+--------------------+-------------------------------------------------+
| **[Nominating      | # The United States of America                  |
| Par                |                                                 |
| ty:]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+
| **[Brief           | [Methyl Bromide Critical Use Nomination for     |
| Descriptive Title  | Preplant Soil Use for Strawberries Grown for    |
| of                 | Fruit in Open Fields on Plastic                 |
| Nominati           | Tarps]{.smallcaps}                              |
| on:]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+
| **[Document        | CUN 2003/059, USc6N11                           |
| Num                |                                                 |
| ber]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+
| **[D               | August 12, 2004                                 |
| ate]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+

Table 1. Region, Key Pests, and Specific Reason for Methyl Bromide in
Ornamentals

+--------------+-----------------------+-------------------------------+
| **[Region    | **[Key disease(s) and | **[Specific reasons why       |
| where methyl | weed(s) to genus and, | methyl bromide                |
| bromide use  | if known, to species  | needed]{.smallcaps}\          |
| is           | level]{.smallcaps}**  | **                            |
| requested]{. |                       |                               |
| smallcaps}** |                       |                               |
+--------------+-----------------------+-------------------------------+
| ###          | **Diseases:** Black   | At moderate to severe pest    |
| # California | root rot              | pressure only MB can          |
|              | *(Rhizoctinia* and    | effectively control the       |
|              | *Pythium* spp.),      | target pests found in         |
|              | crown rot             | California, specifically in   |
|              | (*Phytophthora        | areas where hilly terrain     |
|              | cactorum*),           | would provide less efficacy   |
|              |                       | from the alternatives. Uses   |
|              | **Nematodes:** root   | of alternatives are limited   |
|              | knot nematode         | by regulatory restrictions    |
|              | (*Meloidogyne* spp.)  | such as the township caps on  |
|              | Sting nematode        | the amount of                 |
|              | (*Belonolaimus* spp.) | 1,3-dichloropropene that can  |
|              |                       | be used. MB applications in   |
|              | **Weeds:** Yellow     | strawberries are typically    |
|              | nutsedge (*Cyperus    | made using 67:33 or, where    |
|              | esculentus*), purple  | feasible, 57:43 mixtures with |
|              | nutsedge (*Cyperus    | chloropicrin under plastic    |
|              | rotundus*), ryegrass, | mulch. Related dosage rates   |
|              | and winter annual     | of 196 kg/ha are below the    |
|              | weeds.                | threshold in the MBTOC 2002   |
|              |                       | Report, making further        |
|              |                       | reduction difficult to        |
|              |                       | achieve without compromising  |
|              |                       | pest management.              |
+--------------+-----------------------+-------------------------------+
| ####         | **Diseases:** Black   | At moderate to severe pest    |
| Eastern U.S. | Root Rot (*Pythium,*  | pressure only MB can          |
|              | *Rhizoctonia*), Crown | effectively control the       |
|              | rot (*Phytopthora     | target pests found in the     |
|              | cactorum*),           | Eastern United States. In     |
|              |                       | addition, buffer zones        |
|              | **Nematodes:** Root   | associated with the use of    |
|              | knot nematode         | alternatives prevents their   |
|              | (*Meloidogyne* spp.)  | use in some situations.       |
|              |                       | Related dosage rates of 151   |
|              | **Weeds:** Yellow     | kg/ha are below the threshold |
|              | nutsedge (*Cyperus    | in the MBTOC 2002 Report,     |
|              | escultentus*), Purple | making further reduction      |
|              | nutsedge (*Cyperus    | difficult to achieve without  |
|              | rotundus)*            | compromising pest management. |
|              |                       |                               |
|              | Ryegrass (*Lolium*    |                               |
|              | spp.)                 |                               |
+--------------+-----------------------+-------------------------------+
| ### Florida  | **Diseases:**         | At moderate to severe pest    |
|              | Phytophthora, Crown   | pressure only MB can          |
|              | Rot (*P. citricola,   | effectively control the       |
|              | P. cactorum*)         | target pests found in         |
|              |                       | Florida. In addition, the use |
|              | **Nematodes:** Sting  | of alternatives are limited   |
|              | (*Belonolaimus        | in some areas because the     |
|              | longicaudatus*),      | soil overlays a vulnerable    |
|              | Root-knot             | water table (karst            |
|              | (*Meloidogyne* spp.)  | topography). MB applications  |
|              |                       | in strawberries are typically |
|              | **Weeds:** Yellow     | made using 67:33 or, where    |
|              | nutsedge (*Cyperus    | feasible, 50:50 mixtures with |
|              | esculentus*), Purple  | chloropicrin under plastic    |
|              | nutsedge (*Cyperus    | mulch. Related dosage rates   |
|              | rotundus*), Carolina  | of 185 kg/ha are below the    |
|              | Geranium (*G.         | threshold in the MBTOC 2002   |
|              | carolinianum*),       | Report, making further        |
|              | Cut-leaf Evening      | reduction difficult to        |
|              | Primrose (*Onoethera  | achieve without compromising  |
|              | laciniata*)           | pest management.              |
+--------------+-----------------------+-------------------------------+

**[[Amount Of Methyl Bromide Nominated]{.underline}]{.smallcaps}**

**[Table 2. Amount of methyl bromide Nominated by the U.S. in 2005\* and
2006.]{.smallcaps}**

  --------------------- --------------------- -------------------------------------------
  **[2005\*             **[2006               **[Description of Differences Between
  (kg)]{.smallcaps}**   (kg)]{.smallcaps}**   Years]{.smallcaps}**

  2,187,535             1,918,400             The amount of methyl bromide nominated for
                                              California was reduced for 2006 because of
                                              increased use of alternatives. The
                                              estimates of key pest pressure in Florida
                                              and eastern U.S. were adjusted upwards
                                              based on new survey data. The U.S. imposed
                                              a reduction in use rate on California and
                                              Florida.
  --------------------- --------------------- -------------------------------------------

\* 2005 Nomination includes 2005 Supplemental Requested nomination
amount.

**[Figure 1. U.S. Total, Requested, and Nominated Hectares of Strawberry
Fruit]{.smallcaps}**

![](media/image1.wmf)

Footnote: Total hectares, based on United States Department of
Agriculture Statistics, are national acreage in production for this
sector. The requested hectares are sum total of all areas in the CUE
applications. The nominated hectares reflect reductions of the requested
hectares to ensure that no double-counting, growth, etc. were included
and that the amount was only sufficient to cover situations (key pests,
regulatory requirements, etc.) where alternatives could not be used.
Total pounds of methyl bromide nominated by the United States government
for this sector are based on these nominated hectares.

See the accompanying spreadsheet 2006 Bromide Usage Numerical Index or
"BUNI" **(Filename: USA 2006 BUNI -- Refined Nomination Package.xls)**
for more detailed information on how the nominated amount was
determined.

**[[Economic Impacts]{.underline}]{.smallcaps}**

The economic impacts were assessed using four economic parameters: 1.
loss per hectare, 2. loss per kilogram of methyl bromide, 3. loss as a
percentage of gross revenue, and 4. loss as a percentage of net revenue.
This assessment compares methyl bromide to the best available
alternative to determine the economic feasibility of using that
alternative. A range of alternatives were examined to determine the best
available alternative scenario taking into account yield loss estimates
and cost increase estimates. The result of the economic impact analysis
is presented in the BUNI analysis. In this sector, no alternatives were
found to be both technically and economically feasible for the
particular circumstances nominated for the CUE.

**[[Response to Questions]{.underline}]{.smallcaps}**

*In general, there are a variety of alternatives to MB for production of
strawberry fruit. The application is based on the technical grounds that
no alternatives are available for moderate to severe pest pressure for
root rot (e.g. Phytophthora) and nutsedge in certain areas, and that
certain topographies and regulatory issues prevent the use of possible
alternatives in several areas.*

*MBTOC considers several alternatives are technically feasible for the
spectrum of target pests. This is recognized in the CUN. It accepts that
use of 1,3-D and its mixtures with chloropicrin are presently restricted
by local air quality regulations and certain topographies. MBTOC
considers that other alternatives (e.g. Pic EC, metham sodium in
combination with PIC) are technically suitable in at least some areas
where regulatory issues, karst topography or slopes affect the use of
1,3-D.*

**MBTOC Question 1 - Further detail is requested on the dosage rates of
MB used in the various regions covered by this CUN, with particular
reference to scope for reduction in MB usage through adoption of
mixtures of MB and chloropicrin containing high proportions of
chloropicrin and use of tarping of low MB permeability. Clarification is
also requested on proportion of the CUN that can use strip fumigation,
with consequent dosage reductions, and the proportion of uptake of strip
fumigation affected by State regulations.**

**U.S. Response -** The 2001 and 2002 average dosage (use) rate
information and 2006 CUE nomination information for the regions covered
by this CUN are presented in Table 3. All of the regions in the U.S. are
using rates below 200 kg/ha of methyl bromide. MBTOC has asked for the
scope for potential reductions using higher proportions of chloropicrin
and tarping with low methyl bromide permeable film. Research on fumigant
combinations with higher concentrations of chloropicrin are being
conducted in several locations throughout the U.S. However, to date
these alternative combinations have not always been as effective as
methyl bromide. Table 4 shows an evaluation of combination fumigant
studies comparing their yield to methyl bromide. In those studies only
44% of the fumigant combinations had yields equal to at least 95% of the
methyl bromide treatment. This suggests that switching to combinations
of fumigants and using higher levels of chloropicrin may not provide
yields similar to methyl bromide, in particular with respect to the
areas nominated by the U.S. because pest pressure is moderate to severe
in these areas. Low permeability tarping has not been widely adopted in
the U.S. for a number of reasons. Tarps are currently used on 93% of the
California and 100% of the Florida soil applications. Regulations
restrict low permeability film in California which accounts for
approximately 76% of the total U.S. strawberry soil use. Under U.S.
conditions VIF has poor application characteristics: it must be unrolled
slower to prevent tearing, photodegradation is a problem when used for
multiple crops, and there are problems with disposal in many localities.
In addition, to date field trials testing strip treatments using
equivalent amounts of methyl bromide have not provided clear evidence
that lower permeability films reduce emissions relative to other films.
MBTOC asked about the proportion of the CUN where strip treatments are
used. Currently strip treatments are used in the Southeast U.S. and
Florida which account for \~ 24% of the U.S. CUN (see Table 3). The use
of strip fumigation is limited in California by air quality standards
because strip treatments can lead to higher rates of methyl bromide
emissions.

Recent research in California has indicated that strip treatments may
increase overall methyl bromide emissions compared to equivalent flat
fumigations. Therefore, while strip treatments might reduce the total
amount of methyl bromide used, it may increase overall air emissions.
The U.S. is reviewing the air emissions information for a number of soil
fumigants and hopes to make those findings available later this year. In
addition to the emission of methyl bromide to the atmosphere, is the
practical issue of the reduction in weed populations on a whole field
scale. The control of perennial weed species in strip fumigation will
allow the weeds to increase in the untreated portions of the field.
While herbicides are available (see Table 7) for this use they posse
additional costs, phytotoxicity concerns, and management challenges for
the growers.

Table 3. Methyl Bromide 2001 and 2002 Two Year Average Use Information
and 2006 Nomination.

+--------------------+-------+-------+-------+--------+-------+-------+
| ###                | *     |       |       | **2006 |       |       |
|                    | *2001 |       |       | Nomina |       |       |
|                    | &     |       |       | tion** |       |       |
|                    | 2002  |       |       |        |       |       |
|                    | Aver  |       |       |        |       |       |
|                    | age** |       |       |        |       |       |
+--------------------+-------+-------+-------+--------+-------+-------+
| ### Applicant      | **K   | **    | **Use | *      | **    | **Use |
|                    | ilogr | Hecta | Rate  | *Kilog | Hecta | Rate  |
|                    | ams** | res** | (kg/  | rams** | res** | (kg/  |
|                    |       |       | ha)** |        |       | ha)** |
+--------------------+-------+-------+-------+--------+-------+-------+
| CA Strawberry      | 1,60  | 8,184 | 196   | 1,4    | 7,422 | 196   |
| Commission         | 1,966 |       |       | 52,732 |       |       |
+--------------------+-------+-------+-------+--------+-------+-------+
| SouthEast          | 27    | 1,851 | 151   | 1      | 1,010 | 151   |
| Strawberry         | 8,957 |       |       | 52,294 |       |       |
| Consortium         |       |       |       |        |       |       |
+--------------------+-------+-------+-------+--------+-------+-------+
| Florida, FFVA --   | 50    | 2,711 | 185   | 3      | 1,682 | 185   |
| Strawberry         | 1,446 |       |       | 10,997 |       |       |
+--------------------+-------+-------+-------+--------+-------+-------+

**Footnote**: Information taken from 2006 Bromide Usage Numerical Index
(BUNI) tables.

**[Table 4. Summary of Research Results for Methyl Bromide Alternatives
on U.S. Strawberry.]{.smallcaps}**

  -----------------------------------------------------------------------
  **Alternatives**              **Total      **Number of Studies with
                                Number of    Yield at Least 95% of Methyl
                                Studies**    Bromide**
  ----------------------------- ------------ ----------------------------
  Basamid (Dazomet) and         27           12
  combinations                               

  Chloropicrin and combinations 58           36

  Metam sodium (Vapam) and      73           24
  combinations                               

  Solarization and Combinations 22           6

  Telone (1,3-dichloropropene)  93           41
  and combinations                           

  **Average Number of Studies                **119/273 = 44%**
  Showing Yield At Least 95% of              
  Methyl Bromide**                           
  -----------------------------------------------------------------------

**MBTOC Question 2 - The part of the CUN relating to Californian
production was based on a 1X township cap for 1,3-D. An estimate is
requested for scope for further reduction in nominated quantity if a 2X
cap is allowed.**

**U.S. Response -** Out of environmental concerns regarding the quality
of the ambient air, California regulates the amount of Telone™ that can
be used in each township within the state. Specifically, Telone™ has
been found by the State of California to be a carcinogen and regulations
have been put in place to limit the cumulative lifetime exposure to
bystanders. There are over four thousand townships (36 square miles or
9,300 ha each) represented in the California township assessment. The
information used to develop the estimate of area impacted by township
caps in California was from papers by Carpenter, Lynch, and Trout, cited
below, supplemented by discussions with Dr. Trout to ensure that any
recent regulatory changes have been properly accounted for.

The current rule in effect for California Telone™ use was used for the
2006 U.S. CUE nomination. This is based on Telone™ usage being allowed
at the baseline amount (1X level), not the short term exemption limits
(2X). The California Department of Pesticide Regulations (Cal DPR) was
contacted for clarification on the Telone™ township cap question. Cal
DPR explained the use of Telone™ starting in 2005 and beyond would be
based on: current and historic use patterns in each individual township,
future enhancements to the air concentration model and health impact
models, and assumptions on the use of adjacent land in the models.
Because of the uncertainties in all of these parameters they are
currently unable to speculate what the future Telone™ township caps will
be in California. Accordingly, we believe that the CUE must cover the
level of MeBr needed to meet the existing 1X regulatory limit.

**MBTOC Question 3 - Application of some alternatives through drip
irrigation systems may be less successful than MB treatment on steeply
sloping ground. As MB injection equipment can be used on slopes at
present, are there any reasons why injection equipment cannot also be
used for alternative fumigants, including 1,3-D mixtures.**

**U.S. Response --** Shank injection of alternatives such as 1,3-D or
1,3-D with chloropicrin are feasible on hilly terrain. However, research
results from California have suggested that this type of application is
less effective than when applied through drip irrigation equipment. The
technical and economic assessment for the eastern U.S. and Florida
indicted a 14% yield loss and \$ 47 and \$ 62 loss per kilogram of
methyl bromide respectively with the best 1,3-D and chloropicrin
application techniques. Because of the lower efficacy, the California
strawberry growers would need to use flat fumigation for effective pest
control which would require 40% more material to be used than in a
typical drip irrigation application to the beds. Growers with weed
control problems would need to factor in the additional cost of a
companion herbicide. In addition, the township cap issue would need to
be evaluated again since more 1,3-D injected uses a different township
cap multiplier than 1,3-D applied through drip irrigation equipment.

**Question 4 - The Party is requested to supply data on MB usage in this
sector for 2003 for the areas for which a CUE is sought and to provide
information on changes to that consumption as reflected in the
nomination for 2006.**

**U.S. Response** -- Available methyl bromide usage information is
presented in Table 3 above. Unfortunately 2003 data is not yet
available. The total hectares of strawberries for fruit in the U.S. were
19,486 in 2002. Estimates of future plantings suggest that the total
will increase to 21,900 hectares or 3% per year (the historical average
increase from 1997 to 2002. Therefore, while the U.S. strawberry area is
estimated to increase by a total of 13% between 2002 and 2006 the CUE
requested is 20% lower than the amount used in 2001 and 2002. Between
1997 and 2000 the U.S. had already reduced the use of methyl bromide in
strawberries grown for fruit production by 24%.

**MBTOC Question 5 - For the part of the CUN relating to Florida and SE
USA the Party is requested to describe the technical basis for the
estimate that moderate/severe nutsedge affects 40% and 30% CUN area in
Florida and SE respectively.**

**US Response -** A critical use of MB in this region is to control
yellow and purple nutsedge. While it is generally accepted by scientific
experts that the incidence of these weeds in the southern USA is very
high, exact figures have been difficult to obtain. The U.S. estimate of
moderate to severe nutsedge distribution is estimated to be between 30
to 40% of the area for both Florida and the eastern U.S.

Earlier this year, Dr. Stanley Culpepper of the University of Georgia
submitted to EPA the results of a survey intended to characterize the
incidence of nutsedge in vegetable operations. In this survey, extension
agents in 34 Georgia vegetable producing counties were polled to better
understand the level of nutsedge infestation in eggplants and peppers,
among other vegetable crops. Their responses are based on their
extensive interactions with vegetable growers in their jurisdictions.
The portion of the survey data related to eggplants and peppers, used as
a surrogate for strawberries, is summarized below (see Table 5 & 6).

**[Table 5. Percent Current Nutsedge Infestation in Georgia Counties
While Methyl Bromide is Available (Culpepper, 2003).]{.smallcaps}**\*

  -------------- --------------- --------------- --------------- ---------------
  **Crop**       **No            **Light         **Moderate      **Severe
                 Infestation**   Infestation**   Infestation**   Infestation**

  **Pepper**     1.3             18.9            65.6            14.2

  **Eggplant**   1.0             40.6            39.0            19.4
  -------------- --------------- --------------- --------------- ---------------

\*Footnote: No infestation = no nutsedge infesting production area.
Light infestation = \< 5 nutsedge plants per square yard. Moderate
infestation = 5 to 30 nutsedge plants per square yard. Severe
infestations = \>30 nutsedge plants per square yard.

In the BUNI "High Key Pest Distribution" was calculated by added the
moderate plus severe infestation. Low Key Pest Distribution was
calculated by adding the severe infestation plus one half the moderate
infestation.

Table 6. Percent Anticipated Nutsedge Infestation The Year After the
Inability to Use Methyl Bromide (Culpepper, 2003). \*

  -------------- --------------- --------------- --------------- ---------------
  **Crop**       **No            **Light         **Moderate      **Severe
                 Infestation**   Infestation**   Infestation**   Infestation**

  **Pepper**     0.0             9.1             31.6            59.3

  **Eggplant**   0.2             11.9            50.3            37.6
  -------------- --------------- --------------- --------------- ---------------

\*Footnote: No infestation = no nutsedge infesting production area.
Light infestation = \< 5 nutsedge plants per square yard. Moderate
infestation = 5 to 30 nutsedge plants per square yard. Severe
infestations = \>30 nutsedge plants per square yard.

In the BUNI "High Key Pest Distribution" was calculated by added the
moderate plus severe infestation. Low Key Pest Distribution was
calculated by adding the severe infestation plus one half the moderate
infestation.

While this survey focused on Georgia, the US believes it is reasonable
to expect that the levels of nutsedge infestations reported for these
crops is likely to be representative of other areas of the southern USA.

**MBTOC Question 6 - In Florida, according to the CUN, karst topography
prevents use of 1,3-D on 40% of the MB-using area. The Party is
requested to describe the technical basis of this estimate or provide
survey data to substantiate this area is impacted and to clarify the
actual proportion of current strawberry crop CUN that cannot use 1,3-D
due to restrictions relating to karst topography. Further detail is
sought why other effective alternatives (e.g. Pic formulations, metham
sodium in combination with Pic), assisted by specific herbicides if
necessary, cannot be used to manage pests in these areas. Are there
barriers to adoption of the combinations, with and without herbicides?**

**US Response --** The estimates of the area impacted by karst geology
in Florida, restricting the use of 1,3-D, were developed and mapped by
the Florida Department of Agriculture (1984). The estimates of karst
geology for Georgia and the southeast U.S. were developed from applicant
and university survey information. In addition see the Reregistration
Eligibility Decision (RED) for 1,3-D (U.S. EPA, 1998). A map of the
karst geology in the U.S. is available online at
<http://www2.nature.nps.gov/nckri/map/maps/engineering_aspects/davies_map_PDF.pdf>
. The proportion of the current Florida strawberry crop that cannot use
1,3-D because of karst geology is 40% (see BUNI, 2006).

The comparative performance of additional alternatives such as 1,3-D
plus chloropicrin, metam sodium with chloropicrin are presented below in
Table 7. Based on these studies under moderate to severe pest pressure
the alternatives would lead to an overall yield loss of 25%.
Chloropicrin alone was not specifically evaluated because it does not
provide adequate control of nematodes or weeds. Table 8 below lists the
herbicides currently registered in the U.S. for strawberries. Of the
registered herbicides only s-metolachlor will provide suppression of
yellow nutsedge, but will provide no control of purple nutsedge at
current label rates. One of the key barriers to adoption of a fumigant
and herbicide combination is the lack of selective herbicides for
strawberry weed control.

**[Table 7 Alternatives Yield Loss Data Summary]{.smallcaps}**

+------------------+---------------+----------------+-----------------+
| ##### [Alternat  | ##### [List   | ##### [Rang    | **[Best         |
| ive]{.smallcaps} |  Type of Pest | e of Yield Los | Estimate of     |
|                  | ]{.smallcaps} | s]{.smallcaps} | Yield           |
|                  |               |                | Loss            |
|                  |               |                | ]{.smallcaps}** |
+------------------+---------------+----------------+-----------------+
| 1,3-             | Weeds,        | 1% gain to 14% | 14.4% (Shaw and |
| Dichloropropene/ | nematodes and | loss           | Larson, 1999)   |
|                  | diseases      |                |                 |
| Chloropicrin     |               |                |                 |
+------------------+---------------+----------------+-----------------+
| Ch               | Multiple      | 6.6-47%        | 27% Locascio,   |
| loropicrin/Metam | pests         |                | 1999            |
| sodium           |               |                |                 |
+------------------+---------------+----------------+-----------------+
| Metam sodium     | Weeds,        | 16%-29.8%      | 29.8% (Shaw and |
|                  | nematodes and |                | Larson,1999)    |
|                  | diseases      |                |                 |
+------------------+---------------+----------------+-----------------+
| ##### [          |               |                | **25%**         |
| Overall Loss Est |               |                |                 |
| imate for All Al |               |                |                 |
| ternatives to Pe |               |                |                 |
| sts]{.smallcaps} |               |                |                 |
+------------------+---------------+----------------+-----------------+

Table 8: Herbicides Labeled and IR-4 designated in the US to Control
Nutsedge in Strawberries

  ----------------------------- ------------------------------ ----------------------------------------------
  **[Herbicide]{.smallcaps}**   **[Registered]{.smallcaps}**   **[Major Comments]{.smallcaps}**

  Glyphosate                    [Yes]{.smallcaps}              Non-selective, will not control nutsedge in
                                                               the plant rows, no residual control

  S-metolachlor                 [Yes]{.smallcaps}              24(c) Florida. & California, suppression of
                                                               yellow nutsedge at label rates, does not
                                                               control purple nutsedge, high water
                                                               solubility, low Koc

  Paraquat                      [Yes]{.smallcaps}              Non-selective, will not control nutsedge in
                                                               the plant rows, no residual control

  Terbacil                      [Yes]{.smallcaps}              Only suppresses nutsedge, crop rotation
                                                               restrictions, Organic Matter restrictions, not
                                                               for use in Calf., used in Canada

  Acifluorfen                   [No\*]{.smallcaps}             Potential injury in strawberry, yellow
                                                               nutsedge control only

  Halosulfuron-methyl           [No]{.smallcaps}               Potential crop injury, crop rotation
                                                               restrictions, variable cultivar tolerances

  Rimsulfuron                   [No]{.smallcaps}               Only suppresses nutsedge, crop rotation
                                                               restrictions

  Thiazopyr                     [No\*]{.smallcaps}             "Nutsedge" suppression, can be used in low
                                                               Organic Matter soils
  ----------------------------- ------------------------------ ----------------------------------------------

**Footnote:** \*IR-4 listed chemical

**MBTOC Question 7 - In SE USA, in the area growing strawberries
according to the CUN, buffer zones restrict use of 1,3-D on 90% of CUN
area. The Party is requested to describe the technical basis of this
estimate or provide survey data to substantiate this area is impacted
and to clarify the actual proportion of current strawberry crop CUN that
cannot use 1,3-D due to these restrictions. Further detail is sought why
other effective alternatives (e.g. Pic formulations, metham sodium/Pic,
dazomet/Pic), assisted by specific herbicides if necessary cannot be
used to manage pests in these areas.**

**US Response --** The U.S. estimates of the area impacted by 100 foot
(30.5 m) buffer zones are 40% for the eastern U.S. and 1% for Florida.
The 2006 CUN request used an estimate of 90% regulatory impacts in the
eastern U.S. because the regulations required a 300 foot (91.4 m) buffer
which has since been reduced to 100 feet on the alternative
1,3-dichloropropene. The current estimates used information from
applicants and alternatives manufacturers including: average field size,
the density of habitable structures near strawberry fields, population
distributions, and surveys of extension agents. That information was
used to make a professional judgment on the impact of buffers. For
example, the eastern U.S. has many small pick-your-own strawberry farms
(less than 4 hectares) where the impact of a 100 foot buffer is more
pronounced than on the larger farms in California or Florida. Because of
the significant impact that these estimates have on the overall request
for methyl bromide, the U.S. EPA is evaluating additional methods to
further substantiate and quantify the impacts of buffer zones.

One of the key barriers to adoption of a fumigant and herbicide
combination (using fumigants such as chloropicrin, metam sodium with
chloropicrin) is the lack of selective herbicides for strawberry weed
control. Table 8 above lists the herbicides currently registered in the
U.S. for strawberries. Of the registered herbicides only s-metolachlor
will provide suppression of yellow nutsedge, but will provide no control
of purple nutsedge at current label rates. An additional constraint is
that under moderate to severe pest pressure there is an average of 25%
yield loss with the alternatives (Table 7).

**[[References]{.underline}]{.smallcaps}**

2006 Bromide Usage Numerical Index (BUNI) -- Refined Nomination Package.
Attached to U.S. Response to Questions as an Excel Spreadsheet.

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

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

Culpepper, S. 2004. Infestations of Nutsedge in Georgia Vegetable Crops.
Supporting survey information. University of Georgia supporting survey
information. Email of January 23, 2004.

Florida Department of Agriculture. May 1984. Summary of soil
hydrogeological and other environmental conditions in the state of
Florida related to the use of pesticides.

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