Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8. In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear Summarize each of the research studies you cite in the Research Summary Worksheet.

If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet 1,3 Dichloropropen/ Chloropicrin Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # For EPA Use Only ID#

See Appendix Z, " 1,3 D Chloropicrin Narrative" Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. See Appendix Z, " 1,3 D Chloropicrin Narrative" Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Appendix Z, " 1,3 D Chloropicrin Narrative"

OMB Control #

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

1,3 Dichloropropene/ Chloropicrin [ Insert Study Title] Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J, M: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Units of product per Area per Application Product Unit ( e. g., lbs.,

gals) $ 0.00 $ 0.00 $ 0.00 InLine + VIF tarp drip application 34 gallons $ 1,541.00 Telone C35 shank flat application 350 400 lbs $ 1,993.00 Telone , flat application 350 400 lbs + coinject PIC 200 400 lbs $ 2,563.00 Average $ 2,278.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total Non Rotation $ 1,541.00 Comments: Total Rotation $ 2,278.00 If you do not have the quantitative data for additional crops grown on the same land, please indicate so in the comment section.

See Appendix U, " mebr_ alts_ prices. xls"

See Appendix V, " Vegetable Rotation Narrative"

OMB Control # For EPA Use Only ID#

See attached narrative Use one row for each active ingredient ( ai). For example, if a product contains 2 ai's use 2 rows for that product. Once a row is completed for a given product, then only Col. B ( if applicable), C, and E need to be completed for additional rows regardin Enter the number of applications in a fumigation cycle comparable to methyl bromide for this alternative pest control regimen. Since this number is an average, it does not need to be a whole number.

Enter the formulation or the % of active ingredient. Cost per Area ( 2001$)

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Name of Product Price per Unit of the Product Cost of Applying Pesticide per Area Other Costs per Application Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: 1,3 D/ Chloropicrin Enter the area receiving at least one application of the pesticide.

If a consortium is submitting this application, the data for this table should reflect a representative user.

Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. If multiple crops are grown Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product.

Col. A: Name of Product and Non chemical Control If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

As a cross check, EPA is requesting both the amount of active ingredient in Col. E and product applied per area in Col. F. Indicate the unit of the product in Col. G.

Use 2001 prices and costs. If the product is custom applied you may enter the total cost in the last column ( Col. M) and override the formula. If a pesticide is applied by the user, enter the price of the product in Col. H and the cost of applying it in Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Gross Revenue A B C D E F Crop/ Commodity Price Factors ( grade, time, market) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( lbs per acre) Price ( per unit of crop/ commodity) Revenue ( per area) $ 0.00 $ 0.00 South $ 0.00 Strawberries Fresh and Processed Total yield per acre 46,801 $ 0.00 Fresh 63% 29,485 $ 0.695 $ 20,491.87 Processed 37% 17,316 $ 0.306 $ 5,298.82 $ 0.00 North $ 0.00 Strawberries Fresh and Processed $ 0.00 Non Rotation 47,633 Fresh 84% 40,012 $ 0.576 $ 23,046.94 Processed 16% 7,621 $ 0.306 $ 2,332.13 Rotation 46,908 Fresh 84% 39,403 $ 0.576 $ 22,696.02 Processed 16% 7,505 0.306 $ 2,296.62 Total Revenue South $ 25,790.69 Total Rev N non rot $ 25,379.07 Total Rev N rotation $ 24,992.64 Comments: Weighted averageyearly price for fresh berries is $ 0.695 South and $ 0.576 based on calculations used for Section 18 applications, Appendix K Percentage of fresh vs processed based on 2001 baseline, Worksheets 2 CS and 2 CN, .63: 37 and .84: 16 respectively Crop/ Commodity Yield calculated from the average percent yield from California strawberry trials, Appendix T, 1,3 D Pic tab Note ratio in South of Fresh to Processed is 63% to 37%

Note ratio in North of Fresh to Processed is 84% to 16%

OMB Control #

Col. A: Crop/ Commodity If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternativ 1,3 D/ Chloropicrin If a consortium is submitting this application, the data for this table should reflect a representative user.

In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this Enter the unit of measurement for your crop/ commodity.

Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please discuss changes in crop cycles resulting from alternative use in the comments. See the Fumigation Cycle Worksheet f Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality, grade, market ( e. g., fresh or processing), timing of harvest, etc., you may itemize by using m Enter the number of units of crop/ commodity produced per area for that price factor identified.

Enter the average 2001 prices received by the users for that crop/ commodity and price factor.

The purpose of this worksheet is to identify the gross revenue for units ( crop, commodity, structure) when using an alternative compared to gross revenue when using methyl bromide.

Postharvest and structural users may modify this form to accommodate diff For EPA Use Only ID#

Col. A: Operation or Cost Item Col. B: Custom Operation Cost Col. C, D, E: Costs per Area Col. F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area $ 0.00 $ 0.00 Custom Fumigation InLine $ 1,541 $ 0.00 Flat fumigation Telone C35 $ 2,278 $ 0.00 Additional yearly maintenance of drip $ 100 $ 0.00 Lost revenue for early crop pull S $ 11 $ 0.00 Lost revenue for early crop pull N $ 1,262 $ 0.00 Gained revenue from not picking N $ 918 $ 0.00 Weeding costs for InLine South $ 236 $ 0.00 Weeding costs for InLine North $ 316 $ 0.00 $ 0.00 Additional rent for rotation $ 525 $ 0.00 $ 0.00 South Total per Area $ 1,887.52 User Total per area $ 0.00 North Total Non Rotation per Area $ 2,301.40 North Total Rotation per Area $ 3,119.00 Comments: Weeding costs for shank application calculated as $ 776 versus $ 713 for the South, $ 1,042 versus $ 957 for the North Weeding costs for drip application calculated as $ 949 versus $ 713 for the South, $ 1,273 versus $ 957 for the North See Appendix Z, 1,3 D Chloropicrin Narrative OMB Control # Enter in Col. C and D, material and labor costs per area that change for operations done by user. The total cost per area is calculated automatically from the values you enter in Cols. C and D. Typical Equipment Used Operation Done by User 1,3 D/ Chloropicrin Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative:

Custom Operation Cost per Area Operation or Cost Item Enter data only for costs ( other than the cost of alternative pest control) that change as a result of using the alternatives instead of methyl bromide. Enter the whole cost, not just the incremental changes. Enter the cost in Col. B for custom operatio Identify changes in the typical equipment used by the user as a result of not using methyl bromide. Please be specific such as tractor horsepower. No cost data are required in this column.

Identify the operations or cost items that change as a result of not using methyl bromide.

Enter custom operation costs that change in Col. B.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

If a consortium is submitting this application, the data for this table should reflect a representative user . For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Reprentative Use Total Operating Costs Total Revenues Net Revenues Southern Region ( w/ o overhead) $ 26,311 $ 25,791 $ 519.83 Northern Region ( w/ o overhead)

Non Rotation $ 26,274 $ 25,379 $ 895.33 Rotation $ 27,092 $ 24,993 $ 2,099.36 Total Revenues for South $ 519.83 Total Revenues for North $ 1,497.35 Comments: Overhead costs not included at this time as best case scenario See Appendix Y, " 1,3 D Chloropicrin Narrative"

OMB Control # Worksheet 3 E. 1,3 D/ Chloropicrin Total Costs and Revenues in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

If a consortium is submitting this application, the data for this table should reflect a representative user.

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated. Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps XXXX 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) XXXX See Appendix AA, " 1,3 D Chloropicrin Metam Narrative" See Appendices P, S, R, X If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

1,3 D/ Chloropicrin/ Metam In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear For EPA Use Only ID# Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # See Appendix AA, " 1,3 D Chloropicrin Metam Narrative" Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss.

Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study.

See Appendix AA, " 1,3 D Chloropicrin Metam Narrative" For EPA Use Only ID# Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Appendix AA, " 1,3 D Chloropicrin Metam Narrative"

OMB Control # Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

1,3 Dichloropropene/ Chloropicrin/ Metam [ Insert Study Title]

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J, M: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Units of product per Area per Application Product Unit ( e. g., lbs.,

gals) $ 0.00 $ 0.00 $ 0.00 InLine + VIF tarp drip application 34 gallons + Metam drip 37 50 gallons $ 1,799.00 Telone C35 shank flat application 350 400 lbs + Metam drip 37 50 gallons $ 2,152.00 Telone , flat application 350 400 lbs + coinject PIC 200 400 lbs + Metam drip 37 50 gallons $ 2,722.00 Average $ 2,437.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total Non Rotation $ 1,799.00 Comments: Total Rotation $ 2,437.00 If you do not have the quantitative data for additional crops grown on the same land, please indicate so in the comment section.

See Appendix U, " mebr_ alts_ prices. xls"

See Appendix V, " Vegetable Rotation Narrative"

OMB Control # Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: 1,3 D/ Chloropicrin/ Metam Enter the area receiving at least one application of the pesticide.

If a consortium is submitting this application, the data for this table should reflect a representative user.

Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. If multiple crops are grown Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product.

Col. A: Name of Product and Non chemical Control If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

As a cross check, EPA is requesting both the amount of active ingredient in Col. E and product applied per area in Col. F. Indicate the unit of the product in Col. G.

Use 2001 prices and costs. If the product is custom applied you may enter the total cost in the last column ( Col. M) and override the formula. If a pesticide is applied by the user, enter the price of the product in Col. H and the cost of applying it in Name of Product Price per Unit of the Product Cost of Applying Pesticide per Area Other Costs per Application For EPA Use Only ID#

See attached narrative Use one row for each active ingredient ( ai). For example, if a product contains 2 ai's use 2 rows for that product. Once a row is completed for a given product, then only Col. B ( if applicable), C, and E need to be completed for additional rows regardin Enter the number of applications in a fumigation cycle comparable to methyl bromide for this alternative pest control regimen. Since this number is an average, it does not need to be a whole number.

Enter the formulation or the % of active ingredient. Cost per Area ( 2001$)

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Gross Revenue A B C D E F Crop/ Commodity Price Factors ( grade, time, market) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( lbs per acre) Price ( per unit of crop/ commodity) Revenue ( per area) $ 0.00 $ 0.00 South $ 0.00 Strawberries Fresh and Processed Total yield per acre 45,836 $ 0.00 Fresh 63% 28,877 $ 0.695 $ 20,069.36 Processed 37% 16,959 $ 0.306 $ 5,189.57 $ 0.00 North $ 0.00 Strawberries Fresh and Processed $ 0.00 Non Rotation 46,651 Fresh 84% 39,187 $ 0.576 $ 22,571.74 Processed 16% 7,464 $ 0.306 $ 2,284.05 Rotation 49,514 Fresh 84% 41,592 $ 0.576 $ 23,956.91 Processed 16% 7,922 $ 0.306 $ 2,424.21 $ 0.00 $ 0.00 Total Revenue South $ 25,258.93 Total Rev Non rot Nort $ 24,855.79 Total Rev Rot North $ 26,381.12 Comments: Weighted averageyearly price for fresh berries is $ 0.695 South and $ 0.576 based on calculations used for Section 18 applications, Appendix K Percentage of fresh vs processed based on 2001 baseline, Worksheets 2 CS and 2 CN, .63: 37 and .84: 16 respectively Crop/ Commodity Yield calculated from the average percent yield from California strawberry trials, Appendix T, 1,3 D Pic Metam tab Note ratio in South of Fresh to Processed is 63% to 37%

Note ratio in North of Fresh to Processed is 84% to 16%

OMB Control # Enter the number of units of crop/ commodity produced per area for that price factor identified.

Enter the average 2001 prices received by the users for that crop/ commodity and price factor.

The purpose of this worksheet is to identify the gross revenue for units ( crop, commodity, structure) when using an alternative compared to gross revenue when using methyl bromide.

Postharvest and structural users may modify this form to accommodate diff Col. A: Crop/ Commodity If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternati 1,3 D Chloropicrin Metam If a consortium is submitting this application, the data for this table should reflect a representative user.

In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this Enter the unit of measurement for your crop/ commodity.

Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please discuss changes in crop cycles resulting from alternative use in the comments. See the Fumigation Cycle Worksheet f Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality, grade, market ( e. g., fresh or processing), timing of harvest, etc., you may itemize by using m For EPA Use Only ID#

Col. A: Operation or Cost Item Col. B: Custom Operation Cost Col. C, D, E: Costs per Area Col. F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area $ 0.00 $ 0.00 Custom Fumigation InLine+ metam $ 1,799 $ 0.00 Flat fumigation Telone C35 + drip $ 2,437 $ 0.00 Additional yearly maintenance of drip $ 100 $ 0.00 Lost revenue for early crop pull S $ 1,841 $ 0.00 Savings from not picking 0.5 month S $ 416 Lost revenue for early crop pull N $ 2,525 $ 0.00 Savings from not picking 1 month N $ 1,836 Additional rent for rotation $ 525 $ 0.00 Weeding costs for InLine South $ 313 $ 0.00 Weeding costs for InLine North $ 421 $ 0.00 $ 0.00 $ 0.00 $ 0.00 South Total Custom per Area $ 3,636.62 User Total per area $ 0.00 North Total Non Rotation per Area $ 3,008.79 North Total Rotation per Area $ 3,383.00 Comments: Weeding costs for shank application calculated as $ 745 versus $ 713 for the South, $ 999 versus $ 957 for the North Weeding costs for drip application calculated as $ 1,026 versus $ 713 for the South, $ 1,378 versus $ 957 for the North See Appendix AA, " 1,3 D Chloropicrin Metam Narrative"

OMB Control # Enter custom operation costs that change in Col. B.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

If a consortium is submitting this application, the data for this table should reflect a representative user .

Enter in Col. C and D, material and labor costs per area that change for operations done by user. The total cost per area is calculated automatically from the values you enter in Cols. C and D. Typical Equipment Used Operation Done by User 1,3 D Chloropicrin/ Metam Sodium Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative:

Custom Operation Cost per Area Operation or Cost Item Enter data only for costs ( other than the cost of alternative pest control) that change as a result of using the alternatives instead of methyl bromide. Enter the whole cost, not just the incremental changes. Enter the cost in Col. B for custom operatio Identify changes in the typical equipment used by the user as a result of not using methyl bromide. Please be specific such as tractor horsepower. No cost data are required in this column.

Identify the operations or cost items that change as a result of not using methyl bromide. For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Reprentative Use Total Operating Costs Total Revenues Net Revenues Southern Region ( w/ o overhead) $ 28,060 $ 25,259 $ 2,800.69 Northern Region ( w/ o overhead) Rotation $ 27,356 $ 26,381 $ 974.88 Non Rotation $ 26,982 $ 24,856 $ 2,126.01 Total Revenues for South $ 2,800.69 Total Revenues for North $ 1,550.44 Comments: Overhead costs not included at this time as best case scenario See Appendix AA, " 1,3 D Chloropicrin Metam Narrative"

OMB Control # Worksheet 3 E. 1,3 D/ Chloropicrin/ Metam Total Costs and Revenues in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

If a consortium is submitting this application, the data for this table should reflect a representative user.

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated. Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe)

See Appendix BB, " Non Chemical Narrative" If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible Worksheet 3 A. Non Chemical Technical Feasibility wrt Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

Non Chemical Alternatives In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear For EPA Use Only ID# Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # See Appendix BB, " Non Chemical Narrative" Worksheet 3 A. Non Chemical Technical Feasibility wrt Methyl Bromide Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss.

Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. None of the non chemical alternatives identified by MBTOC control the entire For EPA Use Only ID#

See Appendix BB, " Non Chemical Narrative" pest complex Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Appendix BB, " Non Chemical Narrative"

OMB Control # Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

Non Chemical [ Insert Study Title]

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after 1. Name of study:

2. Researcher( s):

3. Your test is planned for:

4. Location:

5. Name of alternative to be tested:

6. Yes XX No 7.

OMB Control # For EPA Use Only ID#

Worksheet 4. Alternatives  Future Research Plans Will crop yield be measured in the study? CSC/ UC/ USDA Statewide Methyl Bromide Alternatives Project ( Continuation)

See Appendix HH Please describe future plans to test alternatives to methyl bromide. ( All available methyl bromide alternatives from the alternatives list should have been tested or have future tests planned.) There is no need to complete a separate worksheet for future research plans for each alternative  you may use this worksheet to describe all future research plans.

If additional testing is not planned, please explain why. ( For example, the available alternatives have been tested and found unsuitable, an alternative has been identified but is not yet registered for this crop, available alternatives are too expensive for this crop, etc.) California Strawberry Growing Region 2003 on Continuation of on farm demo plots of methyl bromide alternatives throughout Strawberry growing region 1. Name of study:

2. Researcher( s):

3. Your test is planned for:

4. Location:

5. Name of alternative to be tested:

6. Yes XX No 7.

OMB Control # California Strawberry Commission Research Grants See Appendix HH Please describe future plans to test alternatives to methyl bromide. ( All available methyl bromide alternatives from the alternatives list should have been tested or have future tests planned.) There is no need to complete a separate worksheet for futur If additional testing is not planned, please explain why. ( For example, the available alternatives have been tested and found unsuitable, an alternative has been identified but is not yet registered for this crop, available alternatives are too expensive California Strawberry Growing Region 2003 2004 Continuation research in Pomology, Plant Pathology, Fumigant efficacy, and Optimization of drip fumigants Will crop yield be measured in the study? For EPA Use Only ID#

Worksheet 4. Alternatives  Future Research Plans 1. Name of study:

2. Researcher( s):

3. Your test is planned for:

4. Location:

5. Name of alternative to be tested:

6. Yes XX No 7.

OMB Control # For EPA Use Only ID#

Worksheet 4. Alternatives  Future Research Plans Will crop yield be measured in the study? Alternative Fumigants for the Control of Soil Pests: Strawberry as a Model System, Renewal See Appendix HH Please describe future plans to test alternatives to methyl bromide. ( All available methyl bromide alternatives from the alternatives list should have been tested or have future tests planned.) There is no need to complete a separate worksheet for futur If additional testing is not planned, please explain why. ( For example, the available alternatives have been tested and found unsuitable, an alternative has been identified but is not yet registered for this crop, available alternatives are too expensive California Strawberry Growing Region 2003 2004 Continuation of nursery to farm research on alternatives, testing of new alternatives, large plot studies 1.

1a. Check all methods you will use Nothing XX Tarpaulin ( high density polyethylene) XX Virtually impermeable film ( VIF) XX Cultural practices ( please specify)

1b. Will you use other pesticides to reduce use of methyl bromide? Yes XX No If yes please specify.

1c. Other non chemical methods: ( please specify):

2. Yes No XX If yes, how many pounds? lbs.

3. Yes No XX If yes, how many pounds? lbs.

4.

$

5.

6.

When do you expect these to occur?

7.

0 10 acres 10 25 acres 25 50 acres 50 100 acres 100 200 acres 200 400 acres over 400 acres Sufficient research on optimal rates of MeI and other alternatives, without phytotoxicity. since profit margins are so small, losses on even small percentages of acres could put growers under How will you minimize your use and/ or emissions of methyl bromide?

Colored tarps for weed control and VIF film for lower rates and better efficacy. No non chemical means work.

Do you have access to recycled methyl bromide? Additions of nematocides, herbicides to pest management program Do you anticipate that you will have any methyl bromide in storage on January 1, 2005?

$ 8,000,000 Manufacturer sponsored " insurance" for growers trying alternatives, to recoup losses should alternatives fail organizing and running Demonstrations Field Days.

Identify what factors would allow you to stop or reduce your use of methyl bromide ( e. g. registration of particular pesticide; completion of research plan; capital outlay). What is the cumulative amount spent to date by the user or consortium on research to develop alternatives to methyl bromide ( beginning in 1992)? CSC money only, from assessements since 1992 Other investments, if any, made to reduce your reliance on methyl bromide. Describe each investment and its associated cost. Staff ( 2 people equivalent) time and salary assisting USDA and Univsersity researchers over the years, VIF film to lower MBr rates efficaciously Worksheet 5. Additional Information For EPA Use Only ID#

13% Lower ratio formulations ( 50: 50)

10% 25% 33% Due to complexity of Pest complex, expect some use of methyl bromide may need to continue for periodic field cleanup 2006, 2007 15%

3% 1% Range of acres farmed by growers included in this application? ( insert number of users in each category) Worksheet 5. Additional Information ( continued)

8.

0  5,000 sq. ft. 5,001  10,000 sq. ft. 10,001  20,000 sq. ft. 20,001  40,000 sq. ft. 40,001  80,000 sq. ft. 80,001  160,000 sq. ft. over 160,000 sq. ft.

I certify that all information contained in this document is factual to the best of my knowledge.

Signature Date Print Name Title Signature Date Print Name Title OMB Control # Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 324 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. Range of square feet of the area to which applicants included in this application will apply methyl bromide? ( insert number of users in each category)

Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered " critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree not to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application. For EPA Use Only ID# 1. 2. 3. 4. Pounds of Methyl Bromide Requested 2005 4,500,000 5. Area Treated with Methyl Bromide 2005 25,000 acres units 6. If methyl bromide is requested for additional years, reason for request:

2006 4,500,000 lbs. Area Treated 25,000 acres units 2007 4,500,000 lbs. Area Treated 25,000 acres units Not Technically Feasible Not Economically Feasible X X X X X X X X X X X X Place an " X" in the column( s) labeled " Not Technically Feasible" and/ or " Not Economically Feasible" where appropriate. Use the " Reasons" column to describe why the potential alternative is not feasible.

Non Chemical Alternatives 1,3 Dichloropropene/ Chloropicrin 1,3 Dichloropropene/ Chloropicrin/ Metam Sodium Metam Sodium Chloropicrin/ Metam Sodium combination 1,3 Dichloropropene Chloropicrin Potential Alternatives Nematocides The consortium is requesting the full amount of methyl bromide anticipated to be used in the 2002 production cycle for the years 2006 and 2007. If the two year trend in adoption of alternatives ( 2000 2001) continues,

or if economically viable alternatives gain registration, future applications for critical use exemptions will be adjusted accordingly Insufficient efficacy against the entire strawberry pest complex in California as evidenced by yield losses showing no economic feasibility. Under regulatory restrictions in California.

Insufficient long term efficacy against the entire strawberry pest complex in California. Further work on lont term efficacy with repeated use required. Marginal economic feasibility. Under regulatory restrictions in California.

Insufficient efficacy against the entire strawberry pest complex in California Insufficient long term efficacy against the entire strawberry pest complex in California. Further work on lont term efficacy with repeated use required. Marginal economic feasibility. Under regulatory restrictions in California.

Insufficient long term efficacy against the entire strawberry pest complex in California. Further work on lont term efficacy with repeated use required. No economic feasibility. Under regulatory restrictions in California.

Insufficient efficacy against the entire strawberry pest complex in California.

Reasons Insufficient efficacy against the entire strawberry pest complex in California. Under regulatory restrictions in California. Insufficient efficacy against the entire strawberry pest complex in California. Under regulatory restrictions in California.

Name of Applicant:

Location:

Crop: California Strawberry Commission P. O. Box 269, Watsonville, CA 95077 0269 Production Strawberries For EPA Use Only ID#

Worksheet 6. Application Summary This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phase out for methyl bromide. Therefore, this worksheet cannot be claimed as CBI. 1,3 Dichloropropene, Chloropicrin and Metam Sodium Technical Feasibility Efficacy. Telone   ( 1,3 dichloropropene) is used as a nematocide with minimal efficacy against disease and weeds when used alone. Because it is not effective against the entire pest complex in California strawberries, this alone prevents it from being a methyl bromide replacement ( Table 1, Pest Complex, in application). Early efficacy work with Telone alone demonstrated it's poorer activity compared to methyl bromide/ chloropicrin standards ( Appendix CC, 91 15 Pink Sheet). And in fact in that study of repeated use over three years, already poor yields dropped with time. The MBTOC 1998 report ( page 51) also indicated it is effective only in combination with other components. The Federal Use Label also shows it is labeled only against nematodes.

Chloropicrin alone has some activity against much of the California Pest Complex. Chloropicrin has good efficacy against Pseudomonas solancearum, Cylindrocladium fungi, Phytophthora, Fusarium, Pyrenochaeta, Pythium, Rhizoctonia, Sclentina, Slcerotium, Verticillium, clubroot organism Plasmodiophora, soil pox Actinomyces ipomoea ( Table 1). Chloropicrin alone as some control of cut worms, grubs, wireworms, and suppression of weeds if used with tarps ( Appendix G.) It has no control over some key weeds, knotweed, clovers, and filaree and limited control over others that MBC does control ( Appendix DD, Fennimore 2002 handout). While used primarily as a fungicide, its control of anthracnose is unknown, and this disease has become an increasingly important problem in California strawberries and is controlled by MBC. Chloropicrin has no reported activity against nematodes. Nematodes may likely become an increasing problem in repeated use of Chloropicrin. MBC has controlled nematodes so well for decades, hard to measure future impact of this pest when faced with less than adequate control from Chloropicrin.

Metam Efficacy Metam sodium has some activity against most of the California strawberry pest complex. However, that activity is limited in many cases. For instance metam has weed activity against weeds and weed seeds of Bermudagrass, Chickweed, Dandelions, Ragweed, Henbit, Labsquarter, Pigweed, Watercress, Johnsongrass, Nightshade, Nutsedge ( suppression only), Wild Morning Glory and Purslane. But methyl bromide/ chloropicrin ( MBC) controls nutsedge well ( S. Fennimore) compared to metam and MBC controls prostrate knotweed better than metam alone ( Appendix DD, Fennimore 2000 handout). Overall, weed biomass compared to the MBC standard was 37% higher when metam alone was used at 75 gal/ acre ( Appendix DD, Fennimore 2000 handout).

Metam only suppresses active forms of nematodes versus eggs ( requires preirrigation for best activity and fully decomposed plant residues). It is also reported to have activity against garden symphalan and against the soil borne diseases Rhizoctonia, Pythium, Phytophthora, Verticillium, and Sclerotina.

Combined Efficacy Of all the alternative regimes the 1,3 D chloropicrin metam alternative combination would appear to have the closest combined efficacy to methyl bromide. Some increased control of weeds has been observed in InLine applications using VIF mulch. However, as in all drip applications, weed control is not observed in areas of the beds where the drip application did not reach, such as the sides. Application of herbicides is not a simple solution because these side weeds are under the mulch. Removal requires extensive labor to lift the tarp sides, pull the weeds, and replace the tarp along the sides. Use of additional herbicides would simply add to the operational costs as would increased labor to hand weed. So while improved weed efficacy would be expected in the direct area of application of metam, weeds would still cause problems and add to costs growing along the sides of the beds and in furrows. ( See discussion on drip fumigation in Appendix Y, 1,3 D Chloropicrin Narrative.)

Yields Efficacy of the combine 1,3 D, chloropicrin, metam sodium regime was highly variable depending on the pest pressure at the site ( Appendix T, 1,3 D Pic Metam tab). When only trials where untreated controls had yields of 80% or less of the MBC standard are considered, the overall yields with 1,3 D/ chloropicrin/ metam averages 95% of the MBC standard. When drip and shank applications are separated, drip was better at 97% versus 90% for shank. Analysis of 10 studies comparing MBC with 1,3 D/ chloropicrin applications by Shaw and Larson showed an overall loss of 14.7% compared to MBC. No studies or work is available on repeated use of 1,3 D/ chloropicrin/ metam on the same land. Since Shaw and Larson showed steady declines over 3 years of chloropicrin use, and 1,3 D has limited efficacy on the pest complex, one would anticipate steady losses with use of this material. In particular, weed pressure may increase so significantly with repeated use to further contribute to yield loss.

Economic Analysis For drip applications, the most economical and safest application technology, there are potential up front costs for ensuring irrigation systems are leak proof and proper valves and safeguards are in place to prevent backflow of materials into water sources. In addition, 1,3 Dichloropropene and chloropicrin are very corrosive substance and if proper care is not taken to clean out systems after application, valves and piping corrode and need replacement. Growers need to replace PVC pipe, which is corroded by 1,3 D and chloropicrin, with non PVC piping such as Oval Hose. The first growers using the technology state that they had minimal up front costs or donations of equipment to upgrade their systems. For the general grower upgrade costs could run thousands of dollars to replace PVC piping and add proper valve and flow equipment. We estimate yearly costs of $ 100 per acre to upgrade and maintain drip systems based on discussions with experienced growers.

The economics associated with soil preparation come into play for 1,3 D/ chloropicrin/ metam applications. Soil preparation and soil moisture are more critical than with MBC applications ( Appendix G). Soil temperature is also more critical. According to label directions, if temperatures drop below 40 ° F, the material loses effectiveness on application and requires an even longer plant back period. The normal plant back period is roughly 1 week for every 10 gallons per acre applied for 1,3 D and with the waiting period and plant back time for metam sodium, at best this leaves a plant back period of 28 days compared to the 7 days for MBC. The Southern grower needs, at best, to pull plants in mid June to do all the preparation, fumigations, and have sufficient plantback time for planting by the end of September.

The Southern grower will lose some revenue for pulling crop early in mid June. Lost revenue would equal two weeks of fresh and processed revenue ($ 1,841). Savings would be incurred for not having two weeks of processed harvest costs at $ 208 per week ($ 416)( processed harvest cost divided by 17 weeks processed harvest time in the south), since it is almost exclusively processed harvest going on in June. The Northern growers however will lose revenue from not in September ($ 2,525 per acre) for rotational growers. There is some savings in not paying fresh harvest costs for four weeks, a total of $ 459 per week ( fresh harvest costs for North divided by 35 weeks harvest), or $ 1,836 per acre. The non rotational growers will have to obtain their land sooner, paying one quarter year's rent to prevent the vegetable grower from doing one last vegetable crop. Land rent in the northern region ranges from $ 1800 2400 per acre. One quarter of the average rent, $ 2,100, is $ 525.

Economic analysis was done with best case scenarios. For the Southern grower and the Northern non rotation grower, it was assumed drip application of InLine and metam were the most efficacious and cost effective. For the rotation grower in the North, flat fumigation of Telone C35 is the only option to ensure coverage of the entire field in anticipation of use the next year by vegetable growers. As such, when these costs are added in, the Southern grower sees a loss of $ 2,801 per acre a total loss of $ 112,040 for the 40 acre representative user. In the North, the non rotation grower experiences a loss of $ 2,126 per acre for a total loss of $ 85,040. The rotational grower experiences a loss of $ 975 per acre to use of the more expensive flat fumigation with Telone C35. The total loss for the 40 acre representative rotation grower is $ 39,000. On average for the Northern grower, losses would be $ 1,550 per acre, or $ 62,000 for the 40 acre Northern grower. This are minimum possible losses because if plant back time, particularly in the colder north, increases so does loss of revenue by having to pull crop even earlier.

Regulatory Pressures 1,3 Dichloropropene The Federal Label requires a 100 foot buffer zone for drip applied Telone. For shank applied Telone, a 100 foot buffer zone is required the first year and a 300 foot buffer zone is required for the next two years on the same ground ( Appendix G). In addition, in California, use is limited by township caps, as an additional protection with respect to the classification of 1,3 D as a B2 carcinogen. Recently township caps were doubled in townships where historical Telone use did not reach the maximum allowed under the caps, in general 90,000 lbs per township ( Appendix S, P) This is, however a temporary increase until the amount of Telone " banked" from previous years is used up, or the registrant convinces the California Department of Pesticide Regulation that permanent increases are justified by reassessing the oncogenic risk Township caps originally set by California were 90,250 " adjusted" pounds per township per year ( Appendix P). Adjusted pounds are actual pounds of 1,3 D applied times an application factor. This calculates out to approximately 345 acres in a township can be treated with InLine using VIF mulch. Since a township is approximately 25,000 acres, and many townships in the Northern and Southern strawberry growing regions have over a thousand acres in strawberries in many townships, obviously not all strawberries growers could use Telone products.

DPR recently doubled the township cap in many of the townships where previous use did equal the amount allowed under the old township cap ( Appendix S). In essence, the unused amount was " banked" for future use. This, however, is only a temporary solution, until the " banked" amounts are used up. Meanwhile, the 1,3 D registrant is working with DPR to revise regional modeling schemes to determine whether permanent caps should be recalculated based on each region's weather conditions. Such analysis so far is predicted to result in caps close to the current increased caps or between the old and new.

Dr. Tom Trout of USDA has provided an analysis of the impacted acres of strawberries in each county based on the old and new township cap ( Appendix P). His analysis shows at best that Telone products will not be available to 47% of the total strawberry acreage in the state. For the strawberry growing regions, his study projects unavailable acres according to the following table ( based on 2001 acreage):

Region Total Acres Straw Acres Unavailable % of Acres Watsonville 10,759 4,344 40.4% Santa Maria 3,817 1,645 43% Ventura County 7,777 4,228 54% Orange County 2,446 243 10%

Roughly half of the Southern acreage would not be able to use Telone products. And roughly 40% of the Northern acreage would not. Considering it is not economical for the Northern rotation growers, to account for concentration of non rotation acres in the same affected townships, from 40 100% of the 2,500 acres of non rotational growers acres in the Watsonville area could use the material, although they could still suffer losses using it over MBC. Much of the land in the Watsonville area however is not amenable to drip applications because of soil type and hilliness, further reducing use of the material. The 1645 acres in Santa Maria would be available and only 4,228 acres in Ventura. At best then, 8,373 strawberries acres may be able to use the material. This roughly calculates to availability to approximately 30% of strawberry growers at best even under the expanded township caps. 1,3 D is also classified as a toxic air contaminant in the state of California and will undergo additional scrutiny in future. This classification in addition to the classification of 13 D as a B 2 probable carcinogen contributes to an uncertain regulatory future in California.

Chloropicrin The California Department of Pesticide Regulation is re evaluating chloropicrin at this time with anticipated completion of the review in approximately 2 3 years. There are already sensitivities around the use of the material due to its physiological effects ( lacrimation and upper respiratory discomfort) at very low levels in the air. Chloropicrin is also currently listed as a toxic air contaminant in the state, and could be subject to additional regulatory restraints after thorough review by the Scientific Review Panel of the Air Board. Of greatest concern is what additional regulatory restraints could be in place in 2005 as a result of the DPR re evaluation, particularly increases in required buffer zones which would limit the products use in the highly urbanized strawberry growing regions.

Buffer zones for the material currently vary from county to county and depend upon local conditions such as proximity of a field to sensitive sites. In most cases if a sensitive site ( occupied buildings, residences, businesses, schools, hospitals etc.) is within 300 feet of a field, a 100 foot or more buffer zone is required depending on the size of the acreage to be fumigated at a given time. These buffer zones are actually larger than buffer zone requirements for methyl bromide applications near most sensitive sites ( 60 feet minimum depending upon application method and acres to be fumigated at a given time.) ( Appendix X)

Metam Sodium Metam sodium recently completed review as a Toxic Air Contaminant with the California Air Resources Board's Scientific Review Panel ( Appendix R). While DPR continues their re evaluation of the material there is a great deal of concern regarding eventual buffer zone requirements when all the analyses are complete. It is possible buffer zone requirements of 500 feet or more may be required in some situations, which would render the material unusable in particularly urbanized settings. If metam sodium buffer zones are increased this high, combined treatments with 1,3 D/ chloropicrin would also be rendered unfeasible particularly in urbanized settings.

Conclusion The combined foil fumigation regime of 1,3 dichloropropene, chloropicrin, and metam sodium is not economically feasible for California strawberry growers. This combined with the continual regulatory scrutiny on all three compounds renders the regime questionable in terms of future viability in California. Biofumigation All California cultivars are highly susceptible to Verticillium wilt, a devastating disease because it causes premature plant death. It is the most important pest to strawberries, and is managed in the past only with soil fumigation. The wide host range of Verticillium dahliae and wide distribution in California soils has rendered crop rotation ineffective. Broccoli can be an effective rotation crop for cauliflower and so was tested by Dr. Frank Martin of the USDA ARS in strawberry culture ( Appendix CC, Pink Sheet 01 11). While broccoli rotations reduced disease severity. Yields were only 77% of the methyl bromide/ chloropicrin control, a yield which is not economically feasible in California strawberry culture ( see economic analysis of metam sodium.)

Solarization For solarization to work, temperatures under the tarp must reach 50 ° C. Solarization has been somewhat effective in the Central Valley of California where air temperatures regularly reach the 90s and 100s during the spring summer and fall and constant sunshine is the norm ( Appendix DD, Molinar handouts). However, the San Joaquin Valley only accounts for approximately 300 acres of the 27,000 acres of strawberries produced in California in 2002.

Along the coast of California, fog and clouds predominate in the morning hours during most of the growing season, and only rarely reach 90 ° F or above. Without constant sun and high temperatures like the San Joaquin Valley, solarization is not a viable alternative to soil fumigation. Work by Dr. Steve Fennimore et al. has shown solarization utilizing single layer tarps has little impact on weed control ( Appendix FF, PMA Report.) Work continues with double layer tarps, but is so far inconclusive.

Steam In California strawberry culture, steam is not an economically feasible alternative. To control Verticillium wilt, the steam needs to penetrate more than 2 feet into the soil. The machinery needs to go slowly in the field to apply the superheated water. In doing so, an extremely large amount of water is needed to create enough steam to bring the relatively cool soil up to a temperature where sterilization can occur. That much water creates retention problems in the soil which then requires a long drying period. Soil also has to be bone dry with no clods for steam to work effectively. And finally, the fuel costs to create steam for our representative 40 acres is extremely costly.

Biological Control Dr. John Duniway of the University of California, Dr. Carolee Bull of USDA ARS, and Dr. Frank Martin of USDA ARS have done extensive work with bacterial inoculums in strawberries searching for beneficial organisms that would increase yield in the absence of soil fumigation. None of the scientists have identified effective mycorrhizal organisms ( Appendix FF, PMA Report.) This represents extensive work over 3 4 years.

Cover Crops and Mulching Cover crops are not economically feasible for strawberries growers because the economics of cropping in the California growing regions demands full use of the land year round. Nearly all strawberry growers rent their land at anywhere from $ 1000 3000 per acre. The land must be used all season long, so there is no allowance for fallowing land with cover crops such as rye, which would not bring in enough income to pay for rent in this region.

Plastic mulch has been used in strawberry culture for decades to help control moisture content of the beds and for weed control. Dr. Steve Fennimore et al. has done extensive work with colored tarps and VIF films in strawberry culture with and without chemical fumigation. Colored tarps are used primarily for weed control as an adjunct to potential alternative regimes with poor weed control.

In organic production, black and brown tarps resulted in the highest yields followed by white ( on black), red ( on brown), green, and yellow ( on brown). However, overall yields were one quarter the yields of marketable berries in fumigated strawberry culture ( Appendix FF, PMA Report.)

In conventional production, clear tarp had significantly higher yields than any of the colored tarps tested. Most colored tarps do not warm the soil as much as clear tarp, and soil temperature has a significant impact on early plant growth and berry production. Clear tarps are generally used more in the Southern region where the earlier the berry production the higher the profits. In the Northern region, colored tarps are used more, but the economics of that region requires more a long steady season of production. Black and green tarps appear to control weeds best, but at the expense of somewhat reduced yield ( PMA Report).

Experimentation with Virtually Impermeable Film ( VIF) began in California in conjunction with the use of InLine soil fumigant. While weed control is weak with the 1,3 D/ chloropicrin alternative regime, VIF film used with drip applied InLine seems to improve weed control. It is theorized that use of VIF film holds fumigant in the soil longer increasing its effectiveness. At the same time, VIF film because of this ability, increases plant back times to avoid potential phytotoxicity. Results of experiments up to now with VIF film and chemical alternatives have been quite variable. Current experimentation with VIF film is aimed at determining appropriate rates to achieve pest control without subsequent phytotoxicity to transplanted strawberries. VIF film also still suffers from quality and supply problems ( one major supplier will no longer produce the material). For instance the first year it was tested, the VIF disintegrated in the fields during the growing season because no UV barrier had been incorporated. It is also very difficult film to distribute in the fields with conventional equipment and before a large number of growers find it economically feasible to use the materials, an appropriate method of laying the material down in the field must be found. So while promising, VIF film use is still in the experimental stages and not ready for mass grower use.

Crop Rotation/ Fallow All California cultivars are highly susceptible to Verticillium wilt, a devastating disease because it causes premature plant death. It is the most important pest to strawberries, and is managed in the past only with soil fumigation. The wide host range of Verticillium dahliae and wide distribution in California soils has rendered crop rotation ineffective.

Biofumigation with crop rotation of Brassica sp. has been investigated with strawberries. Broccoli can be an effective rotation crop for cauliflower and so was tested by Dr. Frank Martin of the USDA ARS in strawberry culture ( Appendix CC, Pink Sheet 01 11). Rotations of broccoli, brussels sprouts, and lettuce. While broccoli rotations reduced disease severity, yields were only 77% of the methyl bromide/ chloropicrin control, a yield which is not economically feasible in California strawberry culture ( see economic analysis of metam sodium.)

Flooding and Water Management Water is a luxury in California. Nearly all of the water used in agriculture is from the collection of winter rains and snow melt into reservoirs. Water is an expensive commodity and is not available in a large enough quantity at a low enough price to make flooding a viable option to fumigation. Nematodes can survive in flooded fields as can Phytophthora sps which also renders this method ineffective. In addition, not all of the strawberry growing region is flat land. Much of it in the northern region around Watsonville is quite hilly, precluding any ability to successfully flood the fields and retain the water. As more water originally destined for agriculture is funneled into the burgeoning urban areas, it is becoming an even more precious commodity for growers. Flooding is not feasible technically or economically in this state.

General IPM California Strawberry growers already use an established and comprehensive IPM program. For example, predatory mites are introduced early into fields to control two spotted spider mites. Much of the cultural practices already in place are part of that IPM program. Unfortunately, they have not yet found a nonchemical IPM practice alone to control Verticillium Wilt or Phytophthora sp., the main soil borne diseases in strawberries ( Appendix D, Crop Profile). Only utilizing land in which no susceptible crops have ever been ( http:// www. ipm. ucdavis. edu/ PMG/ selectnewpest. strawberry. html) has some success, a very unlikely prospect in the heavily farmed strawberry growing regions.

Grafting/ Resistant Root Stock/ Plant Breeding Strawberry plants cannot be grafted this only applies to tree crops.

Plant breeding efforts are hampered by the severity and number of diseases that affect California strawberries. The University plant breeders, Dr. Doug Shaw and Dr. Kirk Larson, have tried, testing 49 strawberry genotypes over the course of 7 years in fumigated and non fumigate soil ( Appendix GG, Shaw and Larson 2001). They found no evidence of genes conferring specific adaptation to nonfumigated soils, or that genes that can confer resistance are selected out by continual growth on non fumigated soil. Efforts will continue, but even if genes were identified today in available cultivars, breeding, selection, testing, and scale up to commercial scale still take 6 7 years.

Organic Amendments/ Compost Organic amendments and composting have also been tested extensively in California strawberry culture. Dr John Duniway et al. ( Appendix FF, PMA Report) have experimented with composting and high nitrogen amendments in Verticillium infested soil in strawberry production using blood, feather, and fish meal at 8, 4, and 8 tons/ acre respectively. While reducing Verticillium wilt, these treatments were also phytotoxic to strawberries, not to mention very expensive at these rates. In addition, chicken manure and mature compost were tested at 8 and 12 tons/ acre respectively as well as stabilized urea, none of which reduced Verticillium wilt significantly.

See Biological Control for discussion of microorganism inoculum as an amendment.

Organic Production Organic production of strawberries in California is difficult. Only 383 acres of organic strawberries were projected for the 2002 season. Successful acreage is largely due to having the land available which has little to no Verticillium wilt and other components of the strawberry pest complex. As reported most recently at the MBAO 2001 conference by Dr. Frank Sances ( Appendix EE), organic culture was slow, with significantly lower yields than conventional culture. In addition, weed growth resulted in very high hand weeding costs. In another study by Dr. Steve Fennimore, yields in organic culture were at best 28% of conventional culture using soil fumigation. While research continues on organic cultural techniques, root diseases take the heaviest toll on organic strawberries ( Appendix EE, Sances 2001.) The most striking reality of strawberry production without soil fumigation was to remember what strawberry yields and culture were like before the advent of soil fumigation in the late 1950' s. Then, even with the continually improving University cultivars, average yields of strawberries were approximately 5,000 lbs per acre ( Appendix GG, Wilhelm.) Compared to the on average 50,000 lbs per acre achieved with soil fumigation with MBC, organic culture would never be able to replace conventional strawberry production in California.

Resistant Cultivars Work by Browne et al. ( Appendix CC, Pink Sheet 02 09) indicates that the major University derived strawberry cultivars used in California are moderately to highly susceptible to Phytophthora sp. While some other cultivars in the country show some potentially useful resistance, breeding with them if they were available would take 6 7 years before they were available to growers. Shaw and Larson's work also support the lack of sufficient genes in strawberry genotypes to withstand culture in non fumigated soil ( Appendix GG, Shaw and Larson 2001)

All California cultivars are highly susceptible to Verticillium wilt, a devastating disease because it causes premature plant death. It is the most important pest to strawberries, and is managed in the past only with soil fumigation ( Appendix FF, PMA Report).

Soilless Culture Soilless culture is another very expensive cultural practice not feasible in California strawberry production. Soilless culture takes up enormous greenhouse space, resource and energy requirements for climate control, and would require off season premium prices for strawberries to approach economic feasibility. The capital outlay alone to construct enough greenhouses to accommodate half a billion strawberry plants is unfathomable. Production strawberries are grown in high density culture in fields because it is the most economical way to produce large quantities of affordable strawberries. Substrates/ Plug Plants The economics of production with substrates is equally prohibitive to that of soilless culture discussed above for large scale California strawberry production. Rockwool for instance is not a cheap material and it is doubtful sufficient quantities exist to grow the over half a billion strawberry plants currently grown in California strawberry production. Substrate culture also requires greenhouses, expensive to build and maintain. Substrate culture has only been successful on small scale, off season ( therefore high prices), such as the Netherlands, where their strawberry production is a fraction of California production.

Plug plants are used to a small extent in California strawberry production. Usually only Southern growers plant them for the very early, high revenue market. Only Southern growers can do plug plants, usually only 2 4 rows, because only short day varieties are amenable to plug plant culture. The day neutral varieties used in the north cannot be converted to plug plants because of the need for dormancy before planting. In addition, Northern markets never harvest in time for sufficient prices to make up the difference in the price of plug plants, 25 cents per plug plant versus 4 5 cents regular plants. The price difference adds $ 5,400 per acre operating cost to a grower if he were to convert completely to plug plants. With the small margins in strawberry production, the additional costs cannot be made up. Pest Complex Controlled by Methyl Bromide/ Chloropicrin Soil Fumigation Pre plant soil fumigation with methyl bromide combined with chloropicrin has been in use in California strawberry production for over forty years. The regime controls a number of soil borne diseases, arthropods, nematodes, and weeds. In searching for chemical and non chemical alternative regimes, the entire pest complex needs to be controlled. Key pests controlled by methyl bromide, and their importance as economic pest is found in Table 1, Pest Complex, in the application form. In addition, the 7 chemical regimes from the U. S. EPA matrix and their efficacy against these pests are listed in Table 1. [ Labels ( Appendix G), Crop Profile ( Appendix D), Integrated Pest Management for Strawberries, Univeristy of California, Statewide Integrated Pest Management Project, Division of Agriculture and Natural Resources, Publication 3351, 1994 http:// www. ipm. ucdavis. edu/ PMG/ selectnewpest. strawberry. html, Field Day Handout Fennimore 2002 ( Appendix DD)]

At this time in California, the key primary pests controlled by methyl bromide/ chloropicrin soil fumigation are Verticillium Wilt, Phytophthora diseases and a number of weeds. Nematodes are important and have probably been kept in check largely through the decades of soil fumigation and the California Department of Food and Agriculture certification program requiring nursery stock to be free of nematode pests before intrastate transport and transplanting. The arthropod complex has also been kept in check to some degree with the decades of soil fumigation.

What is unknown is to what degree the importance and impact of some of these pests will change with repeated use of alternatives with apparent technical feasibility. For instance, Dr. Frank Martin studies " root nibler" diseases such as black root rot, currently controlled by methyl bromide and chloropicrin mixtures, but which may grow into a much larger problem with some technically feasible alternatives. ( Martin 2001Handout, Appendix DD). Similar problems could erupt with the arthropod complex For instance, arthropods not consider significant pests at this time such as root weevils and Strawberry rootworms, were significant pests in the 1950' s before the advent of soil fumigation ( Dr. Frank Zalom, 2002 Appendix H). Representative User Description Introduction Strawberry production is an important component of the agricultural industry in the state of California. California produces 83% of the strawberries consumed in the United States and 20% of the strawberries consumed in the rest of the world on 50% of the US acreage. California strawberries brought a yearly average of $ 734,000,000 gross revenues to the state in the last five years produced on an average of 25,000 acres along the south and central coast of California ( California Strawberry Commission, http:// www. nass. usda. gov/ ca/).

Nearly all of the acreage is farmed by small family farmers along the coast from San Diego to Santa Cruz ( Appendix A). The mean size farm is approximately 40 acres, and 71% of the growers farm on 50 acres or less ( see Worksheet 5). The coastal areas constitute 99% of the production strawberry acres in the state. The strawberry industry employs approximately 65,000 people throughout the growing regions. Communities in strawberry growing areas are heavily dependent on the industry for major portions of their local economies. Before fumigation, over 40 years ago, yields averaged 5 tons per acre, although variability of yields was high due largely to pressure from soil borne diseases which could wipe out a filed in a matter of weeks ( Wilhelm, Appendix GG). Although some of the change in production is due to new varieties with higher yields, today's average yield of 25 tons per acre with pre plant soil fumigation with methyl bromide/ chloropicrin is less variable. But in today's markets and in today's highly regulated environment revenue from 25 tons per acre barely pays for the costs of production.

California Strawberry Culture ( from California Strawberry Crop Profile) Strawberries have been described as a perennial crop grown as an annual. To a large extent this is true once the strawberry plant reaches the production field. But strawberries are also a fragile fruit, highly perishable and susceptible to a multitude of diseases and pests. Hence great care is taken in all stages of strawberry production including a dependence upon soil fumigation in the strawberry nursery to ensure healthy stock for berry production. Included in this package is a Power Point presentation, Overview of the California Strawberry Industry ( Appendix J).

Nursery Propagation of Strawberry Stock The berry producing plant starts five years earlier as nuclear plant stock from Foundation Plant Materials Services at the University of California or from inhouse meristem and clean stock programs in individual nurseries. The nuclear plant stock is planted in hanging pots in heat chambers, and allowed to produce aerial runners, which never touch the ground. These runners are then meristemmed to produce virus and disease free plants. The clean, meristemmed plants are then planted in the second year in an enclosed screenhouse ( the first foundation generation) where there is 100% testing for virus and nematodes through the California Department of Food and Agriculture Certification Program. The plants are also checked for diseases and pests as well as checked for " true to type". The plants that test clean, are then planted the following year in an outside foundation block where, again, they are tested for virus and nematodes and visually inspected through out the season for pests and diseases. Before planting either in the screenhouse or in the outside foundation field, it is critical that the ground be thoroughly fumigated to control diseases and pests that could infect the clean plants. Pre plant fumigation is required by the California Department of Food and Agriculture Certification Program.

From there, the stock is multiplied in the field over the course of two more years, one more generation in the field at low elevation nursery locations ( to produce registered stock) and the final generation in the field at high elevation nursery locations ( to produce certified stock). In these fields as well, it is critical that ground be fumigated before each transplanting event. The plants are certified under the California Department of Agriculture to be free of nematodes and viruses. Finally, in year six the certified planting stock is planted in the fruit production field. It is vital that the fruit producer receive clean, pest and pathogen free planting stock from the nursery. Once planted into production fields, transplants are dormant and in a weakened state requiring clean fumigated soil to help fight off pests and diseases while taking root in their new environment through the winter.

Fumigation. Several weeks before planting, in all but the organically grown acreage, the soil is fumigated with a combination of methyl bromide and chloropicrin applied under a sealed plastic tarp ( mulch), which is removed after 5 days. Methyl bromide alternatives are also beginning to be used including drip applied 1,3 dichloropropene, chloropicrin, and combinations thereof, with and without metam sodium. For drip applied materials and bed fumigation with methyl bromide, beds are preformed and tarped before the fumigation occurs. For flat, or broadcast fumigation, the ground is first fumigated and then, after an appropriate waiting period to allow the chemical to dissipate, the ground is reworked. Raised beds are formed, irrigation tape laid, and beds covered with the plastic mulch, sheets of thin plastic which are laid over the top of the soil.

Mulch. Plastic mulch is used primarily to maintain adequate soil temperatures for root growth but also prevents the strawberries from coming into contract with soil. This reduces pathogen transfer to the fruit and it also enhances soil warming while improving water management. The color of the tarp chosen for use determines the efficiency in promoting soil temperatures and/ or weed control. Typically, clear polyethylene mulch is used which is best for warming the soil and increasing early plant growth. In all growing regions, use of black or colored tarps reduce weed populations but can result in a 10% early yield reduction due to less effective soil warming. Typcially fields tarped with clear vs colored tarp come into production earlier when the market price is higher Planting. Clean plants, purchased from certified nurseries, are planted in raised beds of fumigated soil containing irrigation drip tape and with plastic mulch covering the beds. The soil is fumigated before planting. Drip tape and plastic mulch may be laid down before planting, in which case plants are planted in holes made in the plastic. Otherwise plants are planted directly into a planting slot if the beds and drip tape is laid down during the planting process. Strawberry plants are hand planted in the fruit production fields. The plastic mulch stays in place until the fruit production season is finished and the plants are removed. In the northern growing regions beds usually only contain two rows of plants while the southern regions have somewhat wider beds with four rows of plants.

Harvesting. The grower assumes control of all operations related to harvest. Once harvesting commences, hand harvesting continues for several months on a 3 to 5 day cycle for fresh berries and a 5 to 7 day cycle for processing berries. Harvest season in Southern California generally begins in January and continues through May for fresh market fruit, through June or July for processing fruit. Harvest season in the more Northern Districts begins in March or April and continues through October or November depending on weather conditions. The Camarosa variety, used predominantly in Southern Districts, allows for the harvesting of fresh berries for the bulk of the season, followed by the harvest of processing berries in the last couple months. Diamante is the predominant variety for the northern districts and is mainly suited for fresh production.

The bulk of the crop is planted in fall for winter through summer production. Smaller acreage of spring and summer planted strawberries planted in the Southern district are harvested from late October through January. With such a long harvest season and day to day picking, this is one of the few crops in California that offers long term stability to large numbers of workers in one location. This fuels any number of local economies and offers families educational and economic opportunities that employment with other crops cannot provide.

Fresh strawberries are harvested carefully by hand and are not subject to washing at the time of harvest or subsequent cooling. Processing berries are also carefully harvested and the calyx removed in the field with a harvesting tool. Processing berries are gently washed at the packing facility. Harvested strawberries are placed in trucks within an hour or two of picking and transported to the cooling facility. Strawberries are typically forced air cooled at temperatures of 34 ° F one to four hours after harvest. Cooling reduces decay and prolongs the fruit shelf life. Nearly all fresh strawberries are shipped in high nitrogen atmosphere to the market in refrigerated trucks, at temperatures in the range of 34 36 ° F during shipment. The following examples are provided to indicate typical times associated with the harvesting, cooling, and shipping operations:

Time After Harvest Activity Day 1 Harvest. Delivery to yard and cooling ( 1 4 hours).

Day 2 6 Shipping within the United States: To Seattle 1 day To Denver 2 days To Chicago 3 days To New York/ Boston 4 days Receiving dock to supermarket: 1 day Day 2 6 Shipping outside the United States: Canada 3 5 days Mexico 3 5 days Japan( air freight) 1 day Varieties. Over a dozen major cultivars of strawberries are grown commercially in California. Strawberry cultivars are developed based on several factors including desired day length, productivity, fruit size, flavor, appearance, and vigor. Cultivars vary in their susceptibility to some pests and abiotic disorders. In 2001, the Camarosa strawberry variety was planted in 43% of the state's acreage, with the Diamante variety planted in 20% of the acreage. Proprietary varieties account for 29% of the acreage. Other varieties, for instance Chandler and Aromas, comprised 8% of the cultivars in 2001. Two new varieties developed by the University of California, Ventana and Camino Real, were released for the 2002 growing season.

The primary cultivar grown in the central and southern coastal regions is the short day cultivar Camarosa, with this variety accounting for 98%, 55%, and 74% of the acreage in the Orange/ San Diego, Oxnard, and Santa Maria districts, respectively in 2001. In contrast, Camarosa is only 14% of the Watsonville/ Salinas district. The day neutral variety Diamante and other day neutral, proprietary varieties are primarily used in the Watsonville/ Salinas district whereas the short day variety Chandler predominates in the San Joaquin Valley. Other cultivars that are grown include Seascape, Aromas, and Selva. Specific planting and harvest seasons vary from one growing area to another; however, two planting seasons are used in most areas although winter planting is by far the preferred planting season. Summer plantings in Southern areas are usually are made in July or August, summer planting in Northern areas in August or September. The main, winter planting season for the Southern areas are the last week of September through the first half of October. The winter planting season for the Northern districits starts in mid October with short day varieties and continues into mid November for strong day neutral varieties.

Cultural Practices. Decisions related to various cultural practices are made daily by growers. Decisions related to field selection, soil nutrient supplements, and cultivars are made well in advance of planting. Fields are graded and planting beds designed to allow proper drainage and irrigation. Clean tillage, raised beds, plastic mulches and water management are all aspects of a systems approach practiced by California strawberry growers.

Crop Rotation. Strawberry fields are sometimes rotated with another cash crop such as beans, broccoli, lettuce, and cauliflower to reduce pest populations and improve soil structure. Cover crops such as rye or barley, are also sometimes rotated but where land and water costs are high, cover crops are not economically feasible.

Sanitary Techniques. Growers rely on high quality pathogen free cultivar transplants and the Strawberry Certification Program overseen by the California Department of Food and Agriculture to help maintain their field free of pests and pathogens. The certification program is based on nursery soil treatment with methyl bromide prior to planting. Grower are also developing improved field sanitations methods when possible including such measures, working the " cleanest" ( pathogen free) fields first, rinsing the equipment with hot water to remove soil and plant debris before moving people and equipment into another field. Weeds are removed by hand from and around strawberry fields before they produce seed. Growers also try to ensure that manure or other organic amendments added to the fields have been properly composted or sterilized.

Pesticide Application Practices. All applications of pesticides in California are under the control of the growers, and/ or their Pest Control Adviser ( PCA), or Pest Control Operator ( PCO). Growers, PCAs, and PCOs work closely to insure that only registered pesticide products are used and that they are applied in compliance with all state and federal laws, rules and regulations, and labeled recommendations.

Communication between growers, PCAs, and PCOs is maintained during the planting and production periods through frequent field visitations by grower representatives and/ or their PCAs. The applicator must inform all affected parties in close proximity to the intended treated area ( e. g., harvesting crews, weeding crews, irrigators, etc.) of their intent to apply pesticides in advance of the application and must also post fields and file post application paperwork with the appropriate state and/ or federal agency. Closed systems are also mandatory for the application of Toxicity Category I pesticides in California.

Fall planted berries are hand weeded approximately multiple times during the season, soon after planting, and again in January or March and then as needed throughout the season. Runner are cut multiple times during the season at the same times crews are weeding the fields. Strawberries are all hand harvested, once or twice a week from depending on time of year and varietal production patterns. Most of the fruit is picked two times a week on a two or three day rotational cycle. . Picking crews generally work six days a week during this period. Processing berries, usually picked toward the end of the season in Southern California, are generally picked once a week. In the northern districts, processing berries are picked on the same schedule as fresh market fruit. The decision to switch from fresh to processed product is determined by fruit quality and market conditions. Irrigation, fertilization, and many pesticide applications are done through drip irrigation. Sprinkler irrigation is only done right after planting from October through Thanksgiving. Summer planted berries have similar regimes.

Summary Pre plant soil fumigation allows production of approximately 650,000 tons of strawberries on the total acreage equivalent to one township, approximately 25,000 acres. Strawberry production in California reflects one of the most environmentally friendly facts about modern, high intensity agriculture; high quality productivity impacting fewer and fewer acres.

Representative User The representative strawberry production grower in California is a small family farmer who grows strawberries on an average of 40 acres of rented land along the south or central coast of California ( growing region map.) The grower usually fumigates the soil and plants in the fall for harvest during the winter, spring and summer of the following year. Two distinct regions can be identified with somewhat different harvest schedules although their overall economics of costs and revenues are nearly identical. In 2001, the Southern region ( 41% of total acreage) resides along the coast in Orange and San Diego counties plus the Oxnard plain in Ventura County ( Appendix A). This region plants early and starts harvesting early, profiting from higher berry prices due to limited supply and high demand. In 2001, the Northern region ( 58% of total acreage) resides along the Santa Maria coast in northern Santa Barbara and San Luis Obispo counties plus the Watsonville coast of Santa Cruz and northern Monterey counties ( Appendix A). This region plants a little later and harvests later over a longer time period, profiting from high volume through a long season into early fall.

We have three representative users to discuss for purposes of this application, two for the Northern Region and one for the Southern Region. Since the economics of production and farm production practices of each of these regions overlaps with many of the sub markets, we feel these users adequately represent the entire consortium of California Strawberry growers.

Southern Region Representative User.

Soil fumigation occurs in July September with planting commencing in late September and early October. Flat, or broadcast, soil fumigation with methyl bromide and chloropicrin formulations are the predominant method, usually a custom application done by a fumigation company. When flat fuming, the ground is disked, plowed and leveled, and sprinklers are put in. After a thorough irrigation, the pipes are pulled and the edges are disked when dry enough to prepare for fumigation. At the proper moisture level the ground is flat fumed, a method in which a tractor injects methyl bromide into the ground and immediately ( on the same tractor) the ground is covered with plastic. With each pass the tarp is glued to the tarp from the previous pass so that when finished the field is sealed with one continuous sheet of plastic. After at least 5 days, the plastic is cut and removed, the field re irrigated, and at the proper moisture level, beds are pulled up. Usually any broadcast applications of fertilizer/ amendments are done just before the beds are made. As the beds are pulled a slow release fertilizer is placed into the top of the bed. The drip tape for irrigation is then laid in the bed and the plastic mulch is applied. Slits are mechanically cut into the plastic mulch on the beds and nursery transplants placed into the holes at least 7 days after the fumigation, usually longer because of the field preparation time. Sprinklers are put in the field and supplement irrigation after planting for the first two months.

Timing of fumigation activities are governed primarily by when growers need to plant the new crop for the next season. Planting in the southern region needs to be done by mid October at the latest and can occur as early as late September to get the level of growth and berry production necessary for producing at the earliest possible date when prices are highest. By May and June most of the harvest switches over to processed freezer berries, which generally run half the price of fresh berries.

The plants after harvest is complete are usually removed by the beginning of July to provide adequate preparation time for fumigation and planting for the following season. Such activities consist of taking down old beds, reworking the ground and irrigating to proper moisture levels ( 2 3 weeks) and fumigating the soil ( under current California regulations 1 3 weeks depending on size of the fields and proximity to sensitive areas). Additional time needs to be incorporated for the plant back time of at least 7 days from the time of fumigation with methyl bromide/ chloropicrin ( MBC), and the additional time for bed formation, preparation and mulching, and finally planting of transplants for the next season.

The Southern Region winter planted varieties are short day cultivars and are planted in late September and early October. Growers use high quality pathogen free cultivar transplants thanks to the Strawberry Certification Program of the California Department of Food and Agriculture and the production practices of the California strawberry nurseries, to help maintain their fields free of pathogens. The certification program is based on nursery soil treatment with methyl bromide prior to planting.

After planting, transplants grow vegetatively the first two months and start producing marketable berries in January and continue in fresh production into May, sometimes June, before switching to freezer ( processed) production. In some cases, lower quality berries during the primary fresh picking season are also harvested separately for juice production. Once harvesting commences, hand harvesting continues for several months on a 3 to 5 day cycle for fresh berries and a 5 to 7 day cycle for processing berries. This continual harvesting ceases when the productivity of the field diminishes significantly. The predominant variety in the Southern region, Camarosa ( 65% in 2001, Appendix B), allows harvesting of fresh berries for the bulk of the season, followed by processing berries in the last couple months of harvest. The remaining 35% of acres are planted in proprietary varieties.

Fresh harvest lasts 26 weeks in the south, ( January 1 through June 30), and processed harvest will last 17 weeks ( mid April to mid August) ( Appendix K, Economics Spreadsheet, Tab " 2001 Fresh Prices"). Fresh strawberries are harvested carefully by hand every three to five days and are not subject to washing at the time of harvest or subsequent cooling. Processing berries are also hand harvested once a week and the calyx removed in the field with a harvesting tool. Processing berries are gently washed at the packing facility. Harvested strawberries are placed in trucks within an hour or two of picking and transported to the cooling facility. Strawberries are typically forced air cooled at temperatures of 34 ° F one to four hours after harvest. Cooling reduces decay and prolongs the fruit shelf life.

Nearly all fresh strawberries are shipped to the market in refrigerated trucks, at temperatures in the range of 34 36 ° F during shipment. Transportation by truck across North America takes from 2 6 days to the retail markets.

Northern Region Representative Growers Much of the practices in the North mirror the South. Custom flat fumigation by contract fumigation companies is the norm, although some grower conducted bed fumigation ( see below) is done in this region. Differences between the regions are in fumigation timing, September through November for the North, and planting times.

Watsonville is predominantly winter planted with fresh plants. If the plants are short day varieties ( Camarosa), then they are dug out of the nurseries in early October, and planted with about one week additional cold storage. These plants, depending on the weather, will start producing in late March or early April and continue into August. If a day neutral variety ( Diamante) is being planted in the Watsonville area, then the plants are dug out of the nursery in mid to late October, and given from 3 to 5 weeks additional cold storage before planting. The actual start date of production is very variety dependent but they should start producing in April and continue until the rain starts in the fall ( sometime in October or November). So planting in the North can run from mid October through November.

The predominant cultivar in the Northern Region is Diamante ( 35% of acreage in 2001), a day neutral variety. Camarosa is also grown, mostly in the Santa Maria area ( 29% of acreage in 2001, Appendix B). Propriety varieties constitute 27% of the acreage. The remaining 9% are small acreages of other varieties.

Harvest timings run longer in the North than the South. Fresh harvest ran 35 weeks in 2001, from mid March through mid November. Processed harvest runs mid April through mid November, 31 weeks in 2001 ( Appendix K, Economics Spreadsheet, Tab " 2001 Prices").

Approximately half of the growers in the northern region alternate the fields they use for strawberry production with vegetable growers over the course of two years ( three quarters of Watsonville, none of Santa Maria). A field fumigated in the fall is taken through production into October or November and then turned over to a vegetable grower, who may grow two to three crops of lettuce, broccoli, celery, or some other annual vegetable through the next year. The land will then go back to the strawberry grower at the end of the next summer or early fall in time for soil fumigation and start of another strawberry cycle, typically the end of September. We are calling this representative grower the Rotation grower.

If a grower is going from strawberries to strawberries, they will not harvest through November, but pull the crop our earlier in order to have time to do prep and fumigation and plant mid late October or November. This system requires pulling out last years crop at the latest at the end of September. This shortens their harvest time and reduces their overall revenue compared to rotating growers. This would be a worst case scenario financially for the Northern grower. We are calling this grower the Non Rotation grower.

For rotation growers getting the land back from the vegetable growers in a timely fashion is essential. A rotational grower can experience a time crunch relating to their fumigation operation if they cannot get ground back by mid September. This can through the fumigation and planting schedules out of the optimum window. Planting even a week or two beyond the window for the cultivar can significantly reduce yields for the coming season ( Shaw, Larson personal communication). In addition, this grower must flat fumigate before planting strawberries to ensure complete coverage and pest control of the entire field or the vegetable grower will not accept the land for vegetables following the strawberry plant. For instance, drip fumigation does not control pests and weeds along the sides of beds or in the furrows. Without thorough fumigation the vegetable grower faces intense and spotty pest pressure when the field is turned over to vegetables.

All of these aspects become important when addressing alternatives and their longer plant back and preparation times. Given longer times for field preparation and longer plant back waiting periods required for alternative fumigants, rotation growers may find themselves in a position of not being able to obtain land for the next season. Or the rotation grower, to obtain land, must take the land from the vegetable grower early, preventing that grower from growing a second or third vegetable crop. In the best case, the consequence to the strawberry grower is to pay approximately ¼ year's extra land rent, on average about $ 525/ acre ( land rent is $ 1,800 2,400 per acre, or an average of $ 2,100 per acre). The additional time can be used by the strawberry grower for ground prep and fumigation to accommodate longer prep times and plant back times of the alternatives. It is also likely the strawberry grower will also have to compensate the vegetable grower for lost crop, which would further increase the rotation growers costs.

The non rotation grower already suffers from less revenue per year because he must pull crop by the end of September, at the latest of continuing to harvest through mid November in the same manner as the rotational grower. For longer field preparation and plant back times with alternatives, the non rotation grower will have to pull crop even sooner to have sufficient time to fumigate and plant in the proper planting window for the next season.

To deal with the somewhat different economics of the rotation and non rotation scenario, and to account for growers who may do both, the economics are separated in the application, but the final net income result is averaged. The worst case scenario is still the non rotational grower. But also taking into consideration that in the economics we have left out overhead costs to provide an overall best case scenario. If overhead costs are included, all growers average in the red.

Bed Fumigation Fewer and fewer growers are conducting bed fumigation, largely because of permit restrictions and buffer zones imposed by the California Department of Pesticide Regulation. Less than 10% of growers do bed fumigation anymore, and that percentage continues to drop because of the current state promulgated permit requirements which require such large buffer zones that bed fumigation is no longer feasible or cost effective for many growers. There are no growers that can do exclusively bed fumigation any longer.

When bed fuming, the field is disked, plowed and leveled, and sprinklers are put in for pre irrigation. At the proper moisture level the pipes are pulled, any broadcast application to be made is done, the ends are disked and the beds are pulled. The irrigation drip tape is then laid and another tractor injects fumigant while laying the plastic mulch. Planting cannot be done for 14 to 21 days. Costs for bed fuming generally run $ 1000 per acre less than custom flat fumigation, hence many small growers prefer to do bed fumigation to significantly reduce their costs of production.

To deal with this for representative user, the economic baseline for the Northern grower is a weighted average of the Cost of Production documents for the Santa Maria area and the Watsonville area since the Santa Maria COP is based on bed fumigation costs. Since most growers who do bed fumigation combine bed with flat fumigation, this weighted average is actually more representative of average costs for the Northern region.

Costs of Production and Revenues Three Cost of Production documents ( COP) were completed in 2001 by the University of California, Davis, Cooperative Extension based on interviews with representative growers in three regions, Ventura County, Santa Maria Valley, and the Monterey & Santa Cruz County region ( Appendix L, http:// coststudies. usdavis. edu). Based on typical harvest schedules in these regions, the Santa Maria Valley parallels much more closely the berry production and harvest schedule of the northern most region Monterey & Santa Cruz counties (" 2001 Prices tab", Appendix K). Ventura County also represents the most southern regions of Orange and San Diego County in harvest schedule and practices. We have therefore used the data from these studies to represent the Northern and Southern growers in California.

The COPs are far more detailed than needed for the economic feasibility portion of the CUE. So various detail activities are combined into more general cost areas, which would not typically change with use of alternatives ( Worksheets 2 E of Application).

Conclusion California strawberry production is nearly completely represented by these three economic representative growers. Production is highly dependent on results of soil fumigation with methyl bromide chloropicrin mixtures. Even so, this highly productive agricultural system in today's markets has very little profit margin. So even seemingly small yield losses can result in bankruptcy. Transitions to alternatives must be done carefully to avoid losses that put a grower out of business before he's been able to determine optimal conditions in his specific circumstances of soil, geography, and pest pressure with any promising alternative. 20a. Why is this representative user typical?

The three Northern and Southern Representative Users represents 85% of the growers in the consortium. Even though their market timing is different, the costs of production per acre are remarkably the same and the cultural practices are almost identical with some differences in timing of specific operations.