Page 1 METHYL BROMIDE CRITICAL USE NOMINATION FOR PREPLANT SOIL USE ON STRAWBERRY NURSERIES IN OPEN FIELDS OR IN PROTECTED ENVIRONMENTS FOR ADMINISTRATIVE PURPOSES ONLY: DATE RECEIVED BY OZONE SECRETARIAT:

YEAR: CUN:

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

X Yes

No CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Tina E. Levine, Ph. D. Title: Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency Mail Code 7503C Page 2 Washington, DC 20460 U. S. A. Telephone: ( 703) 308 3099 Fax: ( 703) 308 8090 E mail: levine. tina@ epa. gov LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE List all paper and electronic documents submitted by the Nominating Party to the Ozone Secretariat 1. PAPER DOCUMENTS: Title of Paper Documents and Appendices Number of Pages Date Sent to Ozone Secretariat 2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: Title of Electronic Files Size of File ( kb) Date Sent to Ozone Secretariat Page 3 TABLE OF CONTENTS PART A: SUMMARY................................................................................................................................................. 6 1. Nominating Party _________________________________________________________ 6 2. Descriptive Title of Nomination______________________________________________ 6 3. Crop and Summary of Crop System___________________________________________ 6 4. Methyl Bromide Nominated _________________________________________________ 6 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 6 6. Summarize Why Key Alternatives Are Not Feasible______________________________ 8 7. Proportion of Crops Grown Using Methyl Bromide ______________________________ 8 8. Amount of Methyl Bromide Requested for Critical Use ___________________________ 9 9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity Nominated for Each Region___________________________________________________________________ 10 Southeastern States  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ............................................. 12 Southeastern States  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request __________________________________________ 12 Southeastern States  11. Characteristics of Cropping System and Climate______________ 12 Southeastern States  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested___________________ 13 SOUTHEASTERN STATES  PART C: TECHNICAL VALIDATION.................................................................................. 14 Southeastern States  13. Reason for Alternatives Not Being Feasible _________________ 14 Southeastern States  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: __ 21 Southeastern States  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _____________________________________________ 21 Southeastern States  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ________________________________________________________________________ 22 Southeastern States  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide __________________________ 23 Southeastern States  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide ___________________________________________ 23 Southeastern States  Summary of Technical Feasibility ____________________________ 23 California  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ........................................................... 24 California  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request______________________________________________ 24 California  11. Characteristics of Cropping System and Climate _____________________ 24 California  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 26 CALIFORNIA  PART C: TECHNICAL VALIDATION ................................................................................................... 27 California  13. Reason for Alternatives Not Being Feasible _________________________ 27 California  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 27 California  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 27 Page 4 California  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 27 California  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 32 California  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide____________________________________________________ 32 California  Summary of Technical Feasibility ___________________________________ 32 PART D: EMISSION CONTROL ................................................................................................................................ 33 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 33 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 33 PART E: ECONOMIC ASSESSMENT.......................................................................................................................... 34 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 34 California 22. Gross and Net Revenue __________________________________________ 34 Southeastern States 22. Gross and Net Revenue __________________________________ 35 Summary of Economic Feasibility _____________________________________________ 38 PART F. FUTURE PLANS ........................................................................................................................................ 40 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 41 25. Additional Comments on the Nomination ____________________________________ 41 26. Citations ______________________________________________________________ 41 APPENDIX B. SUMMARY OF NEW APPLICANTS ___________ Error! Bookmark not defined.

LIST OF TABLES PART A: SUMMARY _____________________________________________________________ 6 Table 4.1: Methyl Bromide Nominated ____________________________________________ 6 Table A. 1: Executive Summary __________________________________________________ 7 Table 7.1: Proportion of Crops Grown Using Methyl Bromide __________________________ 8 Southeastern States and California Table 8.1: Amount of Methyl Bromide Requested for Critical Use ______________________________________________________________ 9 Table A. 2: 2006 Sector Nomination   Strawberry Nurseries ___________________________ 11 SOUTHEASTERN STATES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ________ 12 Southeastern States  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ________________________________________________________________ 12 Southeastern States  Table 11.1: Characteristics of Cropping System ___________________ 12 Southeastern States  Table 11.2 Characteristics of Climate and Crop Schedule____________ 12 Southeastern States  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________ 13 SOUTHEASTERN STATES  PART C: TECHNICAL VALIDATION ______________________________ 14 Southeastern States   Table 13.1: Reason for Alternatives Not Being Feasible ____________ 14 Southeastern States   Table 14.1: Technically Infeasible Alternatives Discussion __________ 21 Southeastern States   Table 15.1: Present Registration Status of Alternatives _____________ 21 Southeastern States   Table 16.1: Effectiveness of Alternatives   Certain Weeds 1 _________ 22 Southeastern States   Table C. 1: Alternatives Yield Loss Data Summary ________________ 23 Page 5 CALIFORNIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE_________________ 24 California  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request__ 24 California  Table 11.1: Characteristics of Cropping System___________________________ 24 California  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 25 California  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 25 California  Table 12.1 Historic Pattern of Use of Methyl Bromide _____________________ 26 CALIFORNIA  PART C: TECHNICAL VALIDATION ______________________________________ 27 Southeastern States   Table 13.1: Reason for Alternatives Not Being Feasible ____________ 27 Southeastern States   Table 14.1: Technically Infeasible Alternatives Discussion __________ 27 California   Table 15.1: Present Registration Status of Alternatives _____________________ 27 CALIFORNIA   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   Chemical Alternatives to Methyl Bromide Fumigation   How Well Do They Work? ______________________________ 29 CALIFORNIA   TABLE 16.2: EFFECTIVENESS OF ALTERNATIVES Chloropicrin Effect on Weed Seed Viability. _______________________________________________________________ 30 CALIFORNIA   TABLE 16.3: EFFECTIVENESS OF ALTERNATIVES  Soil Fumigation and Runner Plant Production._________________________________________________________ 30 CALIFORNIA   TABLE 16.4: EFFECTIVENESS OF ALTERNATIVES  Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries _____ 31 California   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 32 PART D: EMISSION CONTROL ____________________________________________________ 33 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 33 PART E: ECONOMIC ASSESSMENT _________________________________________________ 34 Table 21.1: Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______ 34 California Table 22.1: Year 1 Gross and Net Revenue _______________________________ 34 California Table 22.2: Year 2 Gross and Net Revenue _______________________________ 35 Table 22.3: Year 3 Gross and Net Revenue ________________________________________ 35 Southeastern States Table 22.1: Year 1 Gross and Net Revenue ________________________ 35 Southeastern States Table 22.2: Year 2 Gross and Net Revenue ________________________ 35 Southeastern States Table 22.3: Year 3 Gross and Net Revenue ________________________ 35 Southeastern States  Table E. 1: Economic Impacts of Methyl Bromide Alternatives _______ 37 California  Table E. 2: Economic Impacts of Methyl Bromide Alternatives _______________ 37 PART F. FUTURE PLANS ________________________________________________________ 40 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI)._________________ 46 Page 6 PART A: SUMMARY 1. NOMINATING PARTY The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION Methyl Bromide Critical Use Nomination for Preplant Soil Use on Strawberry Nurseries in Open Fields or in Protected Environments 3. CROP AND SUMMARY OF CROP SYSTEM Southeastern growers ( Maryland, North Carolina, Tennessee) produce their transplants in open fields on an annual basis. Individual fields are only planted to strawberries once every three years. Approximately eighty five percent of transplants produced are exported to Florida.

California growers produce their transplants over a five year cycle. Screenhouses are utilized during the first two years and open field plantings are used during the last three years. Methyl bromide is only needed in production years 2 thru 5. Individual planting sites are only planted to strawberries once every three years. The fourth and fifth production years account for 22 and 77 percent, respectively, of the current methyl bromide nursery usage in California. Transplants produced are distributed widely throughout the U. S. and other countries.

4. METHYL BROMIDE NOMINATED TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG) NOMINATION AREA ( HA) 2006 56,291 209 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE The U. S. nomination is only for those areas where the alternatives are not suitable. In U. S. strawberry nursery production there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  Pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible for use in tomato production.  Quarantine and Pre Shipment uses are not included in this CUE.

Methyl bromide is needed for strawberry nursery production to produce plants free of all damaging diseases and nematodes to meet state and foreign certification standards, as well as prospective buyer expectations. In addition to these certification related pest control concerns, weed control is also essential to insure maximum runner production and prevent the spread of Page 7 noxious weeds. The available alternatives have thus far not been found to provide acceptable levels of control of the key pests to depths of three feet. In addition, there are no markets for plants that do not meet the certification standards, which means that losses up to 100 percent are possible when less than required levels of pest control occur. Failure to adequately control pests in transplants would jeopardize the viability of the transplant and fruit production industries in the US, as well as the viability of fruit production in countries purchasing U. S. plants ( e. g., Canada, Mexico, Spain, South America, and a number of other countries).

TABLE A. 1: EXECUTIVE SUMMARY Region Southeastern States California AMOUNT OF NOMINATION 2006 Kilograms 2,086 53,751 Application Rate ( kg/ ha) 413 263 Area ( ha) 5 204 AMOUNT OF APPLICANT REQUEST 2006 Kilograms 41,453 443,432 Application Rate ( kg/ ha) 413 263 Area ( ha) 100 1,683 ECONOMICS FOR NEXT BEST ALTERNATIVE Marginal Strategy 1,3D+ Pic 1,3D+ Pic Yield Loss (%) 10% 10%

Loss per hectare ( US$/ ha) $ 5,469 $ 7,208 Loss per kg Methyl Bromide ( US$/ kg) $ 13.26 $ 27.37 Loss as % of Gross Revenue (%) 13% 18%

Loss as % of Net Revenue (%) 46% 61% Page 8 6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE The key alternatives are 1,3 D/ chloropicrin, 1,3 D/ chloropicrin/ metam sodium, and 1,3 D/ metam sodium. None of these alternatives provide an adequate level of disease and nematode control throughout the root zone ( up to 3 feet deep). Additionally, these alternatives generally provide little or no control of Yellow & Purple Nutsedge ( Cyperus esculentus, C. rotundus) ( SE States only) and a number of other critical weed pests in California ( Table 10.1). The state certification requirements ( references 7, 32a, 37a, 43a listed in section 26) associated with the requesting states are very high ( virtually zero tolerance for any damaging diseases and plant parasitic nematodes) in order to minimize the prospect of spreading these nematode and disease pests to other states and countries where these plants are shipped.

7. ( i) PROPORTION OF CROPS GROWN USING METHYL BROMIDE All growers in the affected states requesting methyl bromide use are dependent upon its wide pest spectrum and high level of pest control.

TABLE 7.1: PROPORTION OF CROPS GROWN USING METHYL BROMIDE REGION WHERE METHYL BROMIDE USE IS REQUESTED TOTAL CROP AREA   2001 2002 AVERAGE ( HA) PROPORTION OF TOTAL CROP AREA TREATED WITH METHYL BROMIDE (%) Southeastern States Not Available Not Available California 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.

Not applicable. Please see the discussion of each alternative for a description of why it cannot be used under these situations.

7. ( iii) WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE THIS?

Not applicable because the alternatives have not been proven effective for the control of the target pests under these conditions. Page 9 8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE SOUTHEASTERN STATES AND CALIFORNIA TABLE 8.1: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: SOUTHEASTERN STATES CALIFORNIA YEAR OF EXEMPTION REQUEST 2006 2006 KILOGRAMS OF METHYL BROMIDE 41,453 443,432 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT FLAT FUMIGATION FLAT FUMIGATION FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 67: 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 100 ha. 1,683 ha.

APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 619 395 APPLICATION RATE* ( kg/ ha) FOR METHYL BROMIDE 413 263 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 61.9 39.5 DOSAGE RATE* ( g/ m2) OF METHYL BROMIDE 41.3 26.3 Page 10 9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION The amount of methyl bromide nominated by the U. S. was calculated as follows:

  The percent of regional hectares in the applicant's request was divided by the total area planted in that crop in the region covered by the request. Values greater than 100 percent are due to the inclusion of additional varieties in the applicant's request that were not included in the USDA National Agricultural Statistics Service surveys of the crop.   Hectares counted in more than one application or rotated within one year of an application to a crop that also uses methyl bromide were subtracted. There was no double counting in this sector.   Growth or increasing production ( the amount of area requested by the applicant that is greater than that historically treated) was subtracted. The two applicants that included growth in their request had the growth amount removed.   There was a small adjustment for use rate in one of the applications.   Quarantine and pre shipment ( QPS) hectares is the area in the applicant's request subject to QPS treatments. Both applicants had QPS listed the amount requested reflects the subtraction of the QPS amount.   Only the acreage experiencing one or more of the following impacts were included in the nominated amount: moderate to heavy key pest pressure. Page 11 TABLE A. 2: 2006 SECTOR NOMINATION   STRAWBERRY NURSERIES*

2006 Strawberry Nurseries Sector Nomination Southeastern States California Requested Hectares ( ha) 100 1,683 Requested Application Rate ( kg/ ha) 413 263 Applicant Request for 2006 Requested Kilograms ( kg) 41,453 443,432 Nominated Hectares ( ha) 5 204 Nominated Application Rate ( kg/ ha) 413 263 CUE Nominated for 2006 Nominated Kilograms ( kg) 2,086 53,751 Overall reduction (%) 88%

2006 U. S. CUE Nomination ( kg) 55,837 Research Amount ( kg) 454 2006 Sector Nomination Totals Total 2006 U. S. Sector Nominated Kilograms ( kg) 56,291 * See Appendix A for complete description of how nominated amount was calculated. Page 12 SOUTHEASTERN STATES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE SOUTHEASTERN STATES  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST SOUTHEASTERN STATES  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Southeastern States Weeds: Yellow nutsedge ( Cyperus esculentus), Purple nutsedge ( Cyperus rotundus)

Diseases: Black root rot ( Rhizoctonia and Pythium spp.); Crown rot ( Phytophthora cactorum); root knot nematodes ( Meloidogyne spp.) None of the available alternatives provide an acceptable level of control of nutsedge; the affected states' regulatory requirements to meet certification standards which amount to virtually complete control of fungal diseases and nematodes, is only attainable with methyl bromide SOUTHEASTERN STATES  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE SOUTHEASTERN STATES  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS SOUTHEASTERN STATES CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Strawberry Transplants ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual crop, replanted in same site once every three years TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Various crops planted SOIL TYPES: ( Sand, loam, clay, etc.) 93% medium and 7% light soils, containing up to 2% organic matter FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Every year OTHER RELEVANT FACTORS: None identified SOUTHEASTERN STATES  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( temperate, zones 6a to 8b) 6a, 6b, 7a, 7b, 8a, 8b RAINFALL ( mm) 163 124 109 87 78 146 113 202 109 116 54 76 OUTSIDE TEMP. ( ° C) 9.4 14.5 17.7 23.4 26 25.9 22.6 14.9 7.7 3.4 2.9 4.2 FUMIGATION SCHEDULE X X PLANTING SCHEDULE X X HARVEST SCHEDULE 2X X * Macon, GA Page 13 SOUTHEASTERN STATES   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

None were identified as being limiting factors.

SOUTHEASTERN STATES  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED SOUTHEASTERN STATES  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 82 82 82 55 67 71 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Virtually all flat fumigation Virtually all flat fumigation Virtually all flat fumigation Virtually all flat fumigation Virtually all flat fumigation Virtually all flat fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 49,386 49,386 33,764 22,900 27,747 29,251 FORMULATIONS OF METHYL BROMIDE ( methyl bromide/ chloropicrin) 98: 2 98: 2 67: 33 67: 33 67: 33 67: 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection APPLICATION RATE OF FORMULATIONS IN kg/ ha* 616 616 619 619 619 619 APPLICATION RATE OF METHYL BROMIDE IN kg/ ha* 604 604 413 413 413 413 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 61.6 61.6 61.9 61.9 61.9 61.9 ACTUAL DOSAGE RATE OF METHYL BROMIDE ( g/ m2)* 60.4 60.4 41.3 41.3 41.3 41.3 * For flat fumigation treatment application rate and dosage rate may be the same. Page 14 SOUTHEASTERN STATES  PART C: TECHNICAL VALIDATION SOUTHEASTERN STATES  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE SOUTHEASTERN STATES   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Chloropicrin Objectionable odors in residential areas; little or nor efficacy on nutsedge ( Locascio 1997 & 1999); in some instances it caused increased emergence of nutsedge ( Motis and Gilreath 2002); very unlikely that the near perfect levels of disease and nematode control required by state certification programs cannot be attained throughout the 1 m. root zone. Chloropicrin is generally considered a good control measure for certain diseases ( Pythium, Phytophthora, Fusarium, Verticillium), but is not generally considered very effective for nematode or weed control. See also chloropicrin issues addressed in the fumigant combination entries in this section. No NON CHEMICAL ALTERNATIVES Biofumigation Lack of adequate data on the activity of biofumigation materials on nutsedge control; Based on studies with other crops, allelochemicals may cause phytotoxic effects ( Norsworthy 2002; Johnson et al. 1993); very unlikely that the near perfect level of disease and nematode control required by state certification programs can be attained throughout the 1m. deep root zone.

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

In addition, biofumigation is not technically feasible because the quantity of Brassica crop needed to control target pests would be approximately 3 hectares for every hectare of strawberry production. Incorporation of Brassica at these levels would be likely to have allelopathic effects on the target crop. In the Southeast, production field trials with cabbage residue and tomato produced inconsistent and inadequate efficacy, and poor yields in two years out of three. The yield losses could range from 0%  50%. No Page 15 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Solarization Even in warmer climates ( Georgia) it is impossible to attain temperatures lethal to nutsedge ( 50 55 ° C) at depths below 10 centimeters ( Miles et. al. 2002); near perfect level of disease and nematode control required by state certification programs very unlikely to be attained throughout the 1 m. deep root zone.

Solarization is not a technically feasible alternative because it does not provide adequate control of target pests to produce certifiable strawberry nursery stock. Use of solarization is not practical due to the depth of heating required to eliminate viable weed seed, nematodes, and disease organisms. The time for solarization to raise soil temperatures to the level needed to kill soil pathogens in any strawberry nursery region is likely to also be the time when the crops themselves must complete their growth cycle. Unpredictable, stormy summer weather still creates risks and may damage mulch. In one Southeast field trial, solarization gave poor yields in two years out of three with losses ranging from 0% to 40%. No General IPM Nothing available for control of nutsedge; near perfect level of disease and nematode control required by state certification programs very unlikely to be attained throughout the 1 m. root zone.

IPM, the use of pest monitoring activities coupled with chemical and non chemical management tools, has been adopted for management of weed, diseases, and nematodes on many crops. However, problematic weeds like nutsedge and nightshade, and soilborne diseases and nematodes are not effectively controlled by these practices in strawberry nurseries.

General IPM is being used in strawberry nursery stock production, but it is not technically feasible alone to provide adequate pest control. IPM practices include field sanitation to limit inoculum buildup, crop rotation to provide non host periods, and breeding for resistance to pathogens. No Page 16 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Cover crops mulching Cover crops/ mulching is currently being used but it is not technically feasible as a complete replacement for methyl bromide to control the target pest and certify the nursery stock; level of disease and nematode control required by state certification programs cannot be attained.

Cover crops/ mulching is currently being used but it is not technically feasible as a complete replacement for methyl bromide to control the target pests and certify the nursery stock. The use of cover crops is a common practice to improve soil structure and suppress an array of soilborne pathogens. Cover crops and mulches have been integrated into strawberry nursery crop production systems.

Some cover crops that have been shown to reduce weed populations also reduced or delayed crop maturity and/ or emergence, as well as yields ( Burgos et al., 1996; Galloway et al., 1996). Cowpea and sunn hemp have been shown to suppress nutsedge, but the effect is short lived, due to the weed's capacity for rapid tuber production. Allelochemicals released by some cover crops or organic mulches can injure crops ( Johnson et al., 1993; Norsworthy, 2002). No Page 17 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Crop rotation/ fallow Growers typically utilize this practice by growing other crops every 2 out of three years; this practice has not resulted in a level of disease and nematode control required by state certification programs throughout the 1 m. deep root zone; no suitable nutsedge controls available during production of the rotational crops ( Culpepper 2002).

A three year crop rotation/ fallow is being used in strawberry nursery stock production, but it is not technically feasible when used alone to control the key target pests.

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

There are registered herbicides that are effective for nutsedge control in agronomic crops. These herbicides are not available for most fruit or vegetable crops, and many of them have 12 to 26 month carryover restrictions for vegetable crops.

Crop rotation and fallow will not suppress nutsedge. Johnson & Mullinix ( 1997) showed that uninterrupted plantings of peanut, corn, or cotton, with moderate levels of weed management suppressed yellow nutsedge in Georgia. Their data also showed an increase in nutsedge densities in fallow plots, likely due to the longevity of nutsedge tubers in soil, mild winters that prevent winter kill of tubers, and the ability of tubers to regenerate with the long growing season in the southeastern coastal plain. There are also reports of increasing populations of yellow nutsedge in fallowed fields, even when weed control/ management is performed. Since there are no herbicides registered for use on strawberry plants that will effectively control nutsedge, management of these weeds during short term rotations and fallow is not effective. No Soilless culture Soilless culture is not being used and it is not technically feasible because it requires a complete transformation of the U. S. production system. There are high costs associated with this as compared to current production practices.

Soilless culture is not being used and it is not technically feasible because it requires a complete transformation of the U. S. production system. There are high costs associated with this as compared to current production practices. According to data provided by The National Center for Food and Agricultural Policy, a greenhouse typically costs between US$ 12.5 million and US$ 20 million per hectare. Although yields obtained through greenhouse production are higher than yields of the best growers, the issue of capitalization for this and other Sectors make the alternative not practically feasible as a near term strategy to reduce reliance on methyl bromide.. No Page 18 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Substrates/ plug plants grown hydroponically Even if effective, it would be cost prohibitive to change over to the required technology.

Substrates/ plug plants are currently being produced and sold in the southeast and to a very limited extent in California but this method alone does not provide pest control and would fail to produce a pest free product. Furthermore, this method would require extensive retooling by the nursery industry. No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin Little or no efficacy on nutsedge ( Locascio 1997 & 1999); level of disease and nematode control required by state certification programs cannot be attained throughout the 1 m. deep root zone; may be the best alternative where nutsedge is not a problem ( 50% of production area).

The combination of 1,3 D and chloropicrin is not technically feasible because it does not adequately control nematodes and diseases to the level required by various state laws, and results in yield losses in nursery plants. 1,3 D provides good nematode control, only moderate disease control, and poor weed control. A 30.5 meter ( 100 feet) 1,3 D buffer requirement, to mitigate area resident exposure, would be particularly constraining on smaller fields in predominantly urban fringe areas, which is typical for the Southeastern U. S. growers. Personal Protective Equipment ( PPE) requirements also limit operations that require workers in the field, particularly given the high temperatures which occur in the southeast, which are exacerbated by high humidity. Workers wearing the required Personal Protective Equipment become at risk for possible heat exhaustion or heat stroke. For example, PPE may require applicators to wear fully sealed suits, with respirators. Such suits do not have refrigeration components, and under conditions of high heat and humidity, rapidly become unbearable for a typical applicator. Growers believe that the requirements for buffers and PPE may make it impractical to adopt 1,3 D. The buffer requirements, especially for the small acreage farms in the Southeastern U. S., eliminate so much area around the perimeter of a field that there is very little left that can be treated using 1,3 D alone to grow strawberries. Chloropicrin provides good disease control, but poor nematode and weed control. Workers complain about eye and lung irritation when applying chloropicrin, which is virtually the same as tear gas. No Page 19 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

1,3 D + chloropicrin + metam sodium Little or no efficacy on nutsedge; very unlikely that the near perfect levels of disease and nematode control required by state certification programs cannot be attained throughout the 1 m. root zone. The combination of 1,3 D, chloropicrin and metam sodium is not technically feasible because it does not adequately control pests and diseases to the level required by various state laws, and therefore this decrease in efficacy results in yield losses in nursery plants. 1,3 D is a good nematicide and chloropicrin is a good fungicide. Metam sodium provides moderate but unpredictable disease, nematode, and weed control since it suffers from erratic efficacy, most likely due to irregular distribution of the product through soil. Metam sodium degrades in the soil to form methylisothiocyanate, which has activity against nematodes, fungi, insects, and weeds. Methyl bromide has a higher vapor pressure than metam sodium, therefore can penetrate and diffuse throughout the soil more effectively than metam sodium. In addition, the effectiveness of metam sodium is very dependent on the organic matter and moisture content of the soil. Studies to evaluate best delivery systems for metam sodium are being conducted. Some studies have shown that soil injections and drenches are more effective than drip irrigation. Research trials show that incorporation of metam sodium with a tractor mounted tillovator provides good results but most growers do not have this equipment.

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

The combination of the three chemicals would still require a companion herbicide or hand weeding. Failure to control the full spectrum of weeds could lead to increased disease pressure over time because the weeds can be reservoirs for disease or harbors insect vectors of disease. Also, in strawberry fruit production, there is demand for pest free strawberry root stock. The nursery growers who do not supply this type of product will be forced out of the market. No Page 20 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

1,3 D + metamsodium 1,3 D or metam sodium possess little or no efficacy on nutsedge ( Webster et. al. 2001); metam component is likely to provide inconsistent nematode, weed and disease control due to poor movement within soil; very unlikely that the near perfect levels of disease and nematode control required by state certification programs can be attained with this combination throughout the 1 m. deep root zone. The combination of 1,3 D and metam sodium is not technically feasible because it does not adequately control pests and diseases to the level required by various state laws, and results in yield losses in nursery plants. 1,3 D is a good nematicide and metam sodium provides moderate but unpredictable disease, nematode, and weed control. As indicated above, metam also suffers from erratic efficacy, most likely due to irregular distribution of the product through soil. The combination of these chemicals would still require a companion herbicide or hand weeding. Failure to control the weed seed in soil would most likely lead to increased disease pressure over time. Also, in strawberry fruit production, there is demand for pest free strawberry root stock. The nursery growers who do not supply this type of product will be forced out of the market.

As with the other suggested combinations ( above) there are issues with the use of Personal Protective Equipment ( PPE) in the hot or hot and humid climates of California and the southeastern U. S. In addition, the buffer requirement of 90 meters ( 300 feet) would be particularly constraining on smaller fields in predominantly urban fringe areas. For small strawberry nursery operations in the southeastern U. S., the 1,3 D buffer requirements eliminate a large area around the field perimeter which impacts the total acreage available for strawberry nursery production.

Sequential application of each one of these chemicals requires significantly more time than using methyl bromide alone since growers must wait longer after fumigation to put the strawberry root stock in the ground. Growers have a greater planting delay for several weeks, which will extend their production schedule. This delay directly impacts cultivar options, Integrated Pest Management practices, timing of planting and harvest for strawberry fruit production, marketing window options, land leasing decisions, and subsequent crop rotation schedules. Since growers will require rootstock at a fixed time during the year, the nursery plants could be of lower grade and quality ( smaller) causing loss to both the nursery grower and the fruit grower. No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. Page 21 SOUTHEASTERN STATES  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE SOUTHEASTERN STATES   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Other fungicides, herbicides, or nematicides. There are no other pesticides ( with the exception of iodomethane) in the registration process that can take the place of methyl bromide.

SOUTHEASTERN STATES  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS. OF ANY CURRENT AND POTENTIAL ALTERNATIVES SOUTHEASTERN STATES   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Iodomethane Not registered for any crop uses in the US. Yes Unknown Propargyl bromide Registration in the U. S. has not yet been requested. Comparative performance data not presented in any of the studies submitted. No Unknown Sodium azide Registration in the U. S. has not yet been requested. No Unknown Page 22 SOUTHEASTERN STATES  16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED Preamble  The following is the only directly relevant study conducted thus far in the southeastern states. Another study conducted in 2003 is nearing completion. Neither study utilizes methyl bromide ( MB) as the comparative treatment, but rather uses methyl iodide ( MI) as the principal alternative and compares it to Telone C 35 and an untreated control. Based on researchers' opinions from numerous studies, MI when used as a soil fumigant generally provides yields and levels of pest control comparable to methyl bromide. Accordingly, we assumed that the results of the available study are representative of previous studies and can be relied upon for assessing the comparative value of the best available alternative ( 1,3 D + 35% chloropicrin).

Given the soil types present in production areas the root zone required to be protected is generally as deep as 3 feet. Although several of the alternatives provide adequate levels of pest control at shallower depths, none consistently provide suitable control levels at 3 feet. Failure to provide levels of pest control at the required depth will result in inadequate levels of control which will result in rejection of the plants produced under these conditions ( 100% loss in affected fields). Accordingly, the maximum loss estimate is listed as 100% because the various State certification requirements which equate to a zero tolerance for disease symptoms and nematodes.

SOUTHEASTERN STATES   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES CERTAIN WEEDS % MB Pest Control Treatment Application Rate ( kg/ ha) Nem. Dis. Weeds % MB Yield Comments Methyl Iodide ( 100%) 263 NQ NQ Assume 100% Assume 100% No methyl bromide tested Methyl Iodide/ Chloropicrin ( 75: 25) 263/ 66 NQ NQ 92% 81%

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

Source: Gilreath, J. P., E. B. Poling, J. W. Noling, 2001, unpublished study Key to Table Abbreviations: NQ = not quantified ( too low and non uniform); Nem. = nematodes; Dis. = diseases MI alone yield was statistically higher than the combination with chloropicrin ( CP) and the 1,3 D/ CP treatments. There was no statistical difference between these later two treatments, however, they both provided statistically higher yields than the untreated controls. The prominent weeds present were hairy galinsoga ( Galinsoga cillata), carpetweed ( Mollugo verticillata), and purslane ( Portulaca oleracea). The most difficult weed to control was hairy galinsoga, with MI alone providing the highest levels of control of this as well as the other Page 23 weeds. The post treatment disease and nematode incidence data were too variable and too low in any of the plots to formulate any conclusions. The yield benefit exhibited by MI is likely to be a combination of weed control plus control of other unidentified microbial pests. The comparative weed control percentages are based solely on control of hairy galinsoga. Note: Another similar study was initiated in 2003 and was near completion in December 2003.

SOUTHEASTERN STATES   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D/ chloropicrin ( Telone C 35) Certain Weeds ( see above table) 0 27% 10%

Metam Sodium Certain Weeds ( see above table) 50%

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 10%

SOUTHEASTERN STATES  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE Iodomethane is in a pending registration status and is being evaluated as an alternative. It is generally considered to be as efficacious as methyl bromide for most preplant crop uses and virtually all pests. Growers can easily transition to this alternative.

Dazomet is also in a pending registration status as a nematicide on strawberries. Based on previous studies on other crops, it is reportedly not likely to be a suitable alternative for strawberry nurseries.

SOUTHEASTERN STATES  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE We are not aware of any that are feasible in the short run. The technology changeover costs for adopting soilless culture techniques are extremely high. Although yields reportedly obtained through greenhouse production are higher than that of the best conventional growers, the issue of capitalization for this and other sectors make the alternative not practically feasible as a near term strategy to reduce reliance on methyl bromide. No information was presented on the long term viability of this option. Reportedly, the organic strawberry fruit production growers are dependent upon methyl bromide treated transplants.

SOUTHEASTERN STATES  SUMMARY OF TECHNICAL FEASIBILITY None are considered technically feasible at the present time due to the high levels of disease and nematode control required by the current state certification standards.

Since chloropicrin is virtually the same as tear gas worker eye irritation concerns exist for this option. Page 24 CALIFORNIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE NEEDED California Diseases: Phytophthora Crown and Root Rots ( Phytophthora spp.); Red Stele ( Phytophthora fragariae); Verticillium Wilt ( Verticillium dahliae); and possibly others Nematodes: Root knot ( Meloidogyne spp.); sting ( Belonolaimus spp.); dagger ( Xiphinema spp.); lesion ( Pratylenchus spp.); foliar ( Aphelenchoides spp.); needle ( Longidorus spp.); stem ( Ditylenchus spp.)

Weeds: numerous weeds listed ( e. g., annual bluegrass, bur clover, carpetweed, chickweed, field bindweed, goat grass, hairy nightshade, lambsquarter, malva, nutsedge, pig weed, portulaca, prostate spurge, puncture vine, purslane, vetch) The State mandatory certification program has strict requirements for control of diseases and nematodes which amount to virtually complete control of the key pests. Given the growing situations encountered over the course of the 5 year transplant production cycle ( a different growing location is used each year), none of the alternatives have thus far been shown to be consistently perform at a highly effective level at soil depths to 3 feet.

Methyl iodide is considered by most researchers to be viable potentially alternative, which is currently proposed for registration in the US.

CALIFORNIA   11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE CALIFORNIA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS CALIFORNIA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Strawberry transplants ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual crop, only planted in the same location once every three years TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) The principal rotational crops are endive, garlic, onion, horseradish, mint, alfalfa, sugarbeets, and potatoes.

SOIL TYPES: ( Sand, loam, clay, etc.) 80 % light soils, 10% medium soils and 10% heavy soils; 70% with 2% or less organic matter FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Every year OTHER RELEVANT FACTORS: No Page 25 CALIFORNIA ( LOW ELEVATION AREAS; YEARS 3 & 4)  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) 6a, 6b, 7a, 9a, 9b RAINFALL ( mm) 16 72.1 17.3 0 trace 1.0 trace 0 44.7 56.9 9.9 30.5 OUTSIDE TEMP. ( ° C) 14.4 14.8 20.8 25.7 30.3 27.4 25.1 18.4 13.4 9.6 10.3 10.6 FUMIGATION SCHEDULE X PLANTING SCHEDULE X X HARVEST SCHEDULE X * For Fresno, California.

CALIFORNIA ( HIGH ELEVATION AREAS; YEAR 5)  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) 6a, 6b, 7a, 9a, 9b FUMIGATION SCHEDULE X X PLANTING SCHEDULE X HARVEST SCHEDULE X X X CALIFORNIA   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

None were identified as being limiting factors. Page 26 CALIFORNIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 1,128 1,153 1,267 1,283 1,295 1,477 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED All Flat fumigation All Flat fumigation All Flat fumigation All Flat fumigation All Flat fumigation All Flat fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 308,860 313,200 341,230 337,604 341,022 389,069 FORMULATIONS OF METHYL BROMIDE ( e. g. methyl bromide 98: 2; methyl bromide / chloropicrin 70: 30) 67: 33 67: 33 67: 33 67: 33 67: 33 67: 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection Flat fumigation soil injection APPLICATION RATE OF FORMULATIONS IN kg/ ha* 411 408 404 395 395 395 APPLICATION RATE OF METHYL BROMIDE IN kg/ ha* 274 272 269 263 263 263 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 41.1 40.8 40.4 39.5 39.5 39.5 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 27.4 27.2 26.9 26.3 26.3 26.3 * For Flat fumigation treatment application rate and dosage rate may be the same. Page 27 CALIFORNIA  PART C: TECHNICAL VALIDATION CALIFORNIA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE Please see the description of the alternatives not being feasible under the Southeastern U. S. above.

CALIFORNIA  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE CALIFORNIA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION Please see the description of the technically infeasible alternatives discussion under the Southeastern U. S. above.

CALIFORNIA  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES CALIFORNIA   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS State if registered for this crop, registered for crop but use restricted, registered for other crops but not target crop, or not registered REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Iodomethane Not registered for any crop uses in the US. Generally considered an excellent potential alternative. Yes Unknown Sodium Azide Not submitted for registration. Comparative performance data not presented in any of the studies submitted. No Unknown Propargyl bromide Not submitted for registration. No Unknown CALIFORNIA  16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED Preamble   Although only several studies are represented in the Tables below, numerous studies have been conducted and referenced ( see section 26) in the two applications ( Southeastern States [ MD, NC, TN], and California). Given all the permutations of edaphic and pest variables Page 28 that exist in the production areas, it is of limited practical value to present a limited subset of the total number of studies as being indicative of the actual performance variability ranges of the alternatives. Given the time constraints associated with these requests, it is impossible to accurately present the finding of all relevant studies. However, after perusing a large number of these studies it is obvious that none of the alternatives can consistently provide sufficient control of the target pests ( comparable to levels and frequency attained with methyl bromide ( MB). This is especially true for those pests subject to the rigorous requirements of the State's nursery certification program ( virtually a zero tolerance for symptoms of soilborne diseases and the presence of plant parasitic nematodes in the soil). Even though most studies have shortcomings in terms of the procedures utilized and/ or the information reported, the aggregate conclusion is that none of the chemical and/ or non chemical alternatives will consistently achieve levels of pest control comparable to methyl bromide.

When one takes into account that the five year production system involves new planting sites each year, consistency is important in satisfying the needs of their international, interstate and intrastate customers. The inconsistency in performance of the alternatives most likely relates to the application methods, application rates, alternative( s) evaluates, formulations of alternatives utilized, soil conditions, and weather conditions which occurred, and pest species and levels present in tests.

Given the soil types present in production areas the root zone required to be protected is generally as deep as 3 feet. Although several of the alternatives provide adequate levels of pest control at shallower depths, none consistently provide suitable control levels at 3 feet. Failure to provide levels of pest control at the required depth will result in inadequate levels of control which will result in rejection of the plants produced under these conditions ( 100% loss in affected fields). Page 29 CALIFORNIA   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   Chemical Alternatives to Methyl Bromide Fumigation   How Well Do They Work?

Treatment Application Method & Rate ( kg/ ha) Pest Control (% of MB) Yield (% of MB) Comments NEM DIS. MB/ CP ( 67: 33) MB: 246kg/ ha; CP: 121 kg/ ha; chisel injection & tarped + + 100 1,3 D/ CP ( 70: 30) 1,3 D: 361 kg/ ha; CP: 155 kg/ ha; chisel injection & tarped + + 96 Chloropicrin ( CP) 95 189; and 190 and higher; chisel injection & tarped + + 89 (< 190kg/ ha);

103 (> 190 kg/ ha) Evaluated both low and high dosage rates Metam Sodium 950 kg/ ha; surface drench and tarped + + 92 Dazomet 340 kg/ ha; bdcst, tilled into soil, and tarped + + 95 Enzone ( sodium tetra thiocarbonate) 2.85 kg/ ha tarped + + 80 Not registered for use on strawberries UTC + + 70 Source: Gubler, W. D., J. M. Duniway, and N. Welch. 1996. Chemical Alternatives to Methyl Bromide Fumigation   How Well Do They Work?

Key to Abbreviations: 1,3 D = 1,3 dichloropropene; MB = methyl bromide; CP = chloropicrin; MS = metam sodium; UTC = untreated control; Nem. = nematodes; Dis. = diseases; bdcst = broadcast application.

Watsonville, CA 1993 study using large scale plots; low levels of Phytophthora crown and root rot, Verticillium wilt, and nematodes; one year evaluation only Page 30 CALIFORNIA   TABLE 16.2: EFFECTIVENESS OF ALTERNATIVES Chloropicrin Effect on Weed Seed Viability.

Control Measures Evaluated Application Method & Rate ( kg/ ha) Weed Control (% of MB) Comments MB/ CP ( 67: 33) MB: 225 kg/ ha CP: 111 kg/ ha; soil injection 100 Very good control of 3 weeds; no control of 2 weeds ( mallow & filaree)

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

MS plus CP MS: 197kg / ha drip irrigation; CP: 83   220 kg/ ha soil injection Very Comp. produced a slight increase in weed control over MS alone = best available treatment for the weed species present Chloropicrin ( CP) CP: 83   220 kg/ ha soil injection Comp. good control of 3 weeds at the higher rates; no control of 2 weeds ( mallow & filaree)

UTC none Source: Haar, M. J., S. A. Fennimore, H. A. Ajwa, C. Q. Winterbottom. 2003. Chloropicrin Effect on Weed Seed Viability. Key to Abbreviations: CP = chloropicrin; MS = metam sodium; 1,3 D = 1,3 dichloropropene; UTC = untreated controls; Comp = comparable.

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

CALIFORNIA   TABLE 16.3: EFFECTIVENESS OF ALTERNATIVES  Soil Fumigation and Runner Plant Production.

Treatment Application Method & Rate ( kg/ ha) Yield (% of MB) Comments Methyl bromide Chisel 100 ( 4 trials)

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

Chloropicrin   300 kg/ ha, Chisel; 86   100 ( 4 trials) Appeared to be the best of the alternatives evaluated 1,3 D/ Chloropicrin ( 70: 30) Chisel; 84 ( 1 trial) Did not rank very high as an alternative due to reduced plant growth and runner production 1,3 D/ Chloropicrin ( 30: 70) Chisel 91 ( 1 trial) Appeared to perform similar to the high rate of chloropicrin UTC Not Applicable 38 55 ( 4 trials) Page 31 Source: Larson, K. D. and D. V. Shaw, 2000, Soil Fumigation and Runner Plant Production: A Synthesis of Four Years of Strawberry Nursery Field Trials, Hort Sci. 35 ( 4): 642 646. Key to Abbreviations: 1,3 D = 1,3 dichloropropene; UTC = untreated controls.

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

CALIFORNIA   TABLE 16.4: EFFECTIVENESS OF ALTERNATIVES  Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries Treatment Application Method & Rate ( kg/ ha) Nematode Control (% of MB)

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

CP: 151 kg/ ha 100 1,3 D/ CP ??? plus m s??? 1,3 D: 518 kg/ ha;

CP: 283 kg/ ha 83 100 1,3 D + Metam Sodium Sequential application; 1,3 D: 518 kg/ ha;

MS: ?? kg/ ha. 16 100 1,3 D/ dazomet Sequential application; 396 kg/ ha; 224 kg/ ha DZ 28 100 Source: McKenry, M. V., 2001. Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries, California Department of Pesticide Regulation ( Contract # 99 0218).

Key to Abbreviations: 1,3 D = ; CP = ; MB = ; DZ = dazomet; Prominent nematode pests present: lesion ( Pratylenchus spp.), spiral ( Helicotylenchus dihystera), dagger ( Xiphinema americanum) and some root knot ( Meloidogyne spp.) Page 32 CALIFORNIA   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D/ Chloropicrin Certain weeds 0 27% 10% 1,3 D + Metam Sodium Certain weeds  13%

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 10 13%

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

California Table 15.1 for status of iodomethane. This fumigant is unregistered, but is reported to be a potential suitable alternative for all key pests.

Dazomet is also in a pending registration status as a nematicide on strawberries. Based on previous studies on other crops, it is reportedly not likely to be a suitable methyl bromide alternative for strawberry nurseries.

CALIFORNIA  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE We are not aware of any current or near future technologies that are technically and/ or economically feasible. Some people consider soilless hydroponic culture as a possible long term option. Although this technique could eliminate all or most of the typical soilborne pests currently controlled by methyl bromide. However, new pests may become problematic, which may/ may not be controllable with available pesticides.

CALIFORNIA  SUMMARY OF TECHNICAL FEASIBILITY None are considered technically feasible at the present time due to the high levels of disease and nematode control required by the current state certification standards, which equate to virtually complete control of all damaging disease and nematode pests. Buffer zones and regulatory constraints are only secondary concerns, since none of the available alternatives can provide suitable pest control at root zone depths to 1 meter. Page 33 PART D: EMISSION CONTROL 19. TECHNIQUES THAT HAVE AND WILL BE USED TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS IN THE PARTICULAR USE TABLE 19.1: TECHNIQUES TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS 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. Between 1997 and 2002 the dosage rate of methyl bromide has dropped by one eighth. All use 67: 33 Unidentified WHAT FURTHER USE/ EMISSION REDUCTION STEPS WILL BE TAKEN FOR THE METHYL BROMIDE USED FOR CRITICAL USES? Research is underway to develop use in commercial production systems Possible changeover from broadcast to raised bed band treatments, Unidentified The U. S. anticipates that the decreasing supply of methyl bromide will motivate growers to try less frequent applications.

OTHER MEASURES ( please describe) Examination of promising but presently unregistered alternative fumigants with non chemical methods. Unidentified Unidentified Unidentified 20. IF METHYL BROMIDE EMISSION REDUCTION TECHNIQUES ARE NOT BEING USED, OR ARE NOT PLANNED FOR THE CIRCUMSTANCES OF THE NOMINATION, STATE REASONS In accordance with the criteria of the critical use exemption, each party is required to describe ways in which it strives to minimize use and emissions of methyl bromide. The use of methyl bromide in the growing of strawberry nurseries in the United States is minimized in several ways. First, because of its toxicity, methyl bromide has, for the last 40 years, been regulated as a restricted use pesticide in the United States. As a consequence, methyl bromide can only be used by certified applicators who are trained at handling these hazardous pesticides. In practice, this means that methyl bromide is applied by a limited number of very experienced applicators with the knowledge and expertise to minimize dosage to the lowest level possible to achieve the needed results. In keeping with both local requirements to avoid " drift" of methyl bromide into inhabited areas, as well as to preserve methyl bromide and keep related emissions to the lowest level possible, methyl bromide application for strawberry nurseries is most often machine injected into soil to specific depths. Page 34 As methyl bromide use has become scarcer, users in the United States have, where possible, experimented with different mixes of methyl bromide and chloropicrin. Specifically, in the early 1990s, methyl bromide was typically sold and used in methyl bromide mixtures made up of 95% methyl bromide and 5% chloropicrin, with the chloropicrin being included solely to give the chemical a smell enabling those in the area to be alerted if there was a risk. However, with the outset of very significant controls on methyl bromide, users have been experimenting with significant increases in the level of chloropicrin and reductions in the level of methyl bromide. While these new mixtures have generally been effective at controlling target pests, at low to moderate levels of infestation, it must be stressed that the long term efficacy of these mixtures is unknown.

Tarpaulin ( high density polyethylene) is also used to minimize use and emissions of methyl bromide. In addition, cultural practices are utilized by strawberry nursery growers.

Reduced methyl bromide concentrations in mixtures, cultural practices, and the extensive use of tarpaulins to cover land treated with methyl bromide has resulted in reduced emissions and an application rate that we believe is among the lowest in the world for the uses described in this nomination.

PART E: ECONOMIC ASSESSMENT 21. COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD:

TABLE 21.1: COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Methyl Bromide 100 1,806 1,806 1,806 Metam Sodium 50 3,187 3,187 3,187 1,3 d+ pic 90 4,774 4,774 4,774 Chloropicrin 95 5,419 5,419 5,419 1,3 d+ Metam Sodium 86 5,317 5,317 5,317 * As percentage of typical or 3 year average yield, compared to methyl bromide CALIFORNIA 22. GROSS AND NET REVENUE CALIFORNIA TABLE 22.1: YEAR 1 GROSS AND NET REVENUE YEAR 1 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide 41,019 11,879 Metam Sodium   1,3 d+ pic 36,918 4,670 Chloropicrin 38,968 8,112 1,3 d+ Metam Sodium 35,892 5,137 Page 35 CALIFORNIA TABLE 22.2: YEAR 2 GROSS AND NET REVENUE YEAR 2 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide 41,019 11,879 Metam Sodium   1,3 d+ pic 36,918 4,670 Chloropicrin 38,968 8,112 1,3 d+ Metam Sodium 35,892 5,137 CALIFORNIA TABLE 22.3: YEAR 3 GROSS AND NET REVENUE YEAR 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide 41,019 11,879 Metam Sodium   1,3 d+ pic 36,918 4,670 Chloropicrin 38,968 8,112 1,3 d+ Metam Sodium 35,892 5,137 SOUTHEASTERN STATES 22. GROSS AND NET REVENUE SOUTHEASTERN STATES TABLE 22.1: YEAR 1 GROSS AND NET REVENUE YEAR 1 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide 42,008 11,763 Metam Sodium 21,004  8,923 1,3 d+ pic 37,807 6,294 Chloropicrin 39,907 7,749 1,3 d+ Metam Sodium

SOUTHEASTERN STATES TABLE 22.2: YEAR 2 GROSS AND NET REVENUE YEAR 2 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide 42,008 11,763 Metam Sodium 21,004  8,923 1,3 d+ pic 37,807 6,294 Chloropicrin 39,907 7,749 1,3 d+ Metam Sodium

SOUTHEASTERN STATES TABLE 22.3: YEAR 3 GROSS AND NET REVENUE Page 36 YEAR 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide 42,008 11,763 Metam Sodium 21,004  8,923 1,3 d+ pic 37,807 6,294 Chloropicrin 39,907 7,749 1,3 d+ Metam Sodium   Page 37 SOUTHEASTERN STATES  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES SOUTHEASTERN STATES METHYL BROMIDE ALTERNATIVE METAM ALTERNATIVE 1,3 D+ PIC YIELD LOSS (%) 0 50 10 YIELD PER HECTARE ( PLANTS) 211,715 105,857 190,543 * PRICE PER UNIT ( US$) .20 .20 .20 = GROSS REVENUE PER HECTARE ( US$) 42,008 21,004 37,807  OPERATING COSTS PER HECTARE ( US$) 30,245 29,927 31,513 = NET REVENUE PER HECTARE ( US$) 11,763  8,923 6,294 LOSS MEASURE 1. LOSS PER HECTARE ( US$) $ 0 $ 20,686 $ 5,469 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 50.15 13.26 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 49% 13%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 176% 46%

CALIFORNIA  TABLE E. 2: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA METHYL BROMIDE ALTERNATIVE 1,3 D METAM ALTERNATIVE 1,3 D+ PIC YIELD LOSS (%) 0 13% 10%

YIELD PER HECTARE ( BOXES) 332 291 299 * PRICE PER UNIT ( US$) 50 50 50 = GROSS REVENUE PER HECTARE ( US$) 41,019 35,892 36,918  OPERATING COSTS PER HECTARE ( US$) 29,141 30,755 32,247 = NET REVENUE PER HECTARE ( US$) 11,879 5,137 4,670 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 6,741 7,208 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 25.59 27.37 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 16% 18%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 57% 61% Page 38 SUMMARY OF ECONOMIC FEASIBILITY The economic analysis compared the costs of methyl bromide alternative control scenarios for the Southeastern Strawberry Consortium and the California Strawberry Growers Association to the baseline costs for methyl bromide. The economic estimates were first calculated in pounds and acres and then converted to kilograms and hectares. The costs for the alternatives are based on market price for the control products multiplied by the number of pounds of active ingredient that would be applied. The baseline costs were based on the average number of applications to treat strawberry plants ( boxes) with methyl bromide per year. The loss per hectare measures the value of methyl bromide based on changes in operating costs and/ or changes in yield. The loss expressed as a percentage of the gross revenue is based on the ratio of the revenue loss to the gross revenue. Likewise for the loss as a percentage of net revenue. The profit margin percentage is the ratio of net revenue to gross revenue per hectare.

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

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

One of the issues facing nursery growers is that pest infestation can wipe out production for the season. If there are quality concerns such as disease, weeds, or insect infestation growers will not be able to market their seedlings. Fruit producers are not willing to purchase plants that have any visual symptoms of disease and may hold the nursery responsible for any disease that shows up during fruiting in the field in the first weeks after planting. Nearly a billion plants are produced by the California strawberry nursery system alone each year and this production is distributed world wide. There are approximately 13 seedling/ runner producers in California that must manage disease incidence over the 4 year production cycle of the strawberry stock. Without data to illustrate the impacts of a growers stock being wiped out, we assumed that if an estimated 10% of the root stock is contaminated this would directly reduce the yield by that amount. Clearly this would have a detrimental impact on the entire industry as the yield losses would be in addition to the yield losses generated by the change to alternative chemical controls. Yield losses on a hectare basis could range from 15 60% reflecting lower yields from alternative control and loss of the nursery supply. However, a more likely scenario is that several growers in a region would suffer pathogen or insect infestation and that the entire stock for those growers cannot be marketed, yield losses would be much higher.

Southeastern States: Under Alternative 1 ( Metam sodium), yield loss was estimated to be 50%, which translates into a 49% loss in gross revenues. With operating costs in U. S. dollars per hectare of $ 29,927, the estimated net revenue was $ 8,923 per hectare, or a loss of 176%. The loss per hectare is estimated to be $ 20,686. The loss per kilogram of methyl bromide in U. S. dollars is estimated to be $ 50.15 per kilogram. Page 39 Under alternative 2 ( 1,3 d + chloropicrin), the yield loss was estimated to be 10% and the loss a percent of gross revenue was 13%. Operating costs in U. S. dollars per hectare are $ 31,513. The estimated net revenue was $ 6,294 per hectare, or a loss of 46%. The loss per hectare is estimated to be $ 5,469. The loss per kilogram of methyl bromide in U. S. dollars is estimated to be $ 13.26 per kilogram.

Under alternative 3 ( chloropicrin alone), the yield loss was estimated to be 5%. Operating costs in U. S. dollars per hectare are $ 32,158. The estimated net revenue was $ 7,749 per hectare. The loss per hectare is estimated to be $ 4,014. The loss per kilogram of methyl bromide in U. S. dollars is estimated to be $ 9.73 per kilogram.

California: Alternative 1 ( Metam sodium), yield was assumed to be 13% with operating costs in U. S. dollars per hectare of $ 30,755. The estimated net revenue was $ 5,137 per hectare. The loss per hectare is estimated to be $ 6,741. The loss per kilogram of methyl bromide in U. S. dollars is estimated to be $ 25.59 per kilogram.

Under alternative 2 ( 1,3 d + chloropicrin), the yield loss was estimated to be 10%. Operating costs in U. S. dollars per hectare are $ 32,247. The estimated net revenue was $ 4,670 per hectare. The loss per hectare is estimated to be $ 7,208. The loss per kilogram of methyl bromide in U. S. dollars is estimated to be $ 27.37 per kilogram.

Under alternative 3 ( chloropicrin), the yield loss was estimated to be 5%. Operating costs in U. S. dollars per hectare are $ 30,856. The estimated net revenue was $ 8,112 per hectare. The loss per hectare is estimated to be $ 3,766. The loss per kilogram of methyl bromide in U. S. dollars is estimated to be $ 14.30 per kilogram. Page 40 PART F. FUTURE PLANS 23. WHAT ACTIONS WILL BE TAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS CROP? The available alternatives are currently all considered unsuitable. Continued testing for 5 to 10 years may be required to explore new or improved application techniques that may be considered suitable. Combinations of several chemical and non chemical controls may ultimately be needed along with application technique changes.

Since 1997, the United States EPA has made the registration of alternatives to methyl bromide a high registration priority. Because the EPA currently has more applications pending in its registration review queue than the resources to evaluate them, EPA prioritizes the applications. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for the EPA to initiate its review.

As one incentive for the pesticide industry to develop alternatives to methyl bromide, the Agency has worked to reduce the burdens on data generation, to the extent feasible while still ensuring that the Agency's registration decisions meet the Federal statutory safety standards. Where appropriate from a scientific standpoint, the Agency has refined the data requirements for a given pesticide application, allowing a shortening of the research and development process for the methyl bromide alternative. Furthermore, Agency scientists routinely meet with prospective methyl bromide alternative applicants, counseling them through the preregistration process to increase the probability that the data is done right the first time and rework delays are minimized The U. S. EPA has also co chaired the USDA/ EPA Methyl Bromide Alternatives Work Group since 1993 to help coordinate research, development and the registration of viable alternatives. This coordination has resulted in key registration issues ( such as worker and bystander exposure through volatilization, township caps and drinking water concerns) being directly addressed through USDA's Agricultural Research Service's U. S.$ 15 million per year research program conducted at more than 20 field evaluation facilities across the country. Also EPA's participation in the evaluation of research grant proposals each year for USDA's U. S.$ 2.5 million per year methyl bromide alternatives research has further ensured close coordination between the U. S. government and the research community.

The amount of methyl bromide requested for research purposes is considered critical for the development of effective alternatives. Without methyl bromide for use as a standard treatment, the research studies can never address the comparative performance of alternatives. This would be a serious impediment to the development of alternative strategies. The U. S. government estimates that strawberry nurseries research will require 454 kg per year of methyl bromide for 2005 and 2006. This amount of methyl bromide is necessary to conduct research on alternatives and is in addition to the amounts requested in the submitted CUE applications. One example of the research is a three year study testing the comparative performance of methyl bromide, alternative fumigants, preplant fungicide dips, post plant fungicides, Page 41 germplasm, microbial inoculants, and cultural practices. The amount of methyl bromide requested for research purposes is considered critical for the development of effective alternatives. Without methyl bromide for use as a standard treatment, the research studies can never address the comparative performance of alternatives. This would be a serious impediment to the development of alternative strategies. The U. S. government estimates that strawberry nurseries research will require 454 kg per year of methyl bromide for 2005 and 2006. This amount of methyl bromide is necessary to conduct research on alternatives and is in addition to the amounts requested in the submitted CUE applications. One example of the research is a three year study testing the comparative performance of methyl bromide, alternative fumigants, preplant fungicide dips, post plant fungicides, germplasm, microbial inoculants, and cultural practices 24. HOW DO YOU PLAN TO MINIMIZE THE USE OF METHYL BROMIDE FOR THE CRITICAL USE IN THE FUTURE?

The U. S. wants to note that our usage rate is among the lowest in the world in requested sectors and represents efforts of both the government and the user community over many years to reduce use rates and emissions. We will continue to work with the user community in each sector to identify further opportunities to reduce methyl bromide use and emissions. .

25. ADDITIONAL COMMENTS ON THE NOMINATION?

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

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

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

Braun, A. L., D. M. Supkoff. 1994. Options to Methyl Bromide for the Control of Soil Borne Diseases and pests in California. Pest Management Analysis and Planning Program. Page 42 Browne, G. T., H. E. Becherer, M. R. Vazuesq, S. A. McGlaughlin, R. J. Wakeman, C. Q. Winterbottom, J. M. Duniway, S. A. Fennimore. 2001. Outlook for Managing Phytophthora Diseases on California Strawberries without Methyl Bromide. Report to DPR.

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

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

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

California Department of Food and Agriculture. 2003. Summary of California Laws and Regulations Pertaining to Nursery Stock.

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

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

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

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

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

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

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

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

Fennimore, S. A., M. J. Haar. 2003. Weed Control in Strawberry Provided by Shank and Drip applied Methyl Bromide Alternative Fumigants. HortSci. 38( l): 55 61 Fennimore, S. A., M. J. Haar, H. Ajwa. 1999. Weed Control Options in California Strawberry without Methyl Bromide. 1999 Annual International Research Conference on Methyl Bromide alternatives and Emissions Reductions. Page 43 Galloway, B. A., and L. A. Weston. 1996. Influence of cover crop and herbicide treatment on weed control and yield in no till sweet corn ( Zea mays L). and pimpkin ( Cucurbita maxima Dutch). Weed Technol. 7: 425 430 Gilreath, J. P., E. B. Poling, J. W. Noling. 2001. unpublished study.

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

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

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

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

Gubler, W. D., J. M. Duniway, N. Welch. 1996. Chemical Alternatives to Methyl Bromide fumigation  How Well Do They Work? Haglund, W. 1999. Metam Sodium and Metam Combinations a Viable Replacement for Methyl Bromide. 1999 Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions.

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

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

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

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

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

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

Larsen, K. D., D. V. Shaw. 2000. Soil Fumigation and Runner Plant Production: A Synthesis of 4 Yrs of Strawberry Nursery Field Trials. HortSci 35( 4): 642 646. Page 44 Locascio, S. J., J. P. Gilreath, D. W. Dickson, T. A. Kucharek, J. P. Jones, and J. W. Noling. 1997. Strawberry production with alternatives to methyl bromide fumigation. 1997 Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions.

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

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

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

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

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

McKenry, M. 2001. Evaluation of Alternatives to Methyl Bromide for soil Fumigation at Commercial Fruit and Nut Tree Nurseries. California Department of Pesticide Regulation. Contract # 99 0218. 29 pgs. McKenry, M. 1999. The Replant Problem and Its Management. Catalina Publishing. 124 pgs.

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

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

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

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

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

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

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

Paulus, A., M. Vilchez, M. Coffey. 1998. Alternatives to Methyl Bromide for Soil fumigation. California Strawberry Commission Pink Sheet 98 1. 1 pg. Page 45 Sances, F. 2000. Plug Plant and Soil Amendment Technology as Alternatives to Methyl Bromide Fumigation on California Strawberries. Report for California Department of Pesticide Regulation. Contract no. 98 0283. 14pgs.

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

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

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

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

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

Trout, T. 2001. Impact of Townships Caps on Telone Use in California. California Strawberry Commission Pinksheet 01 09. 4pgs.

Trout, T. H. Ajwa. 1999. Strawberry Response to Fumigants Applied by Drip Irrigation Systems. 1999 Annual International Research Conference on methyl Bromide alternatives and Emissions Reductions, San Diego, California, November 1 4, 1999.

Welch, N. 1991 ' Soil Fumigation using Telone. California Strawberry Commission Pink Sheet. 2 pgs.

Westerdahl, B., B. Haglund, M. McKenry. 2002. Unpublished data from on going research trial with Shasta Nursery. Page 46 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI). 2001 & 2002 Average % of 2001 &

2002 Average not available not available not available not available not available not available Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha) % Reduction 53,751 204 263 88%

2,086 5 413 95%

55,837 209 267 88%

88% 88%

2006 Low High Low High Low High Low High Low High Low High Low 263 263 0 0 0 0 100 100 0 0 0 0 0 0 413 413 0 0 0 0 100 100 0 0 0 0 0 0 Strip Bed Treatment Currently Use Alternatives? Research /

Transition Plans Tarps /

Deep Injection Used Pest

free Cert.

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

State Frequency of Treatment Loss per Hectare (

US$/

ha) Loss per Kilogram of MeBr (

US$/

kg) Loss as a %

of Gross Revenue Loss as a %

of Net Revenue No Yes Yes Tarp Yes + Yes No Yes Yes Tarp Yes + Yes Conversion Units: 1 Pound = Kilograms Hectare Quality/ Time/ Market Window/

Yield Loss (%) Marginal Strategy 10% or 13 %

10% 1,3 D + Pic or 1,3 D + Metam 1,3 D + Pic Combined Impacts (%)

HIGH 100% 100% LOW 100% 100%

Regional Hectares**

% of Requested Hectares MOST LIKELY IMPACT VALUE not available not available not available not available Sector: STRAWBERRY NURSERY 2006 Methyl Bromide Usage Numerical Index ( BUNI) % of Average Hectares Requested: not available Date: 2/ 26/ 2004 Methyl Bromide Critical Use Exemption Process Average Hectares in the US:

2006 Amount of Request 2001 & 2002 Average Use* Quarantine and Pre Shipment Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha) Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha)

443,432 1,683 263 365,045 1,386 263 85%

41,453 100 413 28,499 69 413 89%

338 87%

TOTAL OR AVERAGE 484,884 1,784 338 393,544 1,455 () QPS HIGH LOW Subtractions from Requested Amounts ( kgs) Combined Impacts Adjustment ( kgs)

2006 Request () Double Counting () Growth or 2002 CUE Comparison () Use Rate Difference 443,432  85,094  304,587 53,751 53,751 41,453  22,489  16,878 2,086 2,086 Nomination Amount 484,884 484,884 377,301 377,301 55,837 55,837 55,837 (%) 100 ft Buffer Zones 88%

% Reduction from Initial Request 0% 0% 22% Cold Soil Temp (%)

REGION CALIFORNIA SOUTHEASTERN US CALIFORNIA 2006 Nomination Options 88%

(%) Key Pest Distribution Regulatory Issues (%) Unsuitable Terrain (%)

CALIFORNIA SOUTHEASTERN US REGION REGION REGION SOUTHEASTERN US CALIFORNIA SOUTHEASTERN US Other Considerations Adjustments to Requested Amounts 0.453592 1 Acre = 0.404686 22% 88% Economic Analysis Dichotomous Variables ( Y/ N) Other Issues Use Rate ( kg/ ha) (%) Karst Topography Page 47 Footnotes for Appendix A: Values may not sum exactly due to rounding. 1. Average Hectares in the US   Average Hectares in the US is the average of 2001 and 2002 total hectares in the US in this crop when available. These figures were obtained from the USDA National Agricultural Statistics Service. 2. % of Average Hectares Requested  Percent (%) of Average Hectares Requested is the total area in the sector's request divided by the Average Hectares in the US. Note, however, that the NASS categories do not always correspond one to one with the sector nominations in the U. S. CUE nomination ( e. g., roma and cherry tomatoes were included in the applicant's request, but were not included in NASS surveys). Values greater than 100 percent are due to the inclusion of these varieties in the U. S. CUE request that were not included in the USDA NASS: nevertheless, these numbers are often instructive in assessing the requested coverage of applications received from growers. 3. 2006 Amount of Request   The 2006 amount of request is the actual amount requested by applicants given in total pounds active ingredient of methyl bromide, total acres of methyl bromide use, and application rate in pounds active ingredient of methyl bromide per acre. U. S. units of measure were used to describe the initial request and then were converted to metric units to calculate the amount of the US nomination. 4. 2001 & 2002 Average Use   The 2001 & 2002 Average Use is the average of the 2001 and 2002 historical usage figures provided by the applicants given in total pounds active ingredient of methyl bromide, total acres of methyl bromide use, and application rate in pounds active ingredient of methyl bromide per acre. Adjustments are made when necessary due in part to unavailable 2002 estimates in which case only the 2001 average use figure is used. 5. Quarantine and Pre Shipment   Quarantine and pre shipment ( QPS) hectares is the percentage (%) of the applicant's request subject to QPS treatments. 6. Regional Hectares, 2001 & 2002 Average Hectares   Regional Hectares, 2001 & 2002 Average Hectares is the 2001 and 2002 average estimate of hectares within the defined region. These figures are taken from various sources to ensure an accurate estimate. The sources are from the USDA National Agricultural Statistics Service and from other governmental sources such as the Georgia Acreage estimates. 7. Regional Hectares, Requested Acreage %  Regional Hectares, Requested Acreage % is the area in the applicant's request divided by the total area planted in that crop in the region covered by the request as found in the USDA National Agricultural Statistics Service ( NASS). Note, however, that the NASS categories do not always correspond one to one with the sector nominations in the U. S. CUE nomination ( e. g., roma and cherry tomatoes were included in the applicant's request, but were not included in NASS surveys). Values greater than 100 percent are due to the inclusion of these varieties in the U. S. CUE request that were not included in the USDA NASS: nevertheless, these numbers are often instructive in assessing the requested coverage of applications received from growers. 8. 2006 Nomination Options   2006 Nomination Options are the options of the inclusion of various factors used to adjust the initial applicant request into the nomination figure. 9. Subtractions from Requested Amounts   Subtractions from Requested Amounts are the elements that were subtracted from the initial request amount. 10. Subtractions from Requested Amounts, 2006 Request   Subtractions from Requested Amounts, 2006 Request is the starting point for all calculations. This is the amount of the applicant request in kilograms. 11. Subtractions from Requested Amounts, Double Counting  Subtractions from Requested Amounts, Double Counting is the estimate measured in kilograms in situations where an applicant has made a request for a CUE with an individual application while their consortium has also made a request for a CUE on their behalf in the consortium application. In these cases the double counting is removed from the consortium application and the individual application takes precedence. 12. Subtractions from Requested Amounts, Growth or 2002 CUE Comparison  Subtractions from Requested Amounts, Growth or 2002 CUE Comparison is the greatest reduction of the estimate measured in kilograms of either the difference in the amount of methyl bromide requested by the applicant that is greater than that historically used or treated at a higher use rate or the difference in the 2006 request from an applicant's 2002 CUE application compared with the 2006 request from the applicant's 2003 CUE application. Page 48 13. Subtractions from Requested Amounts, QPS  Subtractions from Requested Amounts, QPS is the estimate measured in kilograms of the request subject to QPS treatments. This subtraction estimate is calculated as the 2006 Request minus Double Counting, minus Growth or 2002 CUE Comparison then multiplied by the percentage subject to QPS treatments. Subtraction from Requested Amounts, QPS = ( 2006 Request   Double Counting   Growth)*( QPS %) 14. Subtraction from Requested Amounts, Use Rate Difference   Subtractions from requested amounts, use rate difference is the estimate measured in kilograms of the lower of the historic use rate or the requested use rate. The subtraction estimate is calculated as the 2006 Request minus Double Counting, minus Growth or 2002 CUE Comparison, minus the QPS amount, if applicable, minus the difference between the requested use rate and the lowest use rate applied to the remaining hectares. 15. Adjustments to Requested Amounts   Adjustments to requested amounts were factors that reduced to total amount of methyl bromide requested by factoring in the specific situations were the applicant could use alternatives to methyl bromide. These are calculated as proportions of the total request. We have tried to make the adjustment to the requested amounts in the most appropriate category when the adjustment could fall into more than one category. 16. (%) Karst topography   Percent karst topography is the proportion of the land area in a nomination that is characterized by karst formations. In these areas, the groundwater can easily become contaminated by pesticides or their residues. Regulations are often in place to control the use of pesticide of concern. Dade County, Florida, has a ban on the use of 1,3D due to its karst topography. 17. (%) 100 ft Buffer Zones   Percentage of the acreage of a field where certain alternatives to methyl bromide cannot be used due the requirement that a 100 foot buffer be maintained between the application site and any inhabited structure. 18. (%) Key Pest Impacts  Percent (%) of the requested area with moderate to severe pest problems. Key pests are those that are not adequately controlled by MB alternatives. For example, the key pest in Michigan peppers, Phytophthora spp. infests approximately 30% of the vegetable growing area. In southern states the key pest in peppers is nutsedge. 19. Regulatory Issues (%)  Regulatory issues (%) is the percent (%) of the requested area where alternatives cannot be legally used ( e. g., township caps) pursuant to state and local limits on their use. 20. Unsuitable Terrain (%)   Unsuitable terrain (%) is the percent (%) of the requested area where alternatives cannot be used due to soil type ( e. g., heavy clay soils may not show adequate performance) or terrain configuration, such as hilly terrain. Where the use of alternatives poses application and coverage problems. 21. Cold Soil Temperatures   Cold soil temperatures is the proportion of the requested acreage where soil temperatures remain too low to enable the use of methyl bromide alternatives and still have sufficient time to produce the normal ( one or two) number of crops per season or to allow harvest sufficiently early to obtain the high prices prevailing in the local market at the beginning of the season. 22. Combined Impacts (%)  Total combined impacts are the percent (%) of the requested area where alternatives cannot be used due to key pest, regulatory, soil impacts, temperature, etc. In each case the total area impacted is the conjoined area that is impacted by any individual impact. The effects were assumed to be independently distributed unless contrary evidence was available ( e. g., affects are known to be mutually exclusive). For example, if 50% of the requested area had moderate to severe key pest pressure and 50% of the requested area had karst topography, then 75% of the area was assumed to require methyl bromide rather than the alternative. This was calculated as follows: 50% affected by key pests and an additional 25% ( 50% of 50%) affected by karst topography. 23. Qualifying Area  Qualifying area ( ha) is calculated by multiplying the adjusted hectares by the combined impacts. 24. Use Rate  Use rate is the lower of requested use rate for 2006 or the historic average use rate. 25. CUE Nominated amount  CUE nominated amount is calculated by multiplying the qualifying area by the use rate. 26. Percent Reduction  Percent reduction from initial request is the percentage of the initial request that did not qualify for the CUE nomination. 27. Sum of CUE Nominations in Sector  Self explanatory. 28. Total US Sector Nomination  Total U. S. sector nomination is the most likely estimate of the amount needed in that sector. 29. Dichotomous Variables   dichotomous variables are those which take one of two values, for example, 0 or 1, yes or no. These variables were used to categorize the uses during the preparation of the nomination. Page 49 30. Strip Bed Treatment   Strip bed treatment is ` yes' if the applicant uses such treatment, no otherwise. 31. Currently Use Alternatives   Currently use alternatives is ` yes' if the applicant uses alternatives for some portion of pesticide use on the crop for which an application to use methyl bromide is made. 32. Research/ Transition Plans   Research/ Transition Plans is ` yes' when the applicant has indicated that there is research underway to test alternatives or if applicant has a plan to transition to alternatives. 33. Tarps/ Deep Injection Used   Because all pre plant methyl bromide use in the US is either with tarps or by deep injection, this variable takes on the value ` tarp' when tarps are used and ` deep' when deep injection is used. 34. Pest free cert. Required  This variable is a ` yes' when the product must be certified as ` pest free' in order to be sold 35. Other Issues. Other issues is a short reminder of other elements of an application that were checked 36. Change from Prior CUE Request This variable takes a `+' if the current request is larger than the previous request, a ` 0' if the current request is equal to the previous request, and a `` if the current request is smaller that the previous request. 37. Verified Historic Use/ State This item indicates whether the amounts requested by administrative area have been compared to records of historic use in that area. 38. Frequency of Treatment   This indicates how often methyl bromide is applied in the sector. Frequency varies from multiple times per year to once in several decades. 39. Economic Analysis   provides summary economic information for the applications. 40. Loss per Hectare   This measures the total loss per hectare when a specific alternative is used in place of methyl bromide. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 41. Loss per Kilogram of Methyl Bromide   This measures the total loss per kilogram of methyl bromide when it is replaced with an alternative. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 42. Loss as a % of Gross revenue   This measures the loss as a proportion of gross ( total) revenue. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 43. Loss as a % of Net Operating Revenue  This measures loss as a proportion of total revenue minus operating costs. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. This item is also called net cash returns. 44. Quality/ Time/ Market Window/ Yield Loss (%)   When this measure is available it measures the sum of losses including quality losses, non productive time, missed market windows and other yield losses when using the marginal strategy. 45. Marginal Strategy  This is the strategy that a particular methyl bromide user would use if not permitted to use methyl bromide. Page 50 APPENDIX B. SUMMARY OF NEW APPLICANTS A number of new groups applied for methyl bromide for 2005 during this application cycle, as shown in the table below. Although in most cases they represent additional amounts for sectors that were already well characterized sectors, in a few cases they comprised new sectors. Examples of the former include significant additional country ( cured, uncooked) ham production; some additional request for tobacco transplant trays, and very minor amounts for pepper and eggplant production in lieu of tomato production in Michigan.

For the latter, there are two large requests: cut flower and foliage production in Florida and California (` Ornamentals') and a group of structures and process foods that we have termed ` Post Harvest NPMA' which includes processed ( generally wheat based foods), spices and herbs, cocoa, dried milk, cheeses and small amounts of other commodities. There was also a small amount requested for field grown tobacco.

The details of the case that there are no alternatives which are both technically and economically feasible are presented in the appropriate sector chapters, as are the requested amounts, suitably adjusted to ensure that no double counting, growth, etc. were included and that the amount was only sufficient to cover situations ( key pests, regulatory requirements, etc.) where alternatives could not be used.

The amount requested by new applicants is approximately 2.5% of the 1991 U. S. baseline, or about 1,400,000 pounds of methyl bromide, divided 40% for pre plant uses and 60% for postharvest needs.

The methodology for deriving the nominated amount used estimates that would result in the lowest amount of methyl bromide requested from the range produced by the analysis to ensure that adequate amounts of methyl bromide were available for critical needs. We are requesting additional methyl bromide in the amount of about 500,000 Kg, or 2% or the 1991 U. S. baseline, to provide for the additional critical needs in the pre plant and post harvest sector.

Applicant Name 2005 U. S. CUE Nomination ( lbs)

California Cut Flower Commission 400,000 National Country Ham Association 1,172 Wayco Ham Company 39 California Date Commission 5,319 National Pest Management Association 319,369 Michigan Pepper Growers 20,904 Michigan Eggplant Growers 6,968 Burley & Dark Tobacco Growers USA  Transplant Trays 2,254 Burley & Dark Tobacco Growers USA  Field Grown 28,980 Virginia Tobacco Growers  Transplant Trays 941 Michigan Herbaceous Perennials 4,200 Page 51 Ozark Country Hams 240 Nahunta Pork Center 248 American Association of Meat Processors 296,800 Total lbs 1,087,434 Total kgs 493,252