Methyl Bromide Critical Use Nomination for Preplant Soil Use for Fruit,
Nut and Flower Nurseries

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                              CUN:

Nominating Party:	The United States of America

Brief Descriptive Title of Nomination:	Methyl Bromide Critical Use
Nomination for Preplant Soil Use for Fruit, Nut and Flower Nurseries
(Submitted in 2006 for the 2008 Use Season)

Nominating Party Contact Details

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

Title:	International Affairs Officer

Address:	Office of Environmental Policy

	U.S. Department of State

	2201 C Street N.W. Room 4325

	Washington, DC 20520

	U.S.A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail:	  HYPERLINK<EMAIL_ADDRESS><EMAIL_ADDRESS>

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

( Yes                                  ( No

Signature

Name

Date

Title:

Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Acting Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U.S.A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail<EMAIL_ADDRESS>

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

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

Paper Documents:

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

electronic copies of all paper documents:

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

Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125796848"  Part A: Summary
PAGEREF _Toc125796848 \h  8

  HYPERLINK \l "_Toc125796849"  1. Nominating Party	  PAGEREF
_Toc125796849 \h  8

  HYPERLINK \l "_Toc125796850"  2. Descriptive Title of Nomination
PAGEREF _Toc125796850 \h  8

  HYPERLINK \l "_Toc125796851"  3. Crop and Summary of Crop System
PAGEREF _Toc125796851 \h  8

  HYPERLINK \l "_Toc125796852"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125796852 \h  9

  HYPERLINK \l "_Toc125796853"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125796853 \h  9

  HYPERLINK \l "_Toc125796854"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125796854 \h  10

  HYPERLINK \l "_Toc125796855"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125796855 \h  10

  HYPERLINK \l "_Toc125796856"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125796856 \h  11

  HYPERLINK \l "_Toc125796857"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125796857 \h  11

  HYPERLINK \l "_Toc125796858"  Western Raspberry Nurseries - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125796858 \h
11

  HYPERLINK \l "_Toc125796859"  Western Raspberry Nurseries - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125796859 \h  11

  HYPERLINK \l "_Toc125796860"  Western Raspberry Nurseries - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125796860
\h  12

  HYPERLINK \l "_Toc125796861"  Western Raspberry Nurseries. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125796861 \h  14

  HYPERLINK \l "_Toc125796862"  Western Raspberry Nurseries. Part C:
Technical Validation	  PAGEREF _Toc125796862 \h  15

  HYPERLINK \l "_Toc125796863"  Western Raspberry Nurseries. 13. Reason
for Alternatives Not Being Feasible	  PAGEREF _Toc125796863 \h  15

  HYPERLINK \l "_Toc125796864"  Western Raspberry Nurseries. 14. List
and Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:
PAGEREF _Toc125796864 \h  17

  HYPERLINK \l "_Toc125796865"  Western Raspberry Nurseries - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125796865 \h  18

  HYPERLINK \l "_Toc125796866"  Western Raspberry Nurseries - 16. State
Relative Effectiveness of Relevant Alternatives Compared to Methyl
Bromide for the Specific Key Target Pests and Weeds for which It Is
Being Requested	  PAGEREF _Toc125796866 \h  18

  HYPERLINK \l "_Toc125796867"  Western Raspberry Nurseries - 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125796867 \h  20

  HYPERLINK \l "_Toc125796868"  Western Raspberry Nurseries - 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?	  PAGEREF _Toc125796868 \h  20

  HYPERLINK \l "_Toc125796869"  Western Raspberry Nurseries - Summary of
Technical Feasibility	  PAGEREF _Toc125796869 \h  21

  HYPERLINK \l "_Toc125796870"  California Deciduous Fruit & Nut Tree
Growers - Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125796870 \h  21

  HYPERLINK \l "_Toc125796871"  California Deciduous Fruit & Nut Tree
Growers - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request	  PAGEREF _Toc125796871
\h  21

  HYPERLINK \l "_Toc125796872"  California Deciduous Fruit & Nut Tree
Growers - 11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125796872 \h  22

  HYPERLINK \l "_Toc125796873"  California Deciduous Fruit & Nut Tree
Growers - 12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125796873 \h  24

  HYPERLINK \l "_Toc125796874"  California Deciduous Fruit & Nut Tree
Growers - Part C: Technical Validation	  PAGEREF _Toc125796874 \h  25

  HYPERLINK \l "_Toc125796875"  California Deciduous Fruit & Nut Tree
Growers - 13. Reason for Alternatives Not Being Feasible	  PAGEREF
_Toc125796875 \h  25

  HYPERLINK \l "_Toc125796876"  California Deciduous Fruit & Nut Tree
Growers - 14. List and Discuss Why Registered (and Potential) Pesticides
and Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:	  PAGEREF _Toc125796876 \h  27

  HYPERLINK \l "_Toc125796877"  California Deciduous Fruit & Nut Tree
Growers - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives	  PAGEREF _Toc125796877 \h  27

  HYPERLINK \l "_Toc125796878"  California Deciduous Fruit & Nut Tree
Growers - 16. State Relative Effectiveness of Relevant Alternatives
Compared to Methyl Bromide for the Specific Key Target Pests and Weeds
for which It Is Being Requested	  PAGEREF _Toc125796878 \h  27

  HYPERLINK \l "_Toc125796879"  California Deciduous Fruit & Nut Tree
Growers - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?
PAGEREF _Toc125796879 \h  29

  HYPERLINK \l "_Toc125796880"  California Deciduous Fruit & Nut Tree
Growers - 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?	  PAGEREF _Toc125796880 \h  30

  HYPERLINK \l "_Toc125796881"  California Deciduous Fruit & Nut Tree
Growers - Summary of Technical Feasibility	  PAGEREF _Toc125796881 \h
30

  HYPERLINK \l "_Toc125796882"  California Nursery Roses - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125796882 \h  30

  HYPERLINK \l "_Toc125796883"  California Nursery Roses - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125796883 \h  30

  HYPERLINK \l "_Toc125796884"  California Nursery Roses - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125796884
\h  31

  HYPERLINK \l "_Toc125796885"  California Nursery Roses - 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested	  PAGEREF _Toc125796885 \h
32

  HYPERLINK \l "_Toc125796886"  California Nursery Roses - Part C:
Technical Validation	  PAGEREF _Toc125796886 \h  32

  HYPERLINK \l "_Toc125796887"  California Nursery Roses - 13. Reason
for Alternatives Not Being Feasible	  PAGEREF _Toc125796887 \h  32

  HYPERLINK \l "_Toc125796888"  California Nursery Roses - 14. List and
Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:
PAGEREF _Toc125796888 \h  34

  HYPERLINK \l "_Toc125796889"  California Nursery Roses - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125796889 \h  35

  HYPERLINK \l "_Toc125796890"  California Nursery Roses - 16. State
Relative Effectiveness of Relevant Alternatives Compared to Methyl
Bromide for the Specific Key Target Pests and Weeds for which It Is
Being Requested	  PAGEREF _Toc125796890 \h  35

  HYPERLINK \l "_Toc125796891"  California Nursery Roses - 17. Are There
Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125796891 \h  40

  HYPERLINK \l "_Toc125796892"  California Nursery Roses - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?	  PAGEREF _Toc125796892 \h  40

  HYPERLINK \l "_Toc125796893"  California Nursery Roses - Summary of
Technical Feasibility	  PAGEREF _Toc125796893 \h  40

  HYPERLINK \l "_Toc125796894"  Part D: Emission Control	  PAGEREF
_Toc125796894 \h  41

  HYPERLINK \l "_Toc125796895"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use
 PAGEREF _Toc125796895 \h  41

  HYPERLINK \l "_Toc125796896"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125796896 \h  41

  HYPERLINK \l "_Toc125796897"  Part E: Economic Assessment	  PAGEREF
_Toc125796897 \h  42

  HYPERLINK \l "_Toc125796898"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125796898 \h  42

  HYPERLINK \l "_Toc125796899"  22. Gross and Net Revenue	  PAGEREF
_Toc125796899 \h  42

  HYPERLINK \l "_Toc125796900"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125796900 \h  42

  HYPERLINK \l "_Toc125796901"  Summary of Economic Feasibility
PAGEREF _Toc125796901 \h  42

  HYPERLINK \l "_Toc125796902"  Part F. Future Plans	  PAGEREF
_Toc125796902 \h  43

  HYPERLINK \l "_Toc125796903"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125796903 \h  43

  HYPERLINK \l "_Toc125796904"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125796904 \h  44

  HYPERLINK \l "_Toc125796905"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125796905 \h  44

  HYPERLINK \l "_Toc125796906"  26. Citations	  PAGEREF _Toc125796906 \h
 45

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125796907"  Part A:
Summary	  PAGEREF _Toc125796907 \h  8

  HYPERLINK \l "_Toc125796908"  Table 4.1: Methyl Bromide Nominated
PAGEREF _Toc125796908 \h  9

  HYPERLINK \l "_Toc125796909"  Table A.1: Executive Summary	  PAGEREF
_Toc125796909 \h  9

  HYPERLINK \l "_Toc125796910"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125796910 \h  10

  HYPERLINK \l "_Toc125796911"  Table 8.1: Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125796911 \h  11

  HYPERLINK \l "_Toc125796912"  Western Raspberry Nurseries - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125796912 \h
11

  HYPERLINK \l "_Toc125796913"  Western Raspberry Nurseries - Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
PAGEREF _Toc125796913 \h  12

  HYPERLINK \l "_Toc125796914"  Western Raspberry Nurseries. Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125796914 \h  13

  HYPERLINK \l "_Toc125796915"  Western Raspberry Nurseries. Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125796915 \h
13

  HYPERLINK \l "_Toc125796916"  Western Raspberry Nurseries. Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796916 \h  14

  HYPERLINK \l "_Toc125796917"  Western Raspberry Nurseries. Part C:
Technical Validation	  PAGEREF _Toc125796917 \h  15

  HYPERLINK \l "_Toc125796918"  Western Raspberry Nurseries. Table 13.1:
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125796918 \h
15

  HYPERLINK \l "_Toc125796919"  Western Raspberry Nurseries - Table
14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125796919 \h  17

  HYPERLINK \l "_Toc125796920"  Western Raspberry Nurseries – Table
15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125796920 \h  18

  HYPERLINK \l "_Toc125796921"  Western Raspberry Nurseries – Table
16.1: Effectiveness of Alternatives – Diseases	  PAGEREF _Toc125796921
\h  19

  HYPERLINK \l "_Toc125796922"  Western Raspberry Nurseries – Table
C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125796922 \h  19

  HYPERLINK \l "_Toc125796923"  California Deciduous Fruit & Nut Tree
Growers B - Part B: Crop Characteristics and Methyl Bromide Use
PAGEREF _Toc125796923 \h  21

  HYPERLINK \l "_Toc125796924"  California Deciduous Fruit & Nut Tree
Growers - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request	  PAGEREF _Toc125796924 \h  21

  HYPERLINK \l "_Toc125796925"  California Deciduous Fruit & Nut Tree
Growers - Table 11.1: Characteristics of Cropping System	  PAGEREF
_Toc125796925 \h  22

  HYPERLINK \l "_Toc125796926"  California Deciduous Fruit & Nut Tree
Growers - Table 11.2 Characteristics of Climate and Crop Schedule
PAGEREF _Toc125796926 \h  23

  HYPERLINK \l "_Toc125796927"  California Deciduous Fruit & Nut Tree
Growers - Table 12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF
_Toc125796927 \h  24

  HYPERLINK \l "_Toc125796928"  California Deciduous Fruit & Nut Tree
Growers  - Part C: Technical Validation	  PAGEREF _Toc125796928 \h  24

  HYPERLINK \l "_Toc125796929"  California Deciduous Fruit & Nut Tree
Growers – Table 13.1: Reason for Alternatives Not Being Feasible
PAGEREF _Toc125796929 \h  25

  HYPERLINK \l "_Toc125796930"  California Deciduous Fruit & Nut Tree
Growers – Table 14.1: Technically Infeasible Alternatives Discussion
PAGEREF _Toc125796930 \h  26

  HYPERLINK \l "_Toc125796931"  California Deciduous Fruit & Nut Tree
Growers – Table 15.1: Present Registration Status of Alternatives
PAGEREF _Toc125796931 \h  26

  HYPERLINK \l "_Toc125796932"  California Deciduous Fruit & Nut Tree
Growers – Table 16.1: Effectiveness of Alternatives – Nematodes
PAGEREF _Toc125796932 \h  27

  HYPERLINK \l "_Toc125796933"  California Deciduous Fruit & Nut Tree
Growers – Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF
_Toc125796933 \h  28

  HYPERLINK \l "_Toc125796934"  California Nursery Roses  - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125796934 \h  29

  HYPERLINK \l "_Toc125796935"  California Nursery Roses - Table 10.1:
Key Diseases and Weeds and Reason for Methyl Bromide Request	  PAGEREF
_Toc125796935 \h  29

  HYPERLINK \l "_Toc125796936"  California Nursery Roses - Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125796936 \h  30

  HYPERLINK \l "_Toc125796937"  California Nursery Roses - Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125796937 \h
30

  HYPERLINK \l "_Toc125796938"  California Nursery Roses - Table 11.3
One Year Rose Crop Schedule	  PAGEREF _Toc125796938 \h  30

  HYPERLINK \l "_Toc125796939"  California Nursery Roses - Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796939 \h  31

  HYPERLINK \l "_Toc125796940"  California Nursery Roses - Part C:
Technical Validation	  PAGEREF _Toc125796940 \h  31

  HYPERLINK \l "_Toc125796941"  California Nursery Roses – Table 13.1:
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125796941 \h
32

  HYPERLINK \l "_Toc125796942"  California Nursery Roses – Table 14.1:
Technically Infeasible Alternatives Discussion	  PAGEREF _Toc125796942
\h  33

  HYPERLINK \l "_Toc125796943"  California Nursery Roses – Table 15.1:
Present Registration Status of Alternatives	  PAGEREF _Toc125796943 \h
34

  HYPERLINK \l "_Toc125796944"  California Nursery Roses – Table 16.1:
Effectiveness of Alternatives – Nematodes	  PAGEREF _Toc125796944 \h
35

  HYPERLINK \l "_Toc125796945"  California Nursery Roses – Table 16.2:
Effectiveness of Alternatives – Phytophthora	  PAGEREF _Toc125796945
\h  36

  HYPERLINK \l "_Toc125796946"  California Nursery Roses – Table 16.3:
Effectiveness of Alternatives – Stunt Nematode	  PAGEREF _Toc125796946
\h  37

  HYPERLINK \l "_Toc125796947"  California Nursery Roses – Table 16.4:
Effectiveness of Alternatives – Root Knot Nematode	  PAGEREF
_Toc125796947 \h  38

  HYPERLINK \l "_Toc125796948"  California Nursery Roses – Table C.1:
Alternatives Yield Loss Data Summary	  PAGEREF _Toc125796948 \h  38

  HYPERLINK \l "_Toc125796949"  Part D: Emission Control	  PAGEREF
_Toc125796949 \h  40

  HYPERLINK \l "_Toc125796950"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125796950 \h  40

  HYPERLINK \l "_Toc125796951"  Part E: Economic Assessment	  PAGEREF
_Toc125796951 \h  41

  HYPERLINK \l "_Toc125796952"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125796952 \h
 41

  HYPERLINK \l "_Toc125796953"  Part F. Future Plans	  PAGEREF
_Toc125796953 \h  42

  HYPERLINK \l "_Toc125796954"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125796954 \h  46

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

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

The United States of America (U.S.)

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

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Fruit,
Nut and Flower Nurseries (Submitted in 2006 for the 2008 Use Season)

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

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

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

Deciduous tree nurseries range from 15 to over 600 hectares in field
beds.  A typical operation in California ranges between 80 and 120
hectares.  The climate and soil make this region an ideal area for tree
nurseries (as well as a major fruit and nut producing region).  While
some nurseries concentrate on specific tree crops, most nurseries grow
and sell a variety of different trees.  Nursery stock is grown on a
cropping system that includes crop rotation or cover cropping between
tree production cycles; therefore, not all of the nursery area is in
tree production in a given year.  The tree production cycle can be
anywhere from a single year to several years depending on the type of
tree crop being produced.  Nursery production of trees takes from one to
four years in the ground depending on the type being produced.  Almonds
take one year and walnuts take at least two years.  Also, target tree
size determines how long plants are grown in the nursery.  The most
common cycle is for the tree crop to be in the ground for either one or
two years.  A typical nursery cycle starts by digging the current tree
crop (to be sold) then planting a cover crop for one or two years,
followed by replanting with a tree crop.  In order to prepare the ground
for planting, the fields are disked, deep ripped, leveled, and then
fumigated to meet certification standards set by the California
Department of Food and Agriculture (CDFA, 2001).  MeBr is applied by
shank and treated area is usually covered with a high barrier tarp.  The
fumigation is carried out around August and September, and planting
begins in October, and may continue through January.  The deciduous
nurseries are subject to mandates set forth by the CDFA (2001) that
trees must be pest free.  The nomination is for the portion of tree
nurseries in California that are in areas where alternatives are either
unsuitable for meeting certification standards or subject to regulatory
restrictions.

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

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

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

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

2008	51,102	185

* Includes research amount of 1,506 kgs, See Appendix A for complete
description of how the nominated amount was calculated.

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

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

Region	Western Raspberry Nurseries	California Deciduous Fruit & Nut Tree
Growers	California Nursery Roses

Amount of Applicant Request

	2008	Kilograms	37,229	11,289	1,998

Amount of Nomination

	2008	Kilograms	36,309	11,289	1,998

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

Nurseries must provide stock that is pest-free in order to meet state
mandated certification requirements for plant material (CDFA, 2001).
Use of products with 1,3-D can provide an effective alternative to MeBr
for nematode control where allowed by township cap regulation and where
soil type and moisture are acceptable, (e.g., Schneider et al., 2004).
Moisture restrictions for 1,3-D may be more limiting than township caps.
 Nurseries with heavy soils or moisture greater than 12% (especially
common in clay soils at depths of 1 to 1.5 meters) may not receive
certification of nursery stock, because of failure to reduce populations
of nematodes or pathogens.  In these situations MeBr is critical.

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

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

Region where Methyl Bromide use is requested	Total crop area

2001 – 2002 average (ha)	Proportion of total crop area treated with
methyl bromide (%)

Western Raspberry Nurseries	Not available	Not available

California Deciduous Fruit & Nut Tree Growers	Not available	Not
available

California Nursery Roses 	Not available	Not available

National Total:	Not available	Not available

7. (ii) If only part of the crop area is treated with methyl bromide,
indicate the reason why methyl bromide is not used in the other area,
and identify what alternative strategies are used to control the target
pathogens and weeds without methyl bromide there.

Nurseries must provide pathogen- and nematode-free stock.  They rely on
MeBr for certification when 1,3-D is not allowed because of soil or
moisture conditions or township caps.  Some areas with light, sandy
soil-types, appropriate soil moisture, and no legal restrictions should
be able to replace MeBr with 1,3-D alternatives.

7. (iii) Would it be feasible to expand the use of these methods to
cover at least part of the crop that has requested use of methyl
bromide?  What changes would be necessary to enable this?

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

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

Table 8.1.  Amount of Methyl Bromide Requested for Critical Use  TC
"Table 8.1: Amount of Methyl Bromide Requested for Critical Use" \f F \l
"1"

Region: 	Western Raspberry Nurseries	California Deciduous Fruit & Nut
Tree Growers	California Nursery Roses

Year of Exemption Request	2008	2008	2008

Kilograms of Methyl Bromide	37,229	11,289	1,998

Use: Flat Fumigation or Strip/Bed Treatment	Flat Fumigation	Flat
Fumigation	Flat Fumigation

Formulation (ratio of methyl bromide/chloropicrin mixture) to be used
for the CUE	67:33	75:25	98:2

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (ha)	142	35	7

Application rate* (kg/ha) for the Active Ingredient	263	321	309

Dosage rate* (g/m2) of Active Ingredient used to calculate requested
kilograms of methyl bromide	26.3	32.1	30.9

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

The amount of MeBr nominated by the U.S. was calculated as follows:

The percent of regional hectares in the applicant’s request was
divided by the total area planted in that crop in the region covered by
the request.

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

 Growth or increasing production (the amount of area requested by the
applicant that is greater than that historically treated) was
subtracted.

Quarantine and pre-shipment (QPS) hectares is the area in the
applicant’s request subject to QPS treatments.  QPS amount of MeBr is
not included in the nomination.

Only the hectares experiencing one or more of the following impacts were
included in the nominated amount: moderate to heavy key pest pressure,
regulatory impacts, and unsuitable terrain.

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

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

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

Region where methyl bromide use is requested	Key Pests 	Specific reasons
why methyl bromide is needed

Western Raspberry Nurseries	Primarily pathogens: Phytophthora fragariae
var. Rubi (root rot), Verticillium spp. (wilt), others including Pythium
spp., Rhizoctonia spp.	To meet certification requirements for sale of
nursery stock.

Western Raspberry Nurseries 11. (i) Characteristics of Cropping System
and Climate  TC "Western Raspberry Nurseries - 11. Characteristics of
Cropping System and Climate" \f C \l "2"

Raspberry nurseries in the western U.S. provide raspberry stock to most
of the growers in North America.  Raspberry nurseries have a large
impact on raspberry production overall.  USDA organic standards
specifically allow the use of nursery stock propagated using MeBr for
organic production in recognition of the vital role vigorous planting
stock plays in organic and integrated pest management systems.  This
exemplifies that the use of MeBr in propagation nurseries reduces the
need for MB, and other chemical inputs, in fruiting fields.  MeBr use is
concentrated within nurseries having a total area of approximately 200
hectares.

According to this consortium, “…fallow is part of the two-year
cycle.  The production of one acre of raspberry nursery is a 24-month
process.  It begins with land preparation in January of year 1.  A cover
crop is then grown during the winter, spring and early summer of year 1.
 In the summer the cover crop is incorporated into the soil and the land
is prepared for fumigation.  There is a brief fallow period in June of
year 1 prior to fumigation.  The field is fumigated in August of year 1.
 The planting beds are constructed in September of year 1.  These beds
lay “fallow” through the winter, until February of year 2.  The
planted crop will grow until harvest in November and December of year 2.
 Following the harvest we begin another cycle in January.

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

Western Raspberry Nurseries. Table 11.1: Characteristics of Cropping
System  TC "Western Raspberry Nurseries. Table 11.1: Characteristics of
Cropping System" \f F \l "1"

Characteristics	Western Raspberry Nurseries

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Raspberry cane
stock

Annual or Perennial Crop: (# of years between replanting) 	2-3 years

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	1 year in foundation nursery, 1 year in
commercial nursery. The raspberry nursery industry utilizes flat
fumigation techniques similar to that of the strawberry industry.
Raspberry nursery stock are grown using a two year production cycle
beginning with tissue culture and moving to foundation nurseries the
first year.  Winter dormant plants are replanted in commercial nurseries
and harvested after one year.  Ten hectares of plants in a foundation
nursery will serve to plant 100 hectares of a commercial nursery.  A
commercial nursery produces enough plants to provide 1200 hectares of
commercial fields; therefore, pest infestation of nursery plants can
impact significant areas of commercial fields.

Soil Types:  (Sand, loam, clay, etc.)	Typically light or medium

Frequency of methyl bromide Fumigation: 	Once in 2-3 years

Other relevant factors:	None identified

Western Raspberry Nurseries. Table 11.2 Characteristics of Climate and
Crop Schedule  TC "Western Raspberry Nurseries. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone

	USDA zones 8a, 9a, 9b

Rainfall (mm)	16	72.1	17.3	0	trace	1.0	trace	0	44.7	56.9	9.9	30.5

Outside Temp. ((C)	14.4	14.8	20.8	25.7	30.3	27.4	25.1	18.4	13.4	9.6	10.3
10.6

Fumigation Schedule

X

Planting

Schedule

X

*For Fresno, California.

Western Raspberry Nurseries 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?

Soil moisture is an important determinant of capacity of 1,3-D efficacy
(McKenry, 1999).  Moisture above 12% is common below 1 meter depth and
reduction of 1,3-D nematicidal activity results at this moisture level;
this is especially a problem with nurseries with heavier soils.  It is
critical that nurseries control pests in the top 1 meter of soil because
the plant roots extend to this depth.

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

Western Raspberry Nurseries. Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Western Raspberry Nurseries. Table 12.1 Historic
Pattern of Use of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	103	111	103	131	151	134

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Flat Fumigation	Flat Fumigation	Flat Fumigation	Flat
Fumigation	Flat Fumigation	Flat Fumigation

Amount of methyl bromide active ingredient used

(total kilograms)	26,671	26,937	24,188	30,570	37,680	34,937

formulations of methyl bromide

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

Method by which methyl bromide applied )	Shank injected, with tarp	Shank
injected, with tarp	Shank injected, with tarp	Shank injected, with tarp
Shank injected, with tarp	Shank injected, with tarp

Application rate [Active Ingredient] (kg/ha*)	258	242	235	234	249	260

Actual dosage rate of Active Ingredient (g/m2)*	25.7	25.8	24.2	23.5	23.4
25.2

Western Raspberry Nurseries. Part C: Technical Validation  TC "Western
Raspberry Nurseries. Part C: Technical Validation" \f F \l "1"    TC
"Western Raspberry Nurseries. Part C: Technical Validation" \f C \l "1"

Western Raspberry Nurseries 13. Reason for Alternatives Not Being
Feasible  TC "Western Raspberry Nurseries. 13. Reason for Alternatives
Not Being Feasible" \f C \l "2"

Western Raspberry Nurseries. Table 13.1: Reason for Alternatives Not
Being Feasible  TC "Western Raspberry Nurseries. Table 13.1: Reason for
Alternatives Not Being Feasible" \f F \l "1"

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

Chemical Alternatives

Chloropicrin	Not sufficiently effective to meet standards for pest-free
nursery stock	No

1,3-dichloropropene (1,3-D) 	In areas with moisture restrictions (e.g.,
>12% at 1-1.5 meters)  (or under township caps) would not be able to
meet standards for pest-free nursery stock; nurseries with no such
restrictions should be able to use 1,3-D as an alternative	Possibly,
where soil conditions and township caps allow use

Metam-sodium	Not sufficiently effective to meet standards for pest-free
nursery stock	No

Dazomet	As with metam-sodium, would not meet standards for nursery.  The
use of dazomet in combination with 1,3-D was examined in a study
submitted by the applicant.  The study showed that although weed
populations were suppressed, nematode populations were not controlled,
causing stock to be commercially unacceptable.  When dazomet was used in
combination with 1,3-D, nematode populations were 15 times greater when
compared to that of a dual application of 1,3-D.  	No

Non Chemical Alternatives

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

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

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

Nursery managers have observed that when raspberries are grown in pots,
the south, or hot, side of the pot has a reduced or absent root system,
which reduces yield and increases water demands.  Some of the largest
nurseries are located in the eastern San Joaquin Valley of California
where temperatures can reach over 40º C in the summer.  Roots are not
as large or healthy as what is produced in field systems.

	No

Virtually Impermeable Film (VIF)	May have a role in reducing MeBr use
rates while maintaining efficacy due to reduced emissions (Guillino et
al., 2002; Martin, 2003).  Ongoing studies may help assess value of VIF
with MeBr and chemical alternatives (VIF use is restricted in
California).	No

Biofumigation, solarization, steam heat, biological control, cover
crops/mulches, crop rotation, flooding and water management,
grafting/resistant rootstocks, organic amendments, sanitation, and
resistant cultivars	Some of these alternatives are important components
of an IPM system and are currently employed by the industry.  These
practices include field sanitation to reduce inoculum, crop rotation to
reduce hosts, and attempts to breed resistance to pathogens.  However,
these alternatives will not meet requirements of CDFA for nursery stock
certification either individually or in combinations.  Use of flooding
is not practical because of the topographic features of many production
areas and requirements for excessive water use.  The use of steam also
requires large quantities of water and is slow and expensive to perform,
which would impact planting and production intervals for this industry.
Use of solarization is not practical due to the depth of heating
required to eliminate propagules; environmental constraints at high
altitude nurseries, including high winds, are of concern.

	No

Combinations of Alternatives

(1,3-D) + chloropicrin	In areas with moisture restrictions (e.g., >12%
at 1-1.5 meters)  (or under township caps) would not be able to meet
standards for pest-free nursery stock; nurseries with no such
restrictions should be able to use 1,3-D as an alternative	Where soil
conditions and township caps allow use

(1,3-D) + metam-sodium	In areas with moisture restrictions (e.g., >12%
at 1-1.5 meters)  (or under township caps) would not be able to meet
standards for pest-free nursery stock; nurseries with no such
restrictions should be able to use 1,3-D as an alternative  Metam-sodium
may be helpful where weeds are problems.	Where soil conditions and
township caps allow use

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

Western Raspberry Nurseries - Table 14.1: Technically Infeasible
Alternatives Discussion  TC "Western Raspberry Nurseries - Table 14.1:
Technically Infeasible Alternatives Discussion" \f F \l "1"

Name of Alternative	Discussion

As listed in Table 13.1	As listed in Table 13.1

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

Western Raspberry Nurseries. Table 15.1: Present Registration Status of
Alternatives  TC "Western Raspberry Nurseries – Table 15.1: Present
Registration Status of Alternatives" \f F \l "1"

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

Sodium azide	No registration has been requested	No	Unknown

Propargyl bromide	No registration has been requested	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

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

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

As with other nursery commodities, yield is not the only (and possibly
not the most important) factor in the production of raspberry nursery
stock.  What is of primary importance is pest-free stock that is of
sufficient quality to meet government standards and comply with
standards for intra- and interstate plant transit.  Consequently, for
nurseries restricted in the use of 1,3-D, there is a critical need for
MeBr for the 2008 use season.

Western Raspberry Nurseries. Table 16.1: Effectiveness of Alternatives
– Diseases  TC "Western Raspberry Nurseries – Table 16.1:
Effectiveness of Alternatives – Diseases" \f F \l "1"

Key Pest: Diseases	Average disease % or rating and yields in past 3~5
years

Methyl Bromide formulations and Alternatives 	# of Trials	Disease (% or
rating)	# of Trials	Actual Yields (t/ha)	Citation

[1] MB (263 kg/ha) + chloropicrin (129 kg/ha)

[2] chloropicrin (140 kg/ha)

[3] no fumigation

No pests identified

12 reps	Runners/mother plant (strawberry)

[1] 18.0a

[2] 15.7b

[3] 7.9c	Larson and Shaw, 2000

[1] MB (314 kg/ha) + chloropicrin (78 kg/ha)

[2] chloropicrin (191 kg/ha)

[3] chloropicrin (303 kg/ha)

[4] no fumigation

No pests identified

4 reps	Runners/mother plant (strawberry)

[1] 29.7a

[2] 27.0a

[3] 29.7a

[4] 11.2b	Larson and Shaw, 2000

[1] MB (263 kg/ha) + chloropicrin (129 kg/ha)

[2] chloropicrin (157 kg/ha)

[3] chloropicrin (314 kg/ha)

[4] no fumigation

No pests identified

24 reps	Runners/mother plant (strawberry)

[1] 18.8a

[2] 16.7b

[3] 18.9a

[4] 10.3c	Larson and Shaw, 2000

[1] MB (263 kg/ha) + chloropicrin (129 kg/ha) [tarped, noble plow]

[2] chloropicrin (168 kg/ha)

[3] chloropicrin (336 kg/ha)

[4] 1,3-D (134 kg/ha) + chloropicrin (314 kg/ha)

[5] 1,3-D (361 kg/ha) + chloropicrin (155 kg/ha)

[6] no fumigation

No pests identified

12 reps (MB trt, 11 reps)	Runners/mother plant (strawberry)

[1] 39.2a

[2] 28.6bc

[3] 33.8abc

[4] 35.8ab

[5] 33.0bc

[6] 15.8d	Larson and Shaw, 2000

N.B.: some studies were with strawberry research, a crop with similar
pest problems and because of the large size of the industry, a greater
resource for research data.

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

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

1,3-D (225 kg/ha)+ chloropicrin (123 kg/ha)	(fungal) pathogens

(strawberry nursery)

2-15% (ref.: CDFA, 2001; Gullino et al., 2002)

14%

Chloropicrin (300 kg/ha)	(fungal) pathogens

(strawberry nursery)

5-16% (ref.: CDFA, 2001; Gullino et al., 2002)

9%

Metam-sodium (350 kg/ha)	(fungal) pathogens

(strawberry nursery)

13-57% (Gullino et al., 2002)

30%

Overall Loss Estimate for All Alternatives to Pests	9% plus
certification issues

More important than yield for raspberry nurseries, as well as other
nurseries, is their dependence on certification of stock as
‘pest-free’ in order to meet state requirements to sell to
commercial outlets.

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

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

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

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

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

Western Raspberry Nurseries Summary of Technical Feasibility  TC
"Western Raspberry Nurseries - Summary of Technical Feasibility" \f C \l
"2"

The raspberry nursery industry faces the same problems that other
nurseries face in their need to produce nearly pest-free plant stock to
their respective growers.  Quality of stock plants may have a greater
place in the requirements of the nursery managers than quantity since
there can be an exponential increase in pest pressure when infested
nursery stock is transferred to production fields.  Therefore, the
threshold for nurseries to manage pest problems is higher than might be
for field production and critical need for effective pest management
tools is paramount.  Because locations of nurseries vary and soil,
climate, and water situations are variable, alternatives such as 1,3-D,
may be acceptable substitutes for MeBr under some conditions.  Results
of meta-analyses (Larson and Shaw, 2000; Shaw and Larson, 2000) of
numerous research studies indicate that for the nurseries unable to use
1,3-D, other alternatives are not sufficiently effective to meet their
production needs.

California Deciduous Fruit & Nut Tree Growers - Part B: Crop
Characteristics and Methyl Bromide Use  TC "California Deciduous Fruit &
Nut Tree Growers B - Part B: Crop Characteristics and Methyl Bromide
Use" \f F \l "1"    TC "California Deciduous Fruit & Nut Tree Growers -
Part B: Crop Characteristics and Methyl Bromide Use" \f C \l "1"

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

California Deciduous Fruit & Nut Tree Growers. Table 10.1: Key Diseases
and Weeds and Reason for Methyl Bromide Request  TC "California
Deciduous Fruit & Nut Tree Growers - Table 10.1: Key Diseases and Weeds
and Reason for Methyl Bromide Request" \f F \l "1"

Region where methyl bromide use is requested	Key pests 	Specific reasons
why methyl bromide is needed

California Deciduous Fruit & Nut Tree Growers	Nuts:
Nematodes—Pratylenchus vulnus (root lesion), Meloidogyne spp. (root
knot), Helicotylenchus dihystera (spiral), Xiphinema americanum
(dagger).

Stone Fruit: Nematodes—Helicotylenchus dihystera (spiral), Tylenchus
mexicanus (Tylenchus), Tylenchorhynchus spp. (stunt), Trichodorus spp.
(stubby root)

	Nurseries providing stock for orchards are required to provide the
stock that is pest-free (and particularly nematode-free).  1,3-D is an
effective nematicide, but its use is restricted in California.
Compounds producing methyl isothiocyanate (MITC) have been tested as
possible alternatives (e.g., metam-sodium and dazomet) but nematode
control was not sufficient to meet certification requirements.

The goal in the orchard nursery industry is 99.9% control when sampled
within 30-60 days after treatment, so certification can be met when
stock is harvested 18 months later (McKenry, 2000).  Generally, less
than 98% control in the 30-60 day sampling period will yield
unacceptable stock plants.  Field moisture is a carefully monitored
factor.  A site (e.g., walnut nursery in Davis, California) with silty
clay loam over sandy loam or clay loam has moisture differential with
the lighter textured soils holding more moisture (>12%), which can
impede distribution of an alternative such as 1,3-D (McKenry, 2000) and
make it ineffective.  In California deciduous tree nurseries,
approximately 30% have silt or clay loam soils requiring MB.  The
remaining 70% have sand or sandy loam soils.  Approximately one half of
these areas have a critical need for MeBr due to moisture requirements.
According to the applicant, approximately 65% of nursery soils in
California have a critical need for MB.  Township caps for 1,3-D may
further limit the use of the best alternative.

California Deciduous Fruit & Nut Tree Growers - 11. (i) Characteristics
of Cropping System and Climate  TC "California Deciduous Fruit & Nut
Tree Growers - 11. Characteristics of Cropping System and Climate" \f C
\l "2"

Deciduous tree nurseries range from 15 to over 600 hectares.  The median
operation in California ranges between 80 and 120 hectares.  While some
nurseries concentrate on specific tree crops, most nurseries grow and
sell a variety of different trees.  Nursery stock is grown on a cropping
system that includes crop rotation or cover cropping between tree
production cycles; therefore, not all of the nursery land is in
production in a given year.

California Deciduous Fruit & Nut Tree Growers - Table 11.1:
Characteristics of Cropping System  TC " California Deciduous Fruit &
Nut Tree Growers - Table 11.1: Characteristics of Cropping System" \f F
\l "1"

Characteristics	California Deciduous Fruit & Nut Tree Growers

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Nursery tree
stock

Annual or Perennial Crop: (# of years between replanting) 	Perennial (1
to 2 years in nursery)

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	The tree production cycle can be anywhere from
1 year to several years depending on the type of tree crop.  Nursery
production of trees takes from 1-4 years.  Almonds take one year,
walnuts take at least two years.  Also, desired tree size determines how
long it is grown in the nursery.  A typical cycle is for the tree crop
to be in the ground for either 1 or 2 years.  A typical nursery cycle
starts by digging the current tree crop (to be sold) then planting a
cover crop for 1 or 2 years, followed by replanting with a tree crop.
Fields are disked, deep ripped, leveled, and then fumigated to meet
certification standards set by the California Department of Food and
Agriculture (CDFA, 2001).  A shank is used to apply a fumigation of 75%
MeBr and 25% chloropicrin, typically at a rate of 340 kg per hectare.
The treated area is covered with a high barrier tarp.  The fumigation is
carried out around August and September, and planting begins in October,
and may continue through January.  The deciduous nurseries are subject
to mandates set forth by the CDFA, that trees must be pest-free.

Soil Types:  (Sand, loam, clay, etc.)	Mostly sandy loam (also sandy clay
loam, sandy loam, silt loam, clay loam); light soils (20%), medium
(50%), heavy (30%)

Frequency of methyl bromide Fumigation: (e.g. every two years)	Typically
once in 3-5 years, depending on crop

Other relevant factors:	Nursery stock is inspected by county
agricultural commissioners through the California Department of Food and
Agriculture (CDFA).  Stock must be “found free of especially injurious
pests and disease symptoms” to qualify for the CDFA Nursery Stock
Certificate for Interstate and Intrastate Shipments (CDFA, 2001).  1,3-D
is a legally acceptable treatment where township restrictions and
physical limitations (e.g., moisture greater than 12% in many soils
reduces efficacy of 1,3-D) do not prevent its use.

California Deciduous Fruit & Nut Tree Growers - Table 11.2
Characteristics of Climate and Crop Schedule  TC " California Deciduous
Fruit & Nut Tree Growers - Table 11.2 Characteristics of Climate and
Crop Schedule" \f F \l "1"

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

Climatic Zone

 	USDA zones 8a, 9a, 9b

Rainfall (mm)	16	72.1	17.3	0	trace	1.0	trace	0	44.7	56.9	9.9	30.5

Outside Temp. ((C)	14.4	14.8	20.8	25.7	30.3	27.4	25.1	18.4	13.4	9.6	10.3
10.6

Fumigation Schedule

X	X

	Planting

Schedule

X	X	X	X

	*For Fresno, California.

California Deciduous Fruit & Nut Tree Growers - 11. (ii) Indicate if any
of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?

Soil moisture content of greater than 12% reduces efficacy of 1,3-D.
Soils that are so dry are unusual at 1.5 meters (the depth required to
be nematode-free) (CDFA, 2001) especially with moderate to heavy
subsoils.  Approximately 65% of nurseries require MeBr to meet
certification requirements (especially in wet years).  Areas with light
soils and dry conditions generally have good results from 1,3-D (where
township caps allow its use) and combinations with chloropicrin and/or
metam-sodium. (See Section 10, above.)

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

Approximately 30% of nursery soils are clay or silt loam and require MB,
while one half of the remaining sand or sandy loam soils do not meet the
moisture requirements of less than 12% for use of 1,3-D.  Therefore,
approximately 65% of the nurseries have a critical need for MB.  MB,
1,3-D and some solarization treatments are the only approved fumigants
for treatment of nematodes in nurseries to meet California Department of
Food and Agriculture standards.  However, MeBr is critical to the
production of nematode-free stock where 1,3-D is not feasible (estimated
by industry as approximately 65% of the area) because of incompatible
soil moisture or soil type, or township cap limitations.

California Deciduous Fruit & Nut Tree Growers - Table 12.1 Historic
Pattern of Use of Methyl Bromide  TC " California Deciduous Fruit & Nut
Tree Growers - Table 12.1 Historic Pattern of Use of Methyl Bromide" \f
F \l "1"

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

Area Treated (hectares)	632	639	633	651	630	442

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Flat Fumigation	Flat Fumigation	Flat Fumigation	Flat
Fumigation	Flat Fumigation	Flat Fumigation

Amount of methyl bromide active ingredient used

(total kg)	222,433	207,755	194,965	208,391	201,309	141,111

formulations of methyl bromide)	75:25	75:25	75:25	75:25	75:25	Unknown

Method by which methyl bromide applied )	Shank injected with tarp	Shank
injected with tarp	Shank injected with tarp	Shank injected with tarp
Shank injected with tarp	Shank injected with tarp

Application rate [Active Ingredient] (kg/ha*)	352	325	308	320	319	319

Actual dosage rate of Active Ingredient (g/m2)*	35.2	32.5	30.8	32.0	31.9
31.9

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

California Deciduous Fruit & Nut Tree Growers. Part C: Technical
Validation  TC " California Deciduous Fruit & Nut Tree Growers  - Part
C: Technical Validation" \f F \l "1"    TC " California Deciduous Fruit
& Nut Tree Growers - Part C: Technical Validation" \f C \l "1"

California Deciduous Fruit & Nut Tree Growers - 13. Reason for
Alternatives Not Being Feasible  TC " California Deciduous Fruit & Nut
Tree Growers - 13. Reason for Alternatives Not Being Feasible" \f C \l
"2"

California Deciduous Fruit & Nut Tree Growers. Table 13.1: Reason for
Alternatives Not Being Feasible  TC " California Deciduous Fruit & Nut
Tree Growers – Table 13.1: Reason for Alternatives Not Being Feasible"
\f F \l "1"

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

Chemical Alternatives

Dazomet, metam-sodium	Not effective nematicides.  The use of dazomet in
combination with 1,3-D was examined in a study submitted by the
applicant.  The study showed that although weed populations were
suppressed, nematode populations were not controlled, causing stock to
be commercially unacceptable.  When dazomet was used in combination with
1,3-D, nematode populations were 15 times greater when compared to that
of a dual application of 1,3-D.  	No

Non Chemical Alternatives  standard nursery practices seek to reduce
pest problems with general ipm programs.  However, for this sector
non-chemical alternatives are not feasible because of california
certification requirements for nematode-free plant stock and township
caps and buffer zone restrictions.

Virtually Impermeable Film (VIF)	May have a role in reducing fumigant
use rates while maintaining efficacy (Gullino et al., 2002; Martin,
2003).  Studies are being conducted to assess film with MeBr and
chemical alternatives, although there are legal restrictions to use of
VIF in California.	No

Biofumigation, solarization, steam heat, biological control, cover
crops/mulches, crop rotation, flooding and water management,
grafting/resistant rootstocks, organic amendments, sanitation, and
resistant cultivars.	Some of these alternatives are important components
of an IPM system and are currently employed by the industry.  These
practices include field sanitation to reduce inoculum, crop rotation to
reduce hosts, and attempts to breed resistance to pathogens.  However,
these alternatives will not meet requirements of CDFA for nursery stock
certification either individually or in combinations.  Use of flooding
is not practical because of the topographic features of many production
areas and requirements for excessive water use.  The use of steam also
requires extremely large quantities of water and is very slow and
expensive to perform which would impact planting and production
intervals for this industry.  Use of solarization is not practical due
to the depth of heating required to eliminate viable weed seed and
environmental constraints at high altitude nurseries including high
winds.

	No

Combinations of Alternatives

1,3-D + chloropicrin	In nominated areas, especially those with moderate
to heavy soils or subsoils, moisture at depths of 1.5 meters (depth
required for nematode-free certification) (CDFA, 2001) is usually >12%,
which significantly reduces efficacy of 1,3-D.  This situation might
occur in 65% of affected soils.  Research trials indicate that these
alternatives can be effective in nematode control (e.g., Schneider et
al., 2002b, 2004; Westerdahl et al., 2002). For areas unable to use
1,3-D, there is a critical need for MeBr for 2008.  According to one
calculation (Martin et al., 2003), overall in California 33% of the area
previously fumigated with MeBr could not be treated with 1,3-D due to
current township caps, regardless of efficacy.	No

1,3-D + chloropicrin + metam-sodium

No

1,3-D + metam-sodium

No

1,3-D + dazomet

No

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

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

California Deciduous Fruit & Nut Tree Growers - Table 14.1: Technically
Infeasible Alternatives Discussion  TC " California Deciduous Fruit &
Nut Tree Growers – Table 14.1: Technically Infeasible Alternatives
Discussion" \f F \l "1"

Name of Alternative	Discussion

Discussed in Section 13	Discussed in Section 13

California Deciduous Fruit & Nut Tree Growers - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives  TC " California Deciduous Fruit & Nut Tree Growers - 15.
List Present (and Possible Future) Registration Status of Any Current
and Potential Alternatives" \f C \l "2"  :

California Deciduous Fruit & Nut Tree Growers - Table 15.1: Present
Registration Status of Alternatives  TC " California Deciduous Fruit &
Nut Tree Growers – Table 15.1: Present Registration Status of
Alternatives" \f F \l "1"

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

Sodium azide	No registration has been requested	No	Unknown

Propargyl bromide	No registration has been requested	No	Unknown

Iodomethane	Not registered in U.S.	Yes	Unknown

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

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

California Deciduous Fruit & Nut Tree Growers. Table 16.1: Effectiveness
of Alternatives – nematodes.  TC " California Deciduous Fruit & Nut
Tree Growers – Table 16.1: Effectiveness of Alternatives –
Nematodes" \f F \l "1"

Key Pest: Nematodes

Methyl Bromide formulations and Alternatives	# of Trials	Disease (% or
rating)	Citation

[1] untreated

[2] MB (568 kg/ha) [Tarped]

[3] 1,3-D (272 kg/ha) + chloropicrin (155 kg/ha) [Telone 35, Untarped]

[4] 1,3-D (312 kg/ha) + chloropicrin (177 kg/ha) [Telone 35, Tarped]

[5] chloropicrin (400 kg/ha) [Untarped]

[6] chloropicrin (455 kg/ha) [Tarped]	Mean of 6 reps. in vine, tree,
berry field nursery trial	Rootknot nematode population/cc soil sampled
at 120-150 cm depth

[1] 21.3a

[2] 0b

[3] 0b

[4] 2.2b

[5] 0b

[6] 0b

	Schneider et al., 2002b

[1] untreated

[2] MB (285 kg/ha) [Tarped, Fall]

[3] MB (285 kg/ha) [Tarped, Spring]

[4] metam-sodium (425 kg/ha injected + 329 kg/ha overlay rotovate)
[Tarped]

[5] metam-sodium (425 kg/ha injected + 329 kg/ha overlay rotovate)
[Untarped]	4 reps, trial Malin, Oregon, 2001; loamy sand; moisture 2% at
surface, 19% at 1 meter)	Percent control of citrus nematode
(bioindicator) compared to untreated:

[2] 93% (some survival at 80 cm depth)

[3] 93% (some survival at 80 cm depth)

[4] 81% (survival at 65-80 cm depth)

[5] 73% % (survival below 5 cm depth)

	Westerdahl et al., 2002

[1] untreated

[2] MB (455 kg/ha) [shank, Tarped]

[3 1,3-D (445 kg/ha) [drip Telone II EC; Tarped]

	4 reps, artificially inoculated soils with rootknot and citrus
nematodes to depths of 30 cm, 90 cm, and 150 cm	Percent control of
citrus and rootknot nematodes compared to untreated:

[2] 100% (at all depths)

[3] significant nematode populations at 150 cm; control at 30 cm was
“excellent”	Schneider et al., 2003a

California Deciduous Fruit & Nut Tree Growers - Table C.1: Alternatives
Yield Loss Data Summary  TC " California Deciduous Fruit & Nut Tree
Growers – Table C.1: Alternatives Yield Loss Data Summary" \f F \l "1"

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

1,3-D (312 kg/ha)+ chloropicrin (177 kg/ha)	Nematodes	Not applicable	Not
applicable

1,3-D (312 kg/ha) +chloropicrin (177 kg/ha) + metam-sodium  (350 kg/ha)

Nematodes	Not applicable	Not applicable

1,3-D + metam-sodium (350 kg/ha)	Nematodes	Not applicable	Not applicable

Overall Loss Estimate for All Alternatives to Pests	Not applicable;
certification issues

Yield is not a sufficient measure of critical need for MeBr for this
industry or to determine economic feasibility in this sector since the
issue is one of constraints due to the quality of the plant stock and
the ability to have such stock certified as pest-free in order to sell
to commercial users.

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

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

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

Studies with new emulsifiable formulations of 1,3-D and chloropicrin ,
such as Inline, may improve efficacy by removing technical limitations
of shank injected 1,3-D.  However, township caps, buffer zones, and
limitations due to physical characteristics of soils are still important
issues to successful nursery production.

California Deciduous Fruit & Nut Tree Growers - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?:  TC " California Deciduous Fruit & Nut Tree Growers -
18. Are There Technologies Being Used to Produce the Crop which Avoid
the Need for Methyl Bromide?" \f C \l "2"

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

California Deciduous Fruit & Nut Tree Growers - Summary of Technical
Feasibility  TC "California Deciduous Fruit & Nut Tree Growers - Summary
of Technical Feasibility" \f C \l "2"

The primary concern for the deciduous tree nursery industry is the need
for stock certification according to the standards for inter-and
intrastate movement of plant material.  According to the government
oversight authorities (CDFA, 2001) MB, and where allowed, 1,3-D, are the
treatments that are recognized effective nematicides, the primary pest
of deciduous tree nurseries.  The critical use of MeBr is the for
nurseries whose soil type or other conditions (e.g., township caps,
buffer zone limitations) precludes the use of 1,3-D formulations.  For
the 2008 use season, MeBr is considered a critical tool to maintain
production and market goals.  In areas with appropriate soils, moisture,
and no legal restrictions, 1,3-D formulations are effective in meeting
certification requirements.

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

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

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

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

California Nursery Roses (primarily in the San Joaquin Valley – 55% to
65% of U.S. rose plant production is located around Wasco, Kern County,
CA)  	Root knot nematode (Meloidogyne hapla); lesion nematode
(Pratylencus penetrans); pin nematode (Paratylenchus hamatus);
Verticillium dahlia;  Pythium spp.; Agrobacterium tumefaciens; weeds
(including Cyperus spp.)	California regulations state that nursery stock
must be commercially clean with respect to established pests of general
distribution.  County agricultural officials may certify a crop based on
the completion of a prescribed fumigation regime, such as the use of
MeBr (CDFA, 2001).

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

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

Characteristics	California Nursery Roses

Crop Type:	Transplant production

Annual or Perennial Crop: 	Perennial (see below)

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Typically, crop rotation for a two-year rose crop includes
one-year fallow, followed by one or two years of rotational crops, and
then a two-year rose crop.  This rotation varies depending on the type
of rose crop being produced (i.e., two-year roses, one-year minis and
patio trees, or an 18-month mini bush).

Soil Types: 	Medium soil with 0 to 2% organic matter.

Frequency of methyl bromide Fumigation: 	Once every 4 to 5 years (a
typical grower fumigates and plants approximately 20-25% of the
production area each year).

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

California Nursery Roses - Table 11.2 Characteristics of Climate and
Crop Schedule+  TC " California Nursery Roses - Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone

	USDA Plant Hardiness Zone 9a

Rainfall (mm)*	16.0	72.1	17.3	0	Trace	1.0	Trace	0	44.7	56.9	9.9	30.5

Outside Temp. ((C)*	14.4	14.8	20.8	25.7	30.3	27.4	25.1	18.4	13.4	9.6
10.3	10.6

Fumigation Schedule

	Land prep	X

Planting

Schedule

	X	X

+ The planting and fumigation schedule are for 1 year roses.  The
schedules vary for other rose crops.

*Data for Jan-Aug, 2003 and Sep-Dec 2002 for Fresno, California.

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

California Nursery Roses - Table 11.3 Multi-year Rose Crop Schedule  TC
"California Nursery Roses - Table 11.3 One Year Rose Crop Schedule" \f F
\l "1"

	spr*	sum	fal	wnt	spr	sum	fal	wnt	spr	sum	fal	wnt	spr	sum	fal	wnt

Fumigation Schedule

X

Planting Schedule

	X

	Harvest Schedule

	X	X

Fallow

	X	X	X	X

Cover Crop	X

X	X	X	X

* spr = spring; sum = summer; fal = fall; wnt = winter

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

Restrictions due to soil moisture or structure.

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

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

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

Area Treated (hectares)	600	609	647	584	576	459

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Flat Fumigation	Flat Fumigation	Flat Fumigation	Flat
Fumigation	Flat Fumigation	Flat Fumigation

Amount of methyl bromide active ingredient used

(total kilograms)	204,933	217,588	219,938	196,496	161,479	144,286

formulations of methyl bromide

( methyl bromide /chloropicrin)	98:2 	98:2 	98:2 	98:2 	98:2

	Method by which methyl bromide applied

(e.g. injected at 25cm depth, hot gas)	Shanked 25 cm and tarped	Shanked
25 cm and tarped	Shanked 25 cm and tarped	Shanked 25 cm and tarped
Shanked 25 cm and tarped	Shanked 25 cm and tarped

Application rate [Active Ingredient] (kg/ha*)	341	357	340	336	280	315

Actual dosage rate of Active Ingredient (g/m2)*	34.1	35.7	34.0	33.6	28.0
31.5

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

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

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

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

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

Chemical Alternatives

1,3-Dichloropropene	1,3-D is feasible in some situations, such as areas
with sandy soils where the soil moisture can be reduced to 12% or less.
According to California certification regulations, this alternative and
MeBr are acceptable soil treatments (CDFA, 2001).

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

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

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

Metam-sodium	Metam-sodium is not a feasible alternative alone because it
results in nursery rose shipments that might not be certified.  Research
indicates that a non-certified crop occurs because metam-sodium did not
move deep enough into the soil (at the 1.2 to 1.5 meter depth metam
sodium did not control the nematodes) (Schneider et al, 2002a; McKenry,
1999; Karlik et al, 1998). 	No.

Non Chemical Alternatives

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

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

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

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

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

Combinations of Alternatives

1,3-Dichloropropene + chloropicrin and/or metam sodium	See the
regulatory and technical limitations for 1,3-D above.	Possibly, if no
restrictions apply; U.S. nomination is for areas where 1,3-D is not
effective.

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

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

Name of Alternative	Discussion

Iodomethane + chloropicrin	This alternative is not registered in the
U.S.

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

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

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

Iodomethane	Not registered	Yes	Unknown

Sodium azide	Registration package not submitted	No	Unknown

Propargyl bromide	Registration package not submitted	No	Unknown

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

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

Perennial Crop Nurseries—Performance of Methyl Bromide Alternatives in
the Field (Schneider et al, 2004).  “Rootknot nematode was found in
the roots of plants grown in the untreated plots and in plots treated
with MIDAS [iodomethane, 30% and chloropicrin, 70% @ 448 kg/ha drip
applied], untarped Telone C35, chloropicrin [224 kg/ha, split
application], metam sodium, and Iota [bacterial suspension].  Treatments
resulting in nematode infested roots are not acceptable for certified
nursery use.  The largest plants were in plots treated with methyl
bromide or tarped Telone C35”.

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

Jackson and Perkins Fumigant Tests, 2003.  Preliminary data submitted by
Jackson and Perkins Operation, Inc. showed yield losses of 2–8% for
metam-sodium (Vapam HL, 701 L/ha), yield losses of 5% for 1,3-D (Telone
II, 309 L/ha), and for MeBr (336 kg/ha) yield gains of up to 10% to
yield losses of 6%  The data submitted gave yields compared to historic
yields for numerous rose varieties.  The first year results indicated
that there was no nematode pressure in the trials.  There was no
statistical analysis on the results.

Other studies submitted were conducted on orchard and vineyard crops.
Some the results are included in the tables below.  These studies
demonstrate that the alternatives do not provide the same level of
nematode control as MeBr to the depth required.

  California Nursery Roses – Table 16.1: Effectiveness of Alternatives
– Nematodes  TC "California Nursery Roses – Table 16.1:
Effectiveness of Alternatives – Nematodes" \f F \l "1"

Key Pest:  Nematodes	Average disease % or rating and yields in past 3~5
years

Methyl Bromide formulations and Alternatives	# of Replications	Total #
Nematodes at a depth across all replicates

(The results have been added across the 4 replicates – there is no
statistical analysis on these results).

Depth	# of Nematodes

MB + CP (75/25) 535 lb/ac (599 kg/ha), tarped	4	0-1 feet (0-0.3 meters)

1-2 feet (0.3-0.6 meters)

2-3 feet (0.6-0.9 meters)

3-4 feet (0.9-1.2 meters)

4-5 feet (1.2-1.5 meters)	0

0

0

2

15

	Dual application Telone C-35 @ 65 gpa (608 L/ha) or approx. 650 lb/acre
(728 kg/ha)	4	0-1 feet (0-0.3 meters)

1-2 feet (0.3-0.6 meters)

2-3 feet (0.6-0.9 meters)

3-4 feet (0.9-1.2 meters)

  4-5 feet (1.2-1.5 meters)	2

1

0

2

47

	1,3-D (330 lb/ac (370 kg/ha)) then metam sodium drench (110 lb/ac (123
kg/ha))	4	0-1 feet (0-0.3 meters)

1-2 feet (0.3-0.6 meters)

2-3 feet (0.6-0.9 meters)

3-4 feet (0.9-1.2 meters)

4-5 feet (1.2-1.5 meters)	5

0

1

40

103

	1,3-D (330 lb/ac (370 kg/ha)) then Basamid drench (200 lb/ac (224
kg/ha))	4	0-1 feet (0-0.3 meters)

1-2 feet (0.3-0.6 meters)

2-3 feet (0.6-0.9 meters)

3-4 feet (0.9-1.2 meters)

4-5 feet (1.2-1.5 meters)	 0

 0

0

2

16

	Non-treated check	4	0-1 feet (0-0.3 meters)

1-2 feet (0.3-0.6 meters)

2-3 feet (0.6-0.9 meters)

3-4 feet (0.9-1.2 meters)

4-5 feet (1.2-1.5 meters)	98

455

416

 836

216

	McKenry, 2000 (this study was conducted on tree nurseries).

California Nursery Roses – Table 16.2: Effectiveness of Alternatives
– Phytophthora  TC " California Nursery Roses – Table 16.2:
Effectiveness of Alternatives – Phytophthora" \f F \l "1"

Key Pest: Phytophthora citricola	Average disease % or rating and yields
in past 3~5 years

Methyl Bromide formulations and Alternatives	# of Replications	Total
Number of colonies formed out of 10 inoculum pieces plated at certain
depths Across all Replicates (max # is 40 – 4 reps x10 pieces.  No
statistical analysis on these results)

Depth	# of Colonies

MB + CP (75/25) 535 lb/ac (599 kg/ha), tarped	4	0.5 feet (0.2 meters)

2.0 feet (0.6 meters)

4.0 feet (1.2 meters)	0

10

40

	Dual application Telone C-35 @ 65 gpa (608 L/ha) or approx. 650 lb/acre
(728 kg/ha)	4	0.5 feet (0.2 meters)

2.0 feet (0.6 meters)

4.0 feet (1.2 meters)	0

0

20

	1,3-D (330 lb/ac (370 kg/ha)) then metam sodium drench (110 lb/ac (123
kg/ha))	4	0.5 feet (0.2 meters)

2.0 feet (0.6 meters)

4.0 feet (1.2 meters)	5

20

38

	1,3-D (330 lb/ac (370 kg/ha)) then Basamid drench (200 lb/ac (224
kg/ha))	4	0.5 feet (0.2 meters)

2.0 feet (0.6 meters)

4.0 feet (1.2 meters)	0

0

40

	Non-treated check	4	0.5 feet (0.2 meters)

2.0 feet (0.6 meters)

4.0 feet (1.2 meters)	37

30

30

	McKenry, 2000 (This study was conducted on tree nurseries).

California Nursery Roses – Table 16.3: Effectiveness of Alternatives
– Stunt Nematode  TC " California Nursery Roses – Table 16.3:
Effectiveness of Alternatives – Stunt Nematode" \f F \l "1"

Key Pest: Stunt Nematode	Disease (% or rating) Mean of 6 replications

Methyl Bromide formulations and Alternatives	# of Reps	0 – 0.3 meters

(0-12 inches)	0.6-0.9 meters

(24-36 inches)	1.2 – 1.5 meters

(48-60 inches)

Untreated	6	1.0 b*	29.8 a	5.8 ab

Methyl bromide – 350 lb/acre (392 kg/ha), tarped – noble plow	6	0.0
b	0.0 b	0.0 c

30% Iodomethane 70% Chloropicrin – 400 lb/acre (448 kg/ha), tarped –
noble plow	6	0.0 b	0.0 b	0.4 bc

Telone C35 – 48 gal/acre (449 L/ha) – noble plow	6	0.0 b	0.9 b	6.2
ab

Telone C35 – 48 gal/acre (449 L/ha); untarped – telone rig	6	0.0 b
0.3 b	3.5 abc

Inline – 50 gal/acre (468 L/ha), drip	6	0.0 b	0.3 b	2.4 abc

Telone EC – 35 gal/acre (327 L/ha), drip	6	0.0 b	0.9 b	6.9 ab

Chloropicrin – 200 lb/acre (224 kg/ha), drip	6	0.0 b	3.0 b	13.3 a

Chloropicrin – 400 lb/acre (448 kg/ha), drip	6	0.0 b	1.4 b	4.8 abc

Chloropicrin – 200 + 200 lb/acre (224 + 224 kg/ha), drip	6	0.0 b	0.0 b
4.2 abc

30% Iodomethane 70% - 400 lb/acre (448 kg/ha), drip	6	0.0 b	0.0 b	0.0 c

50% Iodomethane 50% Chloropicrin – 300 lb/acre (336 kg/ha), drip	6	0.2
b	0.0 b	0.0c

Metam sodium – 75 gal/acre (701 L/ha) (42% a.i.), drip	6	0.2 b	0.0 b
10.0 a

Iota (a bacterial suspension from FUSION 360, Turlock, CA)	6	5.5 a	47.8
a	7.9 ab

Schneider et al, 2002b

* Statistical analysis conducted on log transformed (ln (n+1)) data.
Data presented are the antilogs of the means.

Stunt Nematode Populations per 250cc soil sampled at planting in a
commercial rose trial.  Results at other depths (12-24 inches (0.3-0.6
meters) and 36-48 inches (0.9-1.2 meters) are also available in the
study.

California Nursery Roses – Table 16.4: Effectiveness of Alternatives
– Root Knot Nematode  TC "California Nursery Roses – Table 16.4:
Effectiveness of Alternatives – Root Knot Nematode" \f F \l "1"

Key Pest: Root Knot Nematode	Root Knot Nemtaode Populations per 100 cc
soil sampled at Planting in a Commercial Rose Trial March 2003

Methyl Bromide formulations and Alternatives	# of RePs	Disease (% or
rating)

# of Nematodes (soil sampled to a depth of 0.6 meters (24 inches)

Mean 	Range

Untreated	6	18.0 a	0-805

Methyl bromide – 350 lb/acre (392 kg/ha), tarped – noble plow	6	0 c
0-0

30% Iodomethane 70% Chloropicrin – 400 lb/acre (448 kg/ha), tarped –
noble plow	6	0 c	0-0

Telone C35 – 48 gal/acre (449 L/ha) – noble plow	6	0.8 bc	0-32

Telone C35 – 48 gal/acre (449 L/ha); untarped – telone rig	6	6.4 ab
0-354

Inline – 50 gal/acre (468 L/ha), drip	6	0 c	0-0

Telone EC – 35 gal/acre (327 L/ha), drip	6	0 c	0-0

Chloropicrin – 200 lb/acre (224 kg/ha), drip	6	0 c	0-0

Chloropicrin – 400 lb/acre (448 kg/ha), drip	6	0 c	0-0

Chloropicrin – 200 + 200 lb/acre (224 + 224 kg/ha), drip	6	0 c	0-0

30% Iodomethane 70% - 400 lb/acre (448 kg/ha), drip	6	0 c	0-0

50% Iodomethane 50% Chloropicrin – 300 lb/acre (336 kg/ha), drip	6	0 c
0-0

Metam sodium – 75 gal/acre (701 L/ha) (42% a.i.), drip	6	0.5 bc	0-12

Iota (a bacterial suspension from FUSION 360, Turlock, CA)	6	10.8 a
0-213

Schneider et al, 2003b

Statistical analyses conducted on log transformed (log (n+1)) data.
Data presented are antilogs of the means, as well as the range of
values.  Means followed by the same letter are not significantly
different at the P=0.05 level.

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

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

See paragraph below.	Nematodes	Not applicable	Not applicable

Overall Loss Estimate for All Alternatives to Pests	Not applicable;
certification issues

Although yield and quality losses may occur due to key pests, the
studies for nursery roses are ongoing.  Because these studies are in
progress and the crop is perennial, yield losses have not been
determined.  However, the crop must meet certification requirements or
the stock will not be accepted.  The pests must be controlled or the
growers will not be able to sell their product.

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

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

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

1,3-D may be an acceptable alternative to MeBr where restrictions do not
apply.  However, nurseries unable to use 1,3-D will have a critical need
for MeBr in 2008.  Some growers are able to control pests thus avoiding
crops and weeds that are hosts to nematodes.  However, re-infestation is
always a threat through contaminated irrigation water, runoff water, or
weeds.  In addition, the income from the rotational crops, often cereal
crops, is about a third of that received for roses.

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

Although 1,3-D with chloropicrin has been demonstrated as an effective
alternative in some situations, it is not available for use in all
nurseries.  In soils with moisture levels above 12%, 1,3-D does not
provide control of nematodes.  In addition, 1,3-D does not control
Verticillium dahilae, Pythium spp., or weeds.  There are regulatory
limitations to the use of 1,3-D, yet growers must meet certification
requirements.  Township caps may limit the availability of this
alternative to growers, especially since nursery roses are primarily
produced in two townships, where other crops that use 1,3-D are also
grown.  Other alternatives, such as metam sodium and dazomet do not
provide consistent control of target pests to a depth of 1.5 meters.

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

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

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

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

What use/emission reduction methods are presently adopted?	Currently
some growers use HDPE tarps.  VIF might be a feasible means of reducing
emissions if physical properties of VIF can be improved, especially the
ability to successfully and consistently roll the film over beds without
breakage and ability to glue the material.  There are restrictions for
use of VIF in California.	Most nurseries have reduced MeBr amounts to
lower rate formulations. Between 1997 and 2001, the U.S. has achieved a
36% reduction in use rates. 	From 2% to 33% or 25% (for some nurseries)
No

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Research is underway to develop use in
commercial production systems 	Research is underway to develop use of a
50% MeBr formulation where pest pressure allows.	Research is underway to
develop use of a 50% MeBr formulation where pest pressure allows.	Not
likely

Other measures (please describe)	Unidentified	Unidentified	Unidentified
Fumigation once every 2 – 3 years

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

Technologies to reduce emissions are being addressed by this sector.
For example, VIF, use of advanced delivery techniques, such as deep
injection, to make alternative chemicals more effective at deeper soil
levels, and reduction in use rate of MeBr to 50:50.  While new mixtures
and formulations can be effective at controlling target pests,
especially at low pest pressure, the long-term efficacy of these
mixtures is unknown, especially where pest-free standards are in force.

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

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

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

This table is not included since none of the alternatives are feasible.
See Summary of Economic Feasibility below.

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

Table 22.1: Year 1 Gross and Net Revenue

Table 22.2: Year 2 Gross and Net Revenue

Table 22.3: Year 3 Gross and Net Revenue

These tables are not included since none of the alternatives are
feasible.  See Summary of Economic Feasibility below.

Measures of Economic Impacts of Methyl Bromide Alternatives  TC
"Measures of Economic Impacts of Methyl Bromide Alternatives" \f C \l
"2"

- Table E.1: Western Raspberry Nurseries Economic Impacts of Methyl
Bromide Alternatives

Table E.2: California Deciduous Fruit & Nut Tree Growers - Economic
Impacts of Methyl Bromide Alternatives

Table E.3: California Nursery Roses - Economic Impacts of Methyl Bromide
Alternatives

These tables are not included since none of the alternatives are
feasible.  See Summary of Economic Feasibility below.

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

An economic analysis was not done because most of the losses cannot be
quantified since there are no data to substantiate the magnitude of
these losses.

Certification requirements.  The requested amount of MeBr in the U.S.
nomination includes those areas where 1,3-D would not meet the
certification requirements or would be limited by township caps.  Under
California regulatory laws, nursery crops must be “free of especially
injurious pests and disease symptoms” in order to qualify for a CDFA
Nursery Stock Certificate for Interstate and Intrastate Shipments (CDFA,
2001).  If an approved fumigation is not used in the nursery, a nematode
sampling procedure is imposed by CDFA, and if nematodes are found all
nursery stock in an area should be destroyed resulting in a complete
loss.  MeBr meets the certification guidelines.  Also, in certain soil
conditions, 1,3-D meets certification guidelines; California township
caps may limit the use of 1,3-D.

If nematodes are found and the nursery stock is not “free of
especially injurious pests and disease symptoms”, then a total loss is
likely because the nursery stock:

Would not qualify for a CDFA Nursery Stock Certificate for Interstate
and Intrastate Shipments,

Would probably not be marketable, since resale for planting is severely
restricted by the CDFA.

Should be destroyed to prevent further infestation.

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

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

Beyond the nursery.  Healthier plants and trees provide benefits beyond
the nursery in terms of higher yields of fruit and nuts and reduced
infestations.  One hectare of nursery stock provides these benefits to
many hectares producing fruits and nuts.

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

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

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

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

As stated in Section 23, minimizing use of MeBr can be achieved through
the development of technologies to improve efficacy of alternatives.
Plans to develop VIF, deep injection, 1,3-D efficacy, and reduction of
MeBr use rates are all ongoing.  Transferring these technologies to
field situations requires additional time.  These consortia are
developing timelines for this transition.  However, for 2008, MeBr will
be critical for nurseries unable to use effective alternatives.

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

This critical use exemption nomination has been reviewed by the U.S.
government and meets the guidelines of The Montreal Protocol on
Substances That Deplete the Ozone Layer.  The nomination for MeBr is for
nurseries that are unable to use effective alternatives to MeBr to
attain certification for nursery plant material.  For raspberry, rose,
and deciduous tree nurseries that can not use 1,3-D due to legal
restrictions or physical limitations, MeBr use will be critical for the
2008 use season.  The loss of MeBr under these circumstances would
result in a significant market disruption.

26. Citations  TC "26. Citations" \f C \l "2"

Braun, A. L. and D. M. Supkoff, 1994. Options to Methyl Bromide for the
Control of Soil-Borne Diseases and Pests in California with Reference to
the Netherlands. Pest Management Analysis and Planning Program,
California Department of Pesticide Regulation.

CDFA (California Department of Food and Agriculture). 2001. Approved
treatment and handling procedures to ensure against nematode pest
infestation of nursery stock. California Code of Regulations, Title 3,
Section 3060, et seq.  Nursery Inspection Procedures Manual, Item #12.
18 pp.; http://www.cdfa.ca.gov/phpps/pe/nipm.htm

Federal Register, February 5, 1998, 40 CFR, part 82. Control of methyl
bromide emissions through use of tarps.
http://frwebgate5.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=82648432
0000+6+0+0&WAISaction=retrieve.

Gan, J. and Yates, S. R. 1998. Ammonium thiosulfate fertilizer reduces
methyl bromide emissions from soil. Methyl Bromide Alternatives, USDA,
ARS. vol 4 (3), July,1998.   HYPERLINK
"http://www.ars.usda.gov/is/np/mba/july98/ammonium.htm"
http://www.ars.usda.gov/is/np/mba/july98/ammonium.htm

Gullino, M. L., Minuto, A., Camponogara, A., Minuto, G., and Garibaldi,
A. 2002. Soil disinfestations in Italy: status two years before the
phase-out of methyl bromide. Annual International Research Conference on
Methyl Bromide Alternatives (2002).   HYPERLINK "http://mbao.org/"
http://mbao.org/

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

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

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

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

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

McKenry, M. 2001. Performance of metam sodium drenched to six different
replant sites. Annual International Research Conference on Methyl
Bromide Alternatives (2001).   HYPERLINK "http://mbao.org/"
http://mbao.org/

McKenry, M. V. 1999. The replant problem and its management. Contractor
for California Association of Nurseryman.  Prepared for California
Department of Pesticide Regulation. Catalina Publishing, Fresno,
California, USA.  http://www.uckac.edu/nematode/PDF/Replant-Sec1.pdf

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

Schneider, S., T. Trout, J. Gerik, and H. Ajwa. 2004. Perennial crop
nurseries—performance of methyl bromide alternatives in the field.
Annual International Research Conference on Methyl Bromide Alternatives
and Emissions Reductions (2004). www.mbao.org

Schneider, S., E. Rosskopf, J. Leesch, D. Chellemi, C. Bull, and M.
Mazzola. 2003a. United States Department of Agriculture – Agricultural
Research Service Research on Alternatives to Methyl Bromide: Pre-plant
and Post-harvest, Pest Management Science 59: 814-826.

Schneider, S., T. Trout, J. Gerik, D. Ramming, and H. Ajwa. 2003b.
Methyl Bromide Alternatives for Perennial Field Nurseries – 1st and
2nd Year Performance, Proceeding from the 2003 Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions. www.mbao.org

Schneider, S., J. Gerik, Trout, T. 2002a. Evaluation of Alternatives to
Methyl Bromide for Roses (Presentation), USDA ARS Parlier.

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

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

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

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

Westerdahl, B. B., Buchner, R. P., Loftus, R., and Loftus, T. 2002.
Tarped metam sodium for nematode and weed control in nurseries. Annual
International Research Conference on Methyl Bromide Alternatives (2002).
  HYPERLINK "http://mbao.org/"  http://mbao.org/

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

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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