farm size is 60 acres; rotational crops include lettuce, strawberries, broccoli and cauliflower.

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

To the best of our knowledge none of the following characteristics of the cropping system would affect adoption of a relevant alternative. The US believes that the Telone township caps prevent the further adoption of Telone as an alternative. Page 15 CALIFORNIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 6,808 7,401 8,600 8,248 8,456 7,912 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED All Flat Fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 1,833,235 1,928,597 2,264,789 1.919,240 1,611,775 1,592,156 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) Typically 67: 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Shank injected 25 to 30 cm deep APPLICATION RATE OF FORMULATIONS IN kg/ ha* 269 260 275 244 191 201 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 26.9 26 27.5 24.4 19.1 20.1 * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 16 CALIFORNIA  PART C: TECHNICAL VALIDATION CALIFORNIA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA, CALIFORNIA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D Dichloropropene ( 1,3 D, Telone) Used alone, 1,3 Dichloropropene does not adequately control diseases and weeds. Buffer zones of 100 feet are too constraining for small fields. Required Protective equipment ( protective suits) pose a health risk to workers in hot and humid weather. Long pre planting intervals affect cultivar selection, Integrated Pest Management practices, timing of harvest, marketing window options, land leasing decisions and crop rotation schedules. In CA, states regulations require township caps, which limits use of 1,3 Dichloropropene. No Basamid Basamid is not registered in the U. S. for strawberry fruit production. No Chloropicrin Chloropicrin alone is not a technically feasible alternative because it provides poor nematode and weed control, although it provides good disease control No Metam sodium Metam sodium alone is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. Metam sodium suffers from erratic efficacy most likely due to irregular distribution of the product through soil. Metam sodium if not technically feasible in California because it has limited activity against soilborne pathogens in strawberry fields. No Metam sodium, chloropicrin Metam sodium with chloropicrin is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. No Methyl iodide Promising, but it is not currently registered in the U. S. for strawberry fruit production. No Nematicides Addressed individually ( e. g., 1,3 D). No Ozone Ozone is not technically feasible alone because it doesn't control diseases and weeds. No NON CHEMICAL ALTERNATIVES Page 17 Biofumigation Biofumigation is not technically feasible because of the quantity of Brassica crop that would be needed to control target pests in strawberries ( approximately three hectares would be required for every hectare of strawberry production). Incorporation of Brassica at these levels is likely to have allelopathic effects on the target crop. In addition, field trials growing tomatoes in cabbage residue produced inconsistent and inadequate efficacy, and poor yield in two years out of three. No Solarization Solarization, when used alone for pre plant fumigation, is not technically feasible because it does not provide adequate control of a wide range of soil borne diseases and pests. This process is highly weather dependent and works best in combination with IPM for control of pests and diseases. No Steam Although practiced successfully in greenhouse situations, fumigation with steam, when used alone in the field for preplant fumigation, is not operationally practical due to low application speeds and high energy requirements ( 1 3 weeks to treat one hectare). In addition results from field experiments steam treatment have been erratic. No Biological Control Biological control is not technically feasible as a stand alone replacement for methyl bromide because it does not provide adequate control of target pests. No Cover Crops and Mulching Although already in use as part of an Integrated Pest Management Program, cover crops and mulching alone do not provide adequate control of the target pests. No Crop rotation/ fallow Crop rotation is already being used in many strawberry production areas, but does not adequately control the target pests. No Flooding and water management Flooding and water management are not feasible due to limited water resources, uneven topography in California, and in the eastern states by sandy soil types that would not retain the flood for an adequate time to control the pests. No General IPM General IPM is already practiced in strawberry production, but it is not technically feasible as a stand alone replacement for methyl bromide since a combination of IPM methods do not offer adequate pest control by itself. No Grafting/ Resistant rootstock/ plant breeding Grafting/ resistant rootstock/ plant breeding is not being used and it is not technically feasible because grafting is not possible given the physical characteristics of strawberry plants. Breeding for resistance to pathogens is valuable as a long term endeavor and the U. S. continues work in this area. At this point in time, plant breeding has not resulted in a cultivar that is sufficiently resistant to the major target pests. No Organic Amendments/ Compost Organic Amendments/ Compost is already being used in certain regions of the U. S., but is not technically feasible as a standalone replacement for methyl bromide. No Organic production In certain regions of the U. S. some organic production of strawberries occurs. However, as a stand alone replacement for methyl bromide it is not technically feasible because of reduced yields. No Resistant cultivars Resistant cultivars are already being used in certain regions of the U. S., but it is not technically feasible as a stand alone replacement for methyl bromide. No Page 18 Soil less culture Soil less culture is not being used and it is not technically feasible because it requires a complete transformation of the U. S. production system. There are high costs associated with this as compared to current production practices. No Substrates/ Plug plants Substrates/ plant plugs are currently being used but are not technically feasible as a stand alone replacement for methyl bromide. Although plug plants have actually proven to be more vigorous than bare root transplants in research trials, it is not known to what extent pathogens are controlled by this method. Weed control would still be an issue. And adopting this use would also require major retooling of the industry. No Hand weeding Hand weeding not listed as a standard option. Hand weeding strawberries is not a desirable practice for controlling weeds because they cannot be removed without damaging the plastic and thereby reducing its effectiveness in excluding weeds, insects, and pathogens. No COMBINATIONS OF ALTERNATIVES 1,3 Dichloropropene/ Chloropicrin This combination is considered technically feasible as an alternative in certain circumstances. Together they provide good nematicidal and fungicidal capabilities, but would still require a herbicide partner to control weeds. Regulatory restrictions for each of the chemicals may further limit their use. No, in areas with moderate to severe pest infestation and if not allowed by local regulations.

1,3 Dichloropropene/ Chloropicrin and Metam sodium These combinations also provide good nematicidal and fungicidal capabilities, but would still require a herbicide partner to control weeds. No, in areas with moderate to severe pest infestation and if not allowed by local regulations.

Basamid + Chloropicrin Basamid is not registered in the U. S. for strawberry fruit production. No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

CALIFORNIA  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE CALIFORNIA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION 1,3 Dichloropropene Drip application of 1,3 D in California, are less expensive and require smaller buffer zones than broadcast applications, making it the preferred application method for this alternative ( drip, 90%; broadcast, 10%). However, when 1,3 D fumigations by drip are used other production costs are significantly higher due to the need for herbicide applications ( i. e. metam sodium) and hand weeding operations. Recent studies in California found that fruit production costs were 20 212% higher than with methyl bromide/ chloropicrin ( Goldhue), with the smaller cost estimates coming from VIF mulch treatments that are not currently usable due to regulatory and technical issues. Page 19 Chloropicrin Chloropicrin alone is not a technically feasible alternative because it provides poor nematode and weed control, although it provides good disease control Metam sodium Metam sodium alone is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. Metam sodium suffers from erratic efficacy most likely due to irregular distribution of the product through soil. Metam sodium if not technically feasible in California because it has limited activity against soilborne pathogens in strawberry fields.

Sodium azide Does not sterilize ground. Yields equal to untreated.

1,3D/ chloropicrin This combination is considered technically feasible as an alternative in certain circumstances. Together they provide good nematicidal and fungicidal capabilities, but would still require a herbicide partner to control weeds. Regulatory restrictions for each of the chemicals may further limit their use.

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

CALIFORNIA   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:

Basamid Not registered for use in U. S. Y Unknown Methyl Iodide Not registered for use in U. S. Y Unknown Propargyl bromide Registration in US has not yet been requested. N Unknown Sodium azide Registration in US has not yet been requested. N Unknown Page 20 CALIFORNIA   16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED CALIFORNIA   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   KEY PEST 1 YELLOW NUTSEDGE KEY PEST: KEY PEST 1 AVERAGE DISEASE % OR RATING AND YIELDS IN PAST 3~ 5 YEARS METHYL BROMIDE FORMULATIONS AND ALTERNATIVES # OF TRIALS ACTUAL YIELDS ( T/ HA) CITATION MBR: Chloropicrin ( 67: 33) 200 lb Telone: chloropicrin 17.5 gal. drip Chloropicrin EC 100 lb drip Metam sodium 35 gal drip 1 lb/ A 14109 15551 14613 15117 ( N. S.) Ferguson, 2001 MBR: Chloropicrin 390kg/ ha Telone + 35% chloropicrin ( 327 L) Telone + 17% chloropicrin ( 327 L) Metam sodium ( 300L) Metam NA + chloropicrin ( 300L + 170 kg) Solarization ( painted black) 1 of 2 flats/ ha 4131 ( a) 3541 ( ab) 3620 ( ab) 2552 ( bcd) 2199 ( cd) 2710 ( bcd) Locascio, 1999 MBR: Chloropicrin 390kg/ ha Telone + 35% chloropicrin ( 327 L) Telone + 17% chloropicrin ( 327 L) Metam NA + chloropicrin ( 300L + 170 kg) Metam sodium ( 300L) Solarization ( painted black) 2 of 2 flats/ ha 3511 ( ab) 3553 ( ab) 3333 ( ab) 3279 ( ab) 2933 ( bc) 3210 ( b) Locascio, 1999 CALIFORNIA   TABLE 16.2: EFFECTIVENESS OF ALTERNATIVES   MULTIPLE PESTS Page 21 EFFECTS OF SOIL FUMIGATION WITH METHYL BROMIDE/ CHLOROPICRIN ( MB/ CP) VS. DICHLOROPROPENE/ CHLOROPICRIN ( DP/ CP) ON YIELDS ( GRAMS/ PLANT) OF STRAWBERRY IN 10 STUDIES ( FROM SHAW AND LARSON 1999). MB: CP treated DP: CP treated Study No Reps. Mean Yield SD Mean Yield SD Percent Increasez ty py dy 2 6 992 177 856 109 15.9 1.60 0.070 0.93 5 6 1331 40 1046 55 27.2 10.27 < 0.001 5.93 7 5 1096 110 687 62 59.5 6.76 < 0.001 4.28 21 6 886 71 914 48  2.9  0.78 0.727  0.45 31 4 655 65 647 54 1.0 0.15 0.443 0.11 58 6 871 56 836 11 4.3 1.52 0.077 0.88 64 36 1381 146 1180 185 17.0 5.12 < 0.001 1.21 65 10 1742 131 1489 141 17.0 4.16 < 0.001 1.86 66 6 994 88 981 97 1.3 0.37 0.355 0.15 67 4 610 46 591 46 3.2 0.58 0.291 0.41 z Unweighted percent increase in yield for the MB: CP treatment over the DP: CP treatment group. y t is Student's t test value, p is a one tailed probability ( requires P< 0.025 for conventional significance), and d is the standardized effect size. Average Percent Increase across all studies is 14.35%.

CALIFORNIA   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 Dichloropropene/ Chloropicrin Weeds, nematodes and diseases 1% gain to 14% loss 14.4% ( Shaw and Larson, 1999) Chloropicrin/ Metam sodium Multiple pests 6.6 47% 27% Locascio, 1999 Metam sodium Weeds, nematodes and diseases 16% 29.8% 29.8% ( Shaw and Larson, 1999)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 14%

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

Previous research evaluating various chemical alternatives to methyl bromide suggests that the mixture of 1,3 dichloropropene ( Telone) with chloropicrin, coupled with separate, but complementary chloropicrin and herbicide treatments for weed control, has a potential an IPM alternative to methyl bromide to manage soil borne pests and sustain crop yields, but this is only feasible in areas where groundwater concerns could allow the use of Telone. There are no selective herbicides for the control of the wide range of weeds found in strawberries.

Iodomethane plus chloropicrin is a promising alternative. It is actively being researched with promising results and, if registered, would be a viable alternative to methyl bromide, depending on what regulatory restrictions may arise. Page 22 CALIFORNIA  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

For chemical alternatives, see above in section 17. Otherwise no, when strawberries are grown in the field for fruit, the growth habit of strawberries ( producing runners which take root in the soil) does not lend itself to technologies such as soil less systems, plug plants, or containerized plants.

CALIFORNIA  SUMMARY OF TECHNICAL FEASIBILITY Regulatory constraints such as township caps, as well as biological considerations such as heavy pressure from pathogens, nematodes and weeds, increasing nematode damage over time from not using methyl bromide, phytotoxicity, variation in yields, time lost due to delays in planting, and missing early harvest with high strawberry prices contribute to the technical infeasibility of replacing methyl bromide.

The US nomination is only for those areas where the alternatives are not suitable. In US strawberry fruit production there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible for use in strawberry fruit production.  geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the US is only nominating a CUE for strawberry fruit where the key pest pressure is moderate to high..  regulatory constraints: e. g., telone use is limited in California due to township caps.  delay in planting and harvesting: e. g., the plant back interval for telone+ chloropicrin is two weeks longer than methyl bromide+ chloropicrin. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices.  unsuitable topography: e. g., alternatives that must be applied with drip irrigation may not be suitable in areas with rolling or sloped topography due to uneven distribution of the fumigant.

EASTERN US  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE EASTERN US  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST EASTERN US  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 NEEDED Page 23 Diseases: Black Root Rot ( Pythium, Rhizoctonia), Crown rot ( Phytopthora cactorum),

Nematodes: Root knot nematode ( Meloidogyne spp.) Eastern US Weeds: Yellow nutsedge ( Cyperus escultentus) Purple nutsedge ( Cyperus rotundus) Ryegrass ( Lolium spp.) At moderate to severe pest pressure only MB can effectively control the target pests found in the Eastern United States. Related dosage rates of 202 kg/ ha are below the threshold in the MBTOC 2002 Report, making further reduction difficult to achieve without compromising pest management.

EASTERN US  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE EASTERN US  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS EASTERN US CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Fruiting plants grown from transplants. ANNUAL OR PERENNIAL CROP: (# of years between replanting) Cultured as annual. TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Varies SOIL TYPES: ( Sand, loam, clay, etc.) 50% light, 45% medium, 5% heavy FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Yearly OTHER RELEVANT FACTORS: None Identified EASTERN US  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE JUN JUL AUG SEPT OCT NOV DEC JAN FEB MAR APR MAY CLIMATIC ZONE 5b   8b RAINFALL ( mm)* 248.2 trace 158 84.3 121.9 108.7 136.9 36.6 131.3 206 107.7 147.8 OUTSIDE TEMP. ( ° C)* 25.6 27.2 27.5 25.1 20.0 11.4 7.5 6.2 9.7 15.1 17.7 22.9 FUMIGATION SCHEDULE X X PLANTING SCHEDULE X X * Macon, GA EASTERN US   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

To our knowledge the above characteristics would not prevent adoption of any relevant alternative. Page 24 EASTERN US  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED EASTERN US, SOUTHEASTERN UNITED STATES  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 1421 1446 1593 1694 1823 1879 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED All strip/ bed All strip/ bed All strip/ bed All strip/ bed All strip/ bed All strip/ bed AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 312,231 317,918 239,851 254,689 274,405 283,530 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 ( e. g. injected at 25cm depth, hot gas) Pressurized injection at 20 cm depth   two shanks/ bed ( approximately 76 cm wide bed; 25 cm height at crown of bed)

APPLICATION RATE OF FORMULATIONS IN kg/ ha* 220 220 151 150 151 151 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 45 45 45 45 45 45 * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 25 EASTERN US  PART C: TECHNICAL VALIDATION EASTERN US  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE EASTERN US   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D Dichloropropene ( 1,3 D, Telone) Used alone, 1,3 Dichloropropene does not adequately control diseases and weeds. Buffer zones of 100 feet are too constraining for small fields. Required Protective equipment ( protective suits) pose a health risk to workers in hot and humid weather. Long pre planting intervals affect cultivar selection, Integrated Pest Management practices, timing of harvest, marketing window options, land leasing decisions and crop rotation schedules No Basamid Basamid is not registered in the U. S. for strawberry fruit production. No Basamid, Chloropicrin Basamid is not registered in the U. S. for strawberry fruit production. No Chloropicrin Chloropicrin alone is not a technically feasible alternative because it provides poor nematode and weed control, although it provides good disease control No Metam sodium Metam sodium alone is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. No Metam sodium, chloropicrin Metam sodium with chloropicrin is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. No Methyl iodide Promising, but it is not currently registered in the U. S. for strawberry fruit production. No Nematicides Addressed individually. No Ozone Ozone is not technically feasible alone because it doesn't control diseases and weeds. No NON CHEMICAL ALTERNATIVES Page 26 Biofumigation Biofumigation is not technically feasible because of the quantity of Brassica crop that would be needed to control target pests in strawberries ( approximately three hectares would be required for every hectare of strawberry production). Incorporation of Brassica at these levels is likely to have allelopathic effects on the target crop. In addition, field trials of growing tomatoes in cabbage residue produced inconsistent and inadequate efficacy, and poor yield in two years out of three. No Solarization Solarization, when used alone for pre plant fumigation, is not technically feasible because it does not provide adequate control of a wide range of soil borne diseases and pests. This process is highly weather dependent and works best in combination with IPM for control of pests and diseases. However, solarization only suppresses nutsedge at best. ( Chase et. al. 1998. Egley, 1983) No Steam Steam, although successfully used in greenhouse situations, when used alone in the field for pre plant fumigation, is not operationally practical due to low application speeds and high energy requirements ( 1 3 weeks to treat one hectare). In addition results from field experiments steam treatment have been erratic. No Biological Control Biological control is not technically feasible as a stand alone replacement for methyl bromide because it does not provide adequate control of target pests. No Cover Crops and Mulching Although already in use as part of an Integrated Pest Management Program, cover crops and mulching alone do not provide adequate control of the target pests. No Crop rotation/ fallow Crop rotation is already being used in many strawberry production areas, but does not adequately control the target pests. No Flooding and water management Flooding and water management are not feasible due to limited water resources, uneven topography in California, and in the eastern states by sandy soil types that would not retain the flood for an adequate time to control the pests. No General IPM General IPM is already practiced in strawberry production, but it is not technically feasible as a stand alone replacement for methyl bromide since a combination of IPM methods do not offer adequate pest control by itself. No Grafting/ Resistant rootstock/ plant breeding Grafting/ resistant rootstock/ plant breeding is not being used and it is not technically feasible because grafting is not possible given the physical characteristics of strawberry plants. Breeding for resistance to pathogens is valuable as a long term endeavor and the U. S. continues work in this area. At this point in time, plant breeding has not resulted in a cultivar that is sufficiently resistant to the major target pests. No Organic Amendments/ Compost Organic Amendments/ Compost is already being used in certain regions of the U. S., but is not technically feasible as a standalone replacement for methyl bromide. No Organic production In certain regions of the U. S. some organic production of strawberries occurs. However, as a stand alone replacement for methyl bromide it is not technically feasible because of reduced yields. No Resistant cultivars Resistant cultivars are already being used in certain regions of the U. S., but it is not technically feasible as a stand alone replacement for methyl bromide. No Page 27 Soil less culture Soil less culture is not being used and it is not technically feasible because it requires a complete transformation of the U. S. production system. There are high costs associated with this as compared to current production practices. No Substrates/ Plug plants Substrates/ plant plugs are currently being used but are not technically feasible as a stand alone replacement for methyl bromide. Although plug plants have actually proven to be more vigorous than bare root transplants in research trials, it is not known to what extent pathogens are controlled by this method. Weed control would still be an issue. And adopting this use would also require major retooling of the industry. No Hand weeding Hand weeding strawberries is not a desirable practice for controlling nutsedge. Sedges reproduce through below ground tubers or nutlets. When a sedge plant is removed by hand the 10 to 30 tubers, which grow 2 to 30 cm ( 1 to 12 inches) below ground, will rapidly produce new plants. Therefore, had weeding can lead to a rapid 10 to 30 fold increase in weeds. In addition, those sedges that germinate under the plastic mulch cannot be removed by hand without damaging the plastic and reducing its effectiveness in excluding weeds, insects, and pathogens. No COMBINATIONS OF ALTERNATIVES 1,3 Dichloropropene/ Chloropicrin This combination is considered technically feasible as an alternative in certain circumstances where weed pressures are low. Together they provide good nematicidal and fungicidal capabilities, but would still require an herbicide partner to control weeds such as nutsedge. Regulatory restrictions for each of the chemicals may further limit their use. No, in areas with moderate to severe pest infestation and if not allowed by local regulations.

1,3 Dichloropropene/ Chloropicrin and Metam sodium These combinations also provide good nematicidal and fungicidal capabilities, but would still require a herbicide partner ( or hand weeding) to control. No, in areas with moderate to severe pest infestation and if not allowed by local regulations. * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

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

EASTERN US   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Metam sodium This potential alternative has an extended time between application and crop planting ( compared to methyl bromide) and is not very effective on nutsedge. It also can be inconsistent for disease control. chloropicrin The alternative does not give effective control of nutsedge. It also produces objectionable odors ( a serious issue in urban fringe areas where strawberries are grown.) Insufficient root knot nematode control. 1,3 D The alternative does not give effective control of nutsedge. Excessive PPE requirements, and set or buffer space requirements. Page 28 1,3 D, chloropicrin The alternative does not give effective control of nutsedge. Excessive PPE requirements, and set or buffer space requirements. There are occasional phytotoxicity problems associated with this alternative. 1,3 D, chloropicrin, metam sodium The alternative does not give effective control of nutsedge. Excessive PPE requirements, and set or buffer space requirements.

Metam sodium, chloropicrin The alternative does not give effective control of nutsedge.

Nematicides None registered except 1,3 D.

EASTERN US  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES EASTERN US   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:

Basamid Not registered for use in U. S. Y Unknown Methyl Iodide Not registered for use in U. S. Y Unknown Propargyl bromide Registration in US has not yet been requested. N Unknown Sodium azide Registration in US has not yet been requested. N Unknown EASTERN US  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 See California region, Section 16, for discussion of studies of relevant alternatives. EASTERN US   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 Dichloropropene/ Chloropicrin Weeds, nematodes and diseases 1% gain to 14% loss 14.4% ( Shaw and Larson, 1999) Chloropicrin/ Metam sodium Multiple pests 6.6 47% 27% Locascio, 1999 Metam sodium Weeds, nematodes and diseases 16% 29.8% 29.8% ( Shaw and Larson, 1999)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 14% Page 29 EASTERN US  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

Iodomethane plus chloropicrin is the clear alternative. It is actively being researched with promising results and, if registered, would be a viable alternative to methyl bromide.

EASTERN US  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?

For chemical alternatives, see above in section 17. Otherwise, no, the growth habit of strawberries ( producing runners which take root in the soil) does not lend itself to technologies such as soil less systems, plug plants, or containerized plants.

EASTERN US  SUMMARY OF TECHNICAL FEASIBILITY At moderate to severe pest pressure only MB can effectively control the target pests found in the Eastern US. MB applications in strawberries are typically made using 67: 33 or, where feasible, 50: 50 mixtures with chloropicrin under plastic mulch. Related dosage rates of 202 kg/ ha are below the threshold in the MBTOC 2002 Report, making further reduction difficult to achieve without compromising pest management.

The US nomination is only for those areas where the alternatives are not suitable. In US strawberry fruit production there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible for use in strawberry fruit production.  geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the US is only nominating a CUE for strawberry fruit where the key pest pressure is moderate to high such as nutsedge in the Southeastern US.  regulatory constraints: e. g., telone use is limited due to the presence of karst geology.  delay in planting and harvesting: e. g., the plant back interval for telone+ chloropicrin is two weeks longer than methyl bromide+ chloropicrin. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices.  unsuitable topography: e. g., alternatives that must be applied with drip irrigation may not be suitable in areas with rolling or sloped topography due to uneven distribution of the fumigant. Page 30 FLORIDA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE FLORIDA  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST FLORIDA, FLORIDA  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 NEEDED Florida Diseases: Phytophthora, Crown Rot ( P. citricola, P. cactorum)

Florida Nematodes: Sting ( Belonolaimus longicaudatus)

Root knot ( Meloidogyne spp.)

Florida Weeds: Yellow nutsedge ( Cyperus esculentus)

Purple nutsedge ( Cyperus rotundus)

Carolina Geranium ( G. carolinianum)

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

FLORIDA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE FLORIDA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS FLORIDA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplants ANNUAL OR PERENNIAL CROP: (# of years between replanting) Cultured as annual.

TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Cucurbits and peppers SOIL TYPES: ( Sand, loam, clay, etc.) Sandy to loam soil FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Annually OTHER RELEVANT FACTORS: None Identified Page 31 FLORIDA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b 9a 10b RAINFALL ( mm) 65.5 50 72.6 134.1 175.8 193.3 152.7 65 42.7 158.8 62 66.8 OUTSIDE TEMP. ( ° C) 19.4 22.1 25.3 27.6 28.2 28.2 27.3 24.1 19.2 17.3 16 16.9 FUMIGATION SCHEDULE X X PLANTING SCHEDULE X X FLORIDA   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

To our knowledge none of these characteristics would prevent the adoption of relevant alternatives. Page 32 FLORIDA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED FLORIDA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 2469 2509 2509 2509 2630 2792 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED All strip AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 542,315 551,205 464,025 471,282 486,477 516,414 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) Chiseled into soil 30 45 cm below surface of bed APPLICATION RATE OF FORMULATIONS IN kg/ ha* 220 220 185 188 185 185 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 15 15 13 13 13 13 * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 33 FLORIDA  PART C: TECHNICAL VALIDATION FLORIDA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE FLORIDA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D Dichloropropene ( 1,3 D, Telone) Used alone, 1,3 Dichloropropene does not adequately control diseases and weeds. Buffer zones of 100 feet are too constraining for small fields. Required Protective equipment ( protective suits) pose a health risk to workers in hot and humid weather. Long pre planting intervals affect cultivar selection, Integrated Pest Management practices, timing of harvest, marketing window options, land leasing decisions and crop rotation schedules No Basamid Basamid is not registered in the U. S. for strawberry fruit production. No Chloropicrin Chloropicrin alone is not a technically feasible alternative because it provides poor nematode and weed control, although it provides good disease control No Metam sodium Metam sodium alone is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. No Metam sodium, chloropicrin Metam sodium with chloropicrin is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. No Methyl iodide Promising, but it is not currently registered in the U. S. for strawberry fruit production. No Nematicides Addressed individually ( e. g., 1,3 D). No Ozone Ozone is not technically feasible alone because it doesn't control diseases and weeds. No NON CHEMICAL ALTERNATIVES Biofumigation Biofumigation is not technically feasible because of the quantity of Brassica crop that would be needed to control target pests in strawberries ( approximately three hectares would be required for every hectare of strawberry production). Incorporation of Brassica at these levels is likely to have allelopathic effects on the target crop. In addition, filed trials on tomatoes grown in cabbage residue produced inconsistent and inadequate efficacy, and poor yield in two years out of three. No Page 34 Solarization Solarization, when used alone for pre plant fumigation, is not technically feasible because it does not provide adequate control of a wide range of soil borne diseases and pests. This process is highly weather dependent and works best in combination with IPM for control of pests and diseases. However, solarization only suppresses nutsedge at best. ( Chase et. al. 1998. Egley, 1983) No Steam Steam, when used alone for pre plant fumigation, is not operationally practical due to low application speeds and high energy requirements ( 1 3 weeks to treat one hectare). In addition results from field experiments steam treatment have been erratic. No Biological Control Biological control is not technically feasible as a stand alone replacement for methyl bromide because it does not provide adequate control of target pests. No Cover Crops and Mulching Although already in use as part of an Integrated Pest Management Program, cover crops and mulching alone do not provide adequate control of the target pests. No Crop rotation/ fallow Crop rotation is already being used in many strawberry production areas, but does not adequately control the target pests. No Flooding and water management Flooding and water management are not feasible due to limited water resources, uneven topography in Florida, and in the eastern states by sandy soil types that would not retain the flood for an adequate time to control the pests. No General IPM General IPM is already practiced in strawberry production, but it is not technically feasible as a stand alone replacement for methyl bromide since even a combination of IPM methods do not offer adequate pest control by itself. No Grafting/ Resistant rootstock/ plant breeding Grafting/ resistant rootstock/ plant breeding is not being used and it is not technically feasible because grafting is not possible given the physical characteristics of strawberry plants. Breeding for resistance to pathogens is valuable as a long term endeavor and the U. S. continues work in this area. At this point in time, plant breeding has not resulted in a cultivar that is sufficiently resistant to the major target pests. No Organic Amendments/ Compost Organic Amendments/ Compost is already being used in certain regions of the U. S., but is not technically feasible as a standalone replacement for methyl bromide. No Organic production In certain regions of the U. S. some organic production of strawberries occurs. However, as a stand alone replacement for methyl bromide it is not technically feasible because of reduced yields. No Resistant cultivars Resistant cultivars are already being used in certain regions of the U. S., but it is not technically feasible as a stand alone replacement for methyl bromide. No Soil less culture Soil less culture is not being used and it is not technically feasible because it requires a complete transformation of the U. S. production system. There are high costs associated with this as compared to current production practices. No Page 35 Substrates/ Plug plants Substrates/ plant plugs are currently being used but are not technically feasible as a stand alone replacement for methyl bromide. Although plug plants have actually proven to be more vigorous than bare root transplants in research trials, it is not known to what extent pathogens are controlled by this method. Weed control would still be an issue. Adopting this use would also require major retooling of the industry. No Hand weeding Hand weeding strawberries is not a desirable practice for controlling nutsedge. Sedges reproduce through below ground tubers or nutlets. When a sedge plant is removed by hand the 10 to 30 tubers, which grow 2 to 30 cm ( 1 to 12 inches) below ground, will rapidly produce new plants. Therefore, had weeding can lead to a rapid 10 to 30 fold increase in weeds. In addition, those sedges that germinate under the plastic mulch cannot be removed by hand without damaging the plastic and reducing its effectiveness in excluding weeds, insects, and pathogens. No COMBINATIONS OF ALTERNATIVES 1,3 Dichloropropene/ Chloropicrin This combination is considered technically feasible as an alternative in certain circumstances where weed pressure is low. Together they provide good nematicidal and fungicidal capabilities, but would still require a herbicide partner to control weeds such as nutsedge. Regulatory restrictions for each of the chemicals may further limit their use. No, in areas with moderate to severe pest infestation and if not allowed by local regulations.

1,3 Dichloropropene/ Chloropicrin and Metam sodium This combination also provides good nematicidal and fungicidal capabilities, but would still require a herbicide partner ( or hand weeding) to control. No, in areas with moderate to severe pest infestation and if not allowed by local regulations. * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

FLORIDA  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE FLORIDA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION 1,3 Dichloropropene Drip application of 1,3 D in Florida are less expensive and require smaller buffer zones than broadcast applications, making it the preferred application method for this alternative ( drip, 90%; broadcast, 10%). However, when 1,3 D fumigations by drip are used other production cots are significantly higher due to the need for herbicide applications ( i. e. metam sodium) and hand weeding operations. Recent studies in California found that fruit production costs were 20 212% higher than with methyl bromide/ chloropicrin ( Goldhue), with the smaller cost estimates coming from VIF mulch treatments that are not currently usable due to technical issues.

Chloropicrin Chloropicrin alone is not a technically feasible alternative because it provides poor nematode and weed control, although it provides good disease control Page 36 Metam sodium Metam sodium alone is not a technically feasible alternative because it provides unpredictable disease, nematode, and weed control. Metam sodium suffers from erratic efficacy most likely due to irregular distribution of the product through soil. Metam sodium if not technically feasible in California because it has limited activity against soilborne pathogens in strawberry fields.

Sodium azide Does not sterilize ground. Yields equal to untreated.

1,3D/ chloropicrin This combination is considered technically feasible as an alternative in certain circumstances where weed pressure is low. Together they provide good nematicidal and fungicidal capabilities, but would still require a herbicide partner to control weeds such as nutsedge. Regulatory restrictions for each of the chemicals may further limit their use. Not economically feasible.

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

FLORIDA   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:

Basamid Not registered for use in U. S. Y Unknown Methyl Iodide Not registered for use in U. S. Y Unknown Propargyl bromide Registration in US has not yet been requested. N Unknown Sodium azide Registration in US has not yet been requested. N Unknown FLORIDA  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 See California Region, Section 16, for discussion of studies of relevant alternatives. FLORIDA   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 Dichloropropene/ Chloropicrin Weeds, nematodes and diseases 1% gain to 14% loss 14.4% ( Shaw and Larson, 1999) Chloropicrin/ Metam sodium Multiple pests 6.6 47% 27% Locascio, 1999 Metam sodium Weeds, nematodes and diseases 16% 29.8% 29.8% ( Shaw and Larson, 1999)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 25% Page 37 FLORIDA  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE? Previous research evaluating various chemical alternatives to methyl bromide suggests that the mixture of 1,3 dichloropropene ( Telone) with chloropicrin, coupled with separate , but complementary chloropicrin and herbicide treatments for weed control, has a potential an IPM alternative to methyl bromide to manage soil borne pests and sustain crop yields. There are no currently registered herbicides for the control of sedges in strawberries.

Current research priorities include the following:  Continue to identify and further define optimum conditions and procedures required to maximize performance of Telone, chloropicrin, and other fumigant and herbicide products.  Develop a more comprehensive understanding of the possible biologic and economic impacts of implementing the proposed alternatives to methyl bromide in commercial Florida agriculture.  Continue to identify and resolve implementation constraints to methyl bromide alternatives ( i. e., high costs, lower efficacy, increased production or environmental risks, regulatory constraints, and/ or reduced farm profitability) that negatively impact future widespread adoption of such alternatives.  Continue to develop effective multi crop, IPM based systems, including characterization of impacts and residual effects within current double cropping systems.  Maintain technology transfer projects to educate growers to learn how to effectively choose, apply, and incorporate alternative chemical so as to maximize pest control, crop response and to avoid problems of plant phytotoxicity and crop loss.  Continue to evaluate mulch technologies and procedures to minimize emissions of methyl bromide and other soil fumigant compounds from soil.  Continue to identify and evaluate emerging nonchemical alternatives.

FLORIDA   18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?

For chemical alternatives, see above in section 17. Otherwise, no, the growth habit of strawberries ( producing runners which take root in the soil) does not lend itself to technologies such as soil less systems, plug plants, or containerized plants.

FLORIDA SUMMARY OF TECHNICAL FEASIBILITY Karst topography, as well as biological considerations such as heavy pest pressure ( especially with nutsedge), increasing nematode damage over time from not using methyl bromide, phytotoxicity, variation in yields, time lost due to delays in planting, and missing early harvest with high strawberry prices contribute to the technical infeasibility of replacing methyl bromide. Page 38 The US nomination is only for those areas where the alternatives are not suitable. In US strawberry fruit production there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible for use in strawberry fruit production.  geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the US is only nominating a CUE for strawberry fruit where the key pest pressure is moderate to high such as nutsedge in the Southeastern US.  regulatory constraints: e. g., telone use is limited due to the presence of karst geology.  delay in planting and harvesting: e. g., the plant back interval for telone+ chloropicrin is two weeks longer than methyl bromide+ chloropicrin. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices.  unsuitable topography: e. g., alternatives that must be applied with drip irrigation may not be suitable in areas with rolling or sloped topography due to uneven distribution of the fumigant.

PART D: EMISSION CONTROL 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 Page 39 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? Although research appears to be promising, early adoption has come upon serious logistical and practical limitations such as: 1. Unreliable supplies of the VIF film since no US source of VIF film exists ( only European sources); 2. US requires season long UV protection in film vs. Europe's 2 weeks; and 3. Difficulty applying VIF under US production systems without damaging film. Between 1997 and 2000 the US has reduced the use of methyl bromide in strawberries grown for fruit production by 24%. Reduction of MB/ Pic in mixtures, i. e. changes from 67: 33 to 57: 43   this may have some promise, but nutsedge is a primary pest on 40% of the land in Eastern region ( 890 ha), and below 30.2 g/ m2 a. i. dosage, nutsedge cannot be controlled successfully. The US anticipates that the decreasing supply of methyl bromide will motivate growers to try less frequent applications.

WHAT FURTHER USE/ EMISSION REDUCTION STEPS WILL BE TAKEN FOR THE METHYL BROMIDE USED FOR CRITICAL USES? Investigations are going to be initiated in 2004 2005 with VIF in Eastern region ( North Carolina) None identified None identified None identified OTHER MEASURES None identified None identified None identified None identified 20. IF METHYL BROMIDE EMISSION REDUCTION TECHNIQUES ARE NOT BEING USED OR ARE NOT PLANNED FOR THE CIRCUMSTANCES OF THE NOMINATION, STATE REASONS 1. Chloropicrin ( drip AND shank) shows great promise in Eastern Region, but economic feasibility is a concern with Pic. Multiple Field studies and economic evaluation have been conducted by Dr. Frank Louws ( frank_ louws@ ncsu. edu) and Lisa Ferguson ( lisa_ ferguson@ ncsu. edu) Also, the USDA Methyl Bromide Alternatives Research/ Extension interdisciplinary working group at NCSU ( contact Lisa Ferguson) is preparing an important summary of multiple years of alternatives research for several Eastern Region States and a manuscript is now being written by Page 40 Dr. Charles Safley, NCSU, Economist, " O. Sydorovych, C. D. Safley, L. M. Ferguson, F. J. Louws, G. E. Fernandez, and E. B. Poling, Economic Evaluation of the Methyl Bromide Alternatives for the Production of Strawberries in the Southeastern United States 2. VIF OR HIGH BARRIER FILMS   E. B. POLING is initiating work in late summer 2004 with harvest in Spring 2005   reports available in summer 2005. 3. Telone C35/ InLine   extensive work has been conducted with InLine by our interdisciplinary group ( see Word Document attachment), and yields are comparable to MB, but important limitations with use of 1,3 D + Pic in the Eastern Region have already been presented in the Narratives for 2002 and 2003. 4. Iodomethane is an excellent replacement for MB ( it has been tested extensively by NCSU researchers), and if there is EPA registration in late 2004, there could be widespread industry adoption by the 2005 2006 season. Two years of unpublished studies at NCSU ( 2002 2003, 2003 2004) are indicating potential of using relatively low application rates with Iodomethane  the cost savings associated with these lower rates will potentially speed the adoption of Iodomethane in the Eastern Region. Studies in 2004 2005 will be initiated with tank mixes of Methyl Bromide + Iodomethane, to further reduce MB needs in 2005 2006.

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

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 ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Methyl Bromide 100 1,248 1,248 1,248 Chloropicrin+ metam sodium 73 964 964 964 1,3 d chloropicrin 86 1,416 1,416 1,416 Metam Sodium 70 849 849 849 * As percentage of typical or 3 year average yield, compared to methyl bromide. Page 41 22. GROSS AND NET REVENUE TABLE 22.1: YEAR 1 GROSS AND NET REVENUE YEAR 1 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 29,818 $ 5484 Chloropicrin+ metam sodium $ 20,679 $ 1,716 1,3 d chloropicrin $ 24,362 $ 702 Metam Sodium $ 19,829 $ 2,396 TABLE 22.2: YEAR 2 GROSS AND NET REVENUE YEAR 2 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 29,818 $ 5484 Chloropicrin+ metam sodium $ 20,679 $ 1,716 1,3 d chloropicrin $ 24,362 $ 702 Metam Sodium $ 19,829 $ 2,396 TABLE 22.3: YEAR 3 GROSS AND NET REVENUE YEAR 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 29,818 $ 5484 Chloropicrin+ metam sodium $ 20,679 $ 1,716 1,3 d chloropicrin $ 24,362 $ 702 Metam Sodium $ 19,829 $ 2,396 Page 42 MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA METHYL BROMIDE ALTERNATIVE PIC+ MS ALTERNATIVE 1,3 D+ PIC ALTERNATIVE MS YIELD LOSS (%) 0 27% 14% 30%

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

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

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

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

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 52%

EASTERN UNITED STATES  TABLE E. 3: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES EASTERN UNITED STATES METHYL BROMIDE ALTERNATIVE PIC+ MS ALTERNATIVE 1,3 D+ PIC ALTERNATIVE MS YIELD LOSS (%) 0% 27% 14% 30% Page 43 YIELD PER HECTARE 22,417 16,364 19,270 15,692 * PRICE PER UNIT ( US$) 2.59 2.59 2.59 2.59 = GROSS REVENUE PER HECTARE ( US$) 51,892 37,881 44,608 36,324  OPERATING COSTS PER HECTARE ( US$) 29,623 30,555 31,658 30,270 = NET REVENUE PER HECTARE ( US$) 22,269 7,327 12,950 6,054 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 14,942 9,319 16,215 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 99.49 62.05 107.96 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 29% 18% 31%

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

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

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

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

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

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

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

( 4) Loss as a Percentage of Net Operating Revenue. We define net cash revenues as gross Page 44 revenues minus operating costs. This is a very good indicator as to the direct losses of income that may be suffered by the owners or operators of an enterprise. However, operating costs can often be difficult to measure and verify.

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

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

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

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

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

For Florida, three scenarios were compared to the methyl bromide baseline: 1) 1,3 d plus chloropicrin; 2) Iodomethane; and 3) Iodomethane + chloropicrin. Because Iodomethane is not registered, it is not considered a feasible alternative but the analysis is provided for comparative purposes. Page 45 Florida In 2002, Florida had 2,792 hectares ( 6,900 acres) or 100% of harvested area treated with an average of 75 kilograms ( 166 pounds) of methyl bromide per hectare ( acre). The closest chemical alternative to methyl bromide is 1,3 d plus chloropricrin ( as Telone C 35). However, US EPA estimates that approximately 40% of Florida's strawberry growing areas overlay Karst geology, which prohibits the use of 1,3 d because of the potential for groundwater contamination. The use of 1,3 d also requires a 100 foot buffer around inhabited structures. This would reduce the strawberry producing acreage by about 10%. Nematodes and nutsedge are key pests in Florida strawberry controlled with methyl bromide. Chloropicrin is not as effective in controlling weeds as methyl bromide. Using chloropicrin adds to production costs through increased weeding and labor costs ( to search for and pick the fruit).

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

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

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

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

California In California, 1,3 d plus chloropicrin would also be the primary replacement for methyl bromide. California restricts total use of 1,3 d, at the local level ( township cap). Approximately 63 percent of California's strawberry acreage is fumigated with methyl bromide, and 31 percent is Page 46 fumigated with alternatives. Approximately 15 percent of the strawberry acreage is on hillsides with slopes severe enough to make drip irrigation impractical.

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

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

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

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

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

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

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

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

It should be noted that the applicants do not consider any alternative to be feasible and that these Page 47 estimates are an attempt to measure potential impacts.

PART F. FUTURE PLANS 23. WHAT ACTIONS WILL BE TAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS CROP?

The amount of methyl bromide requested for research purposes is considered critical for the development of effective alternatives. Without methyl bromide for use as a standard treatment, the research studies can never address the comparative performance of alternatives. This would be a serious impediment to the development of alternative strategies. The U. S. government estimates that strawberry fruit research will require 2377 kg per year of methyl bromide for 2005 and 2006. This amount of methyl bromide is necessary to conduct research on alternatives and is in addition to the amounts requested in the submitted CUE applications. One example of the research is a field study testing the comparative performance of methyl bromide, host resistance, cultural practices, pest management approaches for control of rootknot nematodes. Another example is a five year field study comparing methyl bromide to 1,3 D combined with biologically based materials including transplant treatments for control of weeds, root knot nematodes and soil borne fungal pathogens.

Research for a methyl bromide alternative for strawberry production continues to be a very active area of research. USDA, University of Florida Institute of Food and Agricultural Sciences, and the Florida Fruit and Vegetable Association are currently conducting research in this area. Over 100 peer reviewed articles have been published to date based on trials conducted by the above groups. Control of nutsedge and winter annual weeds is crucial to successful berry production in Florida. Control of nutsedge is also extremely important to 40 percent of the Eastern strawberry production land where nutsedge is a problem. In the near term, research is needed to find a suitable pre emergent herbicide, or to find ways to get better herbicidal efficacy from currently available fumigants. In the long term, efforts should be continued to find non chemical means to suppress nutsedge damage. Some additional research to fine tune use of alternative fumigants to maximize efficacy and yield is also needed.

Research studies submitted with the critical use exemption request packages include trials conducted to assess the effectiveness of the most likely chemical and non chemical alternatives to methyl bromide, including some potential alternatives that are not currently included in the MBTOC list. Based on preliminary results from research conducted in this area and largely in the area of tomatoes and strawberries, researchers believe that a mix of fumigants together with an herbicide treatment is the best possible alternative to methyl bromide. Combinations of 1,3 dichloropropene/ chloropicrin, and metam sodium/ chloropicrin are being tested for disease and weed control. Future research plans will test combinations of these fumigants with chemicals such as halosulfuron, metolachlor, and sulfentrazone. A program to evaluate host resistance to Phytophthora root and crown rot has been implemented. Growers are starting to deploy lines identified as having both genetic resistance and acceptable horticultural qualities. Page 48 As demonstrated by the chart and description below, U. S. efforts to research alternatives for methyl bromide have been substantial, and they have been growing in size as the phase out has approached. The U. S. is committed to sustaining its research efforts out into the future until technically and economically viable alternatives are found for each and every controlled use of methyl bromide. The U. S. is also committed to continuing to share our research, and enable a global sharing of experience. Toward that end, for the past several years, key U. S. government agencies have collaborated with industry to host an annual conference on alternatives to methyl bromide. This conference, the Methyl Bromide Alternatives Outreach ( MBAO), has become the premier forum for researchers and others to discuss scientific findings and progress in this field.

Methyl Bromide Alternatives Research Funding History Year Amount ( Million)

1993 US$ 7.255 M 1994 US$ 8.453 M 1995 US$ 13.139 M 1996 US$ 13.702 M 1997 US$ 14.580 M 1998 US$ 14.571 M 1999 US$ 14.380 M 2000 US$ 14.855 M 2001 US$ 16.681 M 2002 US$ 17.880 M The numerous methyl bromide alternative research trials that have been produced quantitative yield data are summarized in the table below. This table shows that, even among studies that demonstrate significant yields using the alternatives, there is significant variation in the performance of the alternative. Thus, while a given alternative may perform well in one study, it may also perform below acceptable standards in another study. The standard used to characterize success in the analysis presented here is if the alternative produced crops with at least 95 percent of the yield of the crop with a methyl bromide control. However, in some instances, even a 95 percent yield may involve some profit losses.

Summary of Research Results for Methyl Bromide Alternatives on U. S. Strawberry.

Alternatives Total Number of Studies Number of Studies with Yield at Least 95% of Methyl Bromide Basamid ( Dazomet) and combinations 27 12 Chloropicrin and combinations 58 36 Compost systems 11 6 Enzone 3 0 Metam sodium ( Vapam) and combinations 73 24 Page 49 Organic production 5 1 Ozone 1 1 Solarization and Combinations 22 6 Tarps 3 1 Telone ( 1,3 dichloropropene) and combinations 93 41 Registration While the U. S. government's role to find alternatives is primarily in the research arena, we know that research is only one step in the process. As a consequence, we have also invested significantly in efforts to register alternatives, as well as efforts to support technology transfer and education activities with the private sector.

The U. S. has one of the most rigorous programs for ensuring that new pesticides are safe for both health and the environment. These safeguards, however, come at a cost of both money and time. It can take a new pesticide, or new pesticide use, several years to be registered by the U. S. EPA. This is in addition to the time it takes to perform, draft results, and deliver the very large number of health and safety studies that are required for registration. Few countries, particularly in the developing world, have the resources to conduct and review these studies or the market power to leverage chemical companies to perform and submit the necessary data. Thus, U. S. registration decisions are often the basis for other countries' pesticide regulations, which means that the benefits from assuring human and environmental safety accrue globally.

The U. S. EPA regulates the use of pesticides under two major federal statutes: the Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) and the Federal Food, Drug, and Cosmetic Act ( FFDCA), both significantly amended by the Food Quality Protection Act of 1996 ( FQPA). Under FIFRA, U. S. EPA registers pesticides provided its use does not pose unreasonable adverse effects to humans or the environment. Under FFDCA, the U. S. EPA is responsible for setting tolerances ( maximum permissible residue levels) for any pesticide used on food or animal feed. With the passage of FQPA, the U. S. EPA is required to establish a single, health based standard for pesticides used on food crops and to determine that establishment of a tolerance will result in a " reasonable certainty of no harm" from aggregate exposure to the pesticide.

The process by which U. S. EPA examines the ingredients of a pesticide to determine if they are safe is called the registration process. The U. S. EPA evaluates the pesticide to ensure that it will not have any unreasonable adverse effects on humans, the environment, and non target species. Applicants seeking pesticide registration are required to submit a wide range of health and ecological effects toxicity data, environmental fate, residue chemistry and worker/ bystander exposure data and product chemistry data. A pesticide cannot be legally used in the U. S. if U. S. EPA has not registered it, unless it has an exemption from regulation under FIFRA.

Since 1997, the U. S. EPA has made the registration of alternatives to methyl bromide a high Page 50 registration priority. Because the U. S. EPA currently has more applications for all types of pesticides pending in its review process than resources to evaluate them, U. S. EPA prioritizes the applications in its registration queue. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for the EPA to initiate its review. This review process takes an average of 38 months to complete. Additionally, the registrant ( the pesticide applicant) has, in most cases, spent approximately 7 10 years developing the data necessary to support registration.

As one incentive for the pesticide industry to develop alternatives to methyl bromide, the U. S. EPA has worked to reduce the burdens on data generation, to the extent feasible while still ensuring that the U. S. EPA's registration decisions meet the Federal statutory safety standards. Where appropriate from a scientific standpoint, the U. S. EPA has refined the data requirements for a given pesticide application, allowing a shortening of the research and development process for the methyl bromide alternative. Furthermore, U. S. EPA scientists routinely meet with prospective methyl bromide alternative applicants, counseling them through the preregistration process to increase the probability that the data is done right the first time and rework delays are minimized.

The U. S. EPA has also co chaired the USDA/ EPA Methyl Bromide Alternatives Work Group since 1993 to help coordinate research, development and the registration of viable alternatives. The work group conducted six workshops in Florida and California ( states with the highest use of methyl bromide) with growers and researchers to identify potential alternatives, critical issues, and grower needs covering the major methyl bromide dependent crops and post harvest uses.

This coordination has resulted in key registration issues ( such as worker and bystander exposure through volatilization, township caps, and drinking water concerns) being directly addressed through USDA's Agricultural Research Service's US$ 15 million per year research program conducted at more than 20 field evaluation facilities across the country. Also U. S. EPA's participation in the evaluation of research grant proposals each year for USDA's US$ 2.5 million per year methyl bromide alternatives research has further ensured close coordination between the U. S. government and the research community.

Several additional, promising alternatives are under review at EPA that may be able to be used on strawberries in the future. These include: iodomethane ( methyl iodide) and propargyl bromide, which currently look very promising in field studies. Although iodomethane is chemically similar to methyl bromide, it photodegrades before it reaches the stratosphere, and therefore is not a significant ozone depleter. While iodomethane and propargyl bromide are not currently registered for use as pesticides in the U. S., research on combinations of pesticides with chemicals like methyl iodide are also planned. Some of these trials will incorporate screening of strawberry varieties for tolerance/ resistance to Phytophthora capsici. Again, while these activities appear promising, it must be noted that concerns about toxicity, drinking water contamination, and the release of air pollutants regarding some alternatives presents another difficulty that may restrict use since many of the growing regions are in sensitive areas such as those in close proximity to schools and homes. Ongoing research on Page 51 alternate fumigants is evaluating ways to reduce emission under various application regimes and examining whether commonly used agrochemicals, such as fertilizers and nitrification inhibitors, could be used to rapidly degrade soil fumigants. If registration of iodomethane or propargyl bromide occurs in the near future, commercial availability and costs will be factors that must be taken into consideration.

24. HOW DO YOU PLAN TO MINIMIZE THE USE OF METHYL BROMIDE FOR THE CRITICAL USE IN THE FUTURE?

First, the Eastern region strawberry growers already apply fumigants in the strip/ bed, and this accounts for 50% lower methyl bromide ( MB) use compared to strawberry growing regions ( e. g. CA) using broadcast applications.

Second, in 1999 the industry switched to the 67: 33 formulation from 98: 2, and this is the main factor accounting for the fact that while total plasticulture acreage in our consortium has increased 32 percent since 1997, total methyl bromide usage has decreased from 312,236 kg ( a. i.) in 1997 to 283,535 kg ( a. i.) in 2002.

Third, an extensive number of research and grower trials in the Eastern Region would suggest that further alterations in the MB: pic formulation offers our best near term strategy to achieve significant reductions in MB dependency without creating significant market disruption. Chloropicrin is expected to be a very important part of pest control practices in the Eastern Region when methyl bromide is no longer available. Either alone or in combination with other materials, chloropicrin has performed well in research trials, and two years of recent research has demonstrated very high strawberry yields in plots treated with a stand alone rate of 250 lb/ acre of 96% chloropicrin ( Plymouth, 2000 2001, and 2001 2002). But, this formulation of chloropicrin is also a very objectionable chemical to work with   causing severe eye irritation and potential acute breathing problems. Worker protection standards must be high. Because of very objectionable odor, it may be impractical to use by farmers in this consortium, most of whom have their strawberry pick your owns and ready pick operations on the fringe of urban and suburban populations. Drift could also be a serious problem.

Nonetheless, we wish to achieve further reductions in MB use in areas of the Eastern Region where nutsedge is not a primary pest ( representing about 60% of the industry, or 1333 ha) by actively pursuing a change in formulation to 57: 43 for the non nutsedge areas  this one change can result in a 9% reduction methyl bromide use in 2005 ( Table 2). By 2006, it may be feasible to use 50: 50 mixtures Page 52 with chloropicrin under plastic mulch beds to achieve further reductions   shown in Table 3.

Stepwise Reductions Proposed for the Eastern Region ( January 2004)

Table 1. Base information before implementation of stepwise reductions Eastern Region ( hectares) Year Nutsedge areas = 40% Consortium Non nutsedge areas = 60% of Consortium Total MB a. i. Application rate for the a. i. ( kg/ ha) 2222 2005 134,278 201,418 335,696 151 2317 2006 140,216 210,324 350,841 151 2376 2007 143,936 215,905 359,841 151 Table 2. Reductions for Step 1   With adoption of 57: 43 by non nutsedge group Eastern Region ( hectares) Year Nutsedge areas = 40% Consortium Non nutsedge areas = 60% of Cons. Table 1 MB Kg ( a. i.) Adjusted MB Kg ( a. i.) Ave. Appl. Rate ( kg/ h) 2222 2005 134,278 171,356 335,696 305,634 138 2317 2006 140,216 178,932 350,841 319,148 138 2376 2007 143,936 183,680 359,841 327,616 138 Table 3. Reductions for Step 1   With adoption of 50: 50 by non nutsedge group in 2006 Eastern Region ( hectares) Year Nutsedge areas = 40% Consortium Non nutsedge areas = 60% of Cons. Table 1 MB Kg ( a. i.) Adjusted MB Kg ( a. i.) Ave. Appl. Rate ( kg/ h) 2222 2005 134,278 171,356 335,696 305,634 138 2317 2006 140,216 156,958 350,841 297,174 128 2376 2007 143,936 161,122 359,841 305,058 128 Step 1 ( increasing the percentage of Pic) can occur with the fewest obstacles to implementation, and can potentially reduce MB use by 9% in 2005, 15% in 2006 and 15% in 2007 ( Table 3). It is more difficult to accomplish comparable reductions in MB use for growers in nutsedge regions by formulation changes, as our experience has shown that MB dosages below 30.2 g/ m2 do not provide satisfactory nutsedge control. Therefore, for growers in nutsedge areas, we wish to investigate, in cooperation with VIF or High Barrier film manufacturers, the potential of growers in these areas to cut MB usage by at least 1/ 3rd with these films.

If VIF or High Barrier Research and Extension Demonstrations in High Pressure Nutsedge Areas of the Eastern Region in 2004 2005 and 2005 2006 are successful, there is potential in 2006 and 2007 to significantly reduce methyl bromide use further: the current projected amount of MB a. i. needed in Eastern Region nutsedge areas for 2006 is calculated to be 140,216 kg ( 350,540 x .4), and this research has the potential to lower this region's dependency from 140,216 kg to 93,947 kg ( Table 4). The net effect of implementing steps 1 and 2 on the Eastern Page 53 Region would be a 28.4 % reduction in 2006, and 28.4% reduction in 2007 ( relative to our current request), and a lowering of the average application rate for our region to 108 kg/ ha.

Table 4. Reductions for Step 2   With adoption of High Barrier Films by Nutsedge Eastern Region ( hectares) Year Nutsedge areas = 40% Consortium Non nutsedge areas = 60% of Cons. Table 1 MB Kg ( a. i.) Adjusted MB Kg ( a. i.) Ave. Appl. Rate ( kg/ h) 2222 2005 134,278 171,356 335,696 305,634 138 2317 2006 93,947 156,958 350,841 250,905 108 2376 2007 96,437 161,122 359,841 257,559 108 Page 54 25. ADDITIONAL COMMENTS ON THE NOMINATION?

In summary, a review of the critical use exemption criteria in Decision IX/ 6 demonstrates that the Parties clearly understood the many issues that make methyl bromide distinctly different from the industrial chemicals previously addressed by the Parties under the essential use process. It is now the challenge of the MBTOC, TEAP and the Parties to consider the national submission of critical use nominations in the context of that criteria, and the information requirements established under Decision XIII/ 11.

In accordance with those Decisions, we believe that the U. S. nomination contained in this document provides all of the information that has been requested by the Parties. On the basis of an exhaustive review of a large, multi disciplinary team of sector and general agricultural experts, we have determined that the MBTOC listed potential alternatives for the strawberry sector are not currently technically or economically feasible from the standpoint of U. S. strawberry growers covered by this critical use exemption nomination. Under certain circumstances in the absence of heavy pest pressure and regulatory constraints, 1,3 dichloropropene with chloropicrin, and possibly also with metam sodium, may be economically feasible, and indeed, the U. S. request has been reduced to take into account possible use in areas that may meet such ideal circumstances. However, any of the following factors would or could make the alternatives economically infeasible:

  Regulatory constraints such as township caps, buffer zones, and karst topology,   Heavy pest pressure such as nutsedge,   Increasing nematode damage over time from not using methyl bromide,   Phytotoxicity,   Variation in yields,   Time lost due to delays in planting,   Missing early harvests with high strawberry prices, and   Less vigorous starter plants if strawberry nurseries cannot use methyl bromide.

We have demonstrated that we have and continue to expend significant efforts to find and commercialize alternatives, and that potential alternatives to the use of methyl bromide in strawberries may be on the horizon. The registration process, which is designed to ensure that new pesticides do not pose an unacceptable risk, is long and rigorous. The U. S. need for methyl bromide for strawberries will be maintained for the period being requested.

In addition, significant efforts have been made to reduce the use and emissions of methyl bromide associated with strawberries. It is particularly valuable to note that the strawberry production industry in California has done a good job of integrating more sustainable and environmentally compatible techniques into their current production system. These currently employed strategies include the use of insects for biological control, and many techniques that limit losses to disease including use of crop rotation, alternation of chemicals fungicides to limit resistance buildup, clean tillage, water management and field sanitation. Unfortunately the continued success of their well constructed IPM system is dependent on the use of methyl bromide as a pre plant soil fumigant. Initial reductions in populations of the entire pest complex achieved with methyl bromide make it feasible to use more environmentally sound Page 55 control measures throughout the season to keep reduced pest populations in check. Without a replacement capable of controlling all of the pests that methyl bromide controls, the entire IPM strategy must be reconstructed. Research on alternatives for this commodity has been progressive and productive. There have been promising advances towards the development of alternative fumigants and application methodologies. The regulatory constraints for employment of the currently available alternatives remain as the largest obstacle to their adoption for strawberry production. Page 56 26. CITATIONS California Department of Food and Agriculture. California Agricultural Statistics Service.

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

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

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

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

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

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

Florida Summary of Plant Protection Regulations. Oct. 2002. Florida Department of Agriculture and Consumer Services.

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

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

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

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

Holm, L. G., D. L. Plucknett, J. V. Pancho, and J. P. Herberger. 1977. The world's worst weeds: distribution and biology. Honolulu, HI: University of Hawaii Press, pp. 8 24. Page 57 Locascio S. J., Olson S. M., Chase C. A., Sinclair T. R., Dickson D. W., Mitchell D. J. and Chellemi D. O. 1999. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions.

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

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

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

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

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

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

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

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

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

Webster, T. M., A. S. Casinos, A. W. Johnson, C. C. Dowler, D. R. Sumner, and R. L. Fery. 2001( a). Methyl bromide alternatives in a bell pepper squash rotation. Crop Rotation 20: 605 614 Webster, T. M. and G. E. Macdonald. 2001( b). A survey of weeds in various crops in Georgia. Weed Technol. 15: 771 790. Page 58 CITATIONS REVIEWED BUT NOT APPLICABLE Southeastern Literature Citations Benlioglu S., Boz, O., Yildiz A., Kaskavalci G., Benlioglu, K., 2002. Soil Solarization Options in Aydin Strawberry Without Methyl Bromide. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions.

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