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**Your reference:**

**Our reference:** OzL./MBTOC-CUN/USA/MS/gao **Date:** 18 March 2005

Dear Sir,

**[Re: Review of Critical-Use Nominations for Methyl Bromide -
USA]{.underline}**

Please refer to the on-going review process of nominations for
critical-use exemptions for methyl bromide.

I am forwarding for your attention the second set of questions from
Methyl Bromide Technical Options Committee on nominations related to
soil applications.

I would appreciate it if your response and any questions you may have
are directly sent to the Co-chairs of the Committee at the addresses
provided below with a copy to the Secretariat.

Dr. H.J. Banks Dr. Nahum M. Mendoza

10 Beltana Road and Department of Agricultural Parasites

Pialligo, ACT 2609 Autonomic University of Chapingo

Australia P.O. Box 56230

Chapingo, Mexico

Tel: (+61-2) 6248-9228 Tel: (+52-595) 954-1646 / 1602

Fax: (+61-2) 6248-9228 Fax; (+52-595) 954-1646 / 1602 / 40692

E-Mail: <apples3@bigpond.com> E-Mail: nahumm@correo.chapingo.mx

Yours sincerely,

![](media/image2.png)

# Marco González

Executive Secretary

Ozone Secretariat

Dr. John E. Thompson, Ph.D.

International Affairs Officer

Office of Environmental Policy

U.S. Department of State

2201 C Street N.W. Room 4325

Washington DC 20520, U.S.A.

Fax: (+1-202) 647-5947

\- 2 -

Copy to: Dr. H. J. Banks

> Fax: (+61-2) 6248-9228

Dr. Nahum M. Mendoza

Fax: (+52) 5954-0692

Ms. Michelle Marcotte

Tel: (+1-301) 262-9866

Dr. Ian Porter

> Fax: (+61-3) 9800 3521

**United States:**

**US Cucurbits:**

1.  In this nomination there are differences (in some cases important
    ones) between the crop areas stated in the CUNs and those used as a
    basis for the requested amounts- and the official USDA statistics
    for these crops. For example Michigan does not appear to be an
    eggplant producer according to USDA´s statistics; or the \"*other
    south-eastern states*\", with the only exception of North Carolina.
    Could the Party please confirm which figures in the nomination are
    correct and the official source of this information.

2.  Could the Party please confirm what data it has used to validate the
    areas cropped with cucurbits that are affected by Karst geology
    areas.

#### US Peppers

1.  Please provide official statistics of pepper production in the
    States of Alabama, Arkansas, Kentucky, Louisiana, South Carolina,
    Tennessee, and Virginia and MB use in those States.

2.  Total area to be treated with the MB in Florida (Tables 8.1&12.1) is
    8,417 ha, while total area in the State is 7,893 ha (table 7.1).
    Please explain?

3.  Please provide accurate information, [on a county
    basis]{.underline}, about yellow and purple nutsedge high and
    moderate infestations and its coincidence within pepper crop areas
    for the Southeast States, Georgia and Florida.

4.  Please provide accurate information, [on a county
    basis]{.underline}, about occurrence of the karst geology phenomena
    and its coincidence with pepper crop areas for the States of Georgia
    and Florida.

5.  California: area treated in 2002 was 121 ha (table 12.1), while MB
    is requested for 759 ha. Please explain?

6.  For the control of *Phytophthora* in Michigan, 1,3 D + chloropicrin
    is a key alternative with efficacy comparable to MB. According to
    the CUN, the main problem for its adoption is a potential delay in
    planting as long as 28 days low soil temperatures. Fumigation
    operations need to be completed by the first week of May to capture
    an early market window. In Michigan, Soil temperatures in April vary
    between 10-15 °C. 1,3 D+Pic can be applied when soil temperature is
    higher than 5°C as it is the case in Michigan in April. Therefore,
    can we consider soil temperature as a limiting factor for the soil
    fumigation with 1,3D+Pic ?.

7.  In Michigan, it was stated that the range of yield loss varies
    between 0% and 6% yield in plots fumigated with 1,3 D+ Pic compared
    to MB (2003). In a trial undertaken in 2004, yields from pepper
    plots treated with various alternatives (metham potassium, alone or
    in combination with chloropicrin, 1,3-D + chloropicrin ) are
    comparable to yields from plots treated with MB + chloropicrin and
    yields from control plots. These results indicate a very low pest
    pressure in all treated and control plots. Therefore, if the
    experiments have been conducted in plots with a very low pathogens
    pressure, has the *Phytophthora* distribution in Michigan been
    established? If yes, what is the % of the areas with poor, moderate
    and high pathogen pressure? Same question for the other pests in the
    US pepper production states.

8.  Important reductions may be obtained by calculating the area with
    Karst geology where MB can be replaced by Metham Sodium and Pic.
    What percentage of US pepper production occurs in Karst geology ?

9.  Why strip fumigation is not adopted in all the US production areas?

10. Since 2000, in Michigan, about 5% of the acreage has been treated
    with the 50:50 formulation of methyl bromide and chloropicrin. What
    are the constraints to increase the use of this formulation? Is it
    possible to introduce or to increase the use of the formulation in
    the other states

11. In Southern US and other states, Pepper is generally double-cropped
    with a cucurbit crop (muskmelon, cucumber, or squash). MB is applied
    every year. The requested quantity can decrease if MB is applied
    every two years, as for Michigan. Are there any constraints to adopt
    this frequency? The party presented also a CUN for cucurbits.

12. The MB formulation adopted is 67:33. Could the formulation 50:50 be
    adopted?

13. One application of methyl bromide can last more than a year in
    California and therefore, the frequency of application is once every
    two years. Why MB in not applied every two years in other states?

14. Locascio et al. (1997) conducted studies on MB alternatives on
    tomatoes grown in small plots at two Florida locations with high
    nutsedge infestation. Is there any similar reference for peppers?
    The yield decrease is probably caused by Fusarium and not by
    nutsedge.

15. In California, has the area fumigated in 2003 increased or
    decreased?

16. When the uture plans to minimize MB use are expected to be adopted
    (VIF, drip irrigation, trials with new alternatives on pepper, MB
    formulation.)

17. The Party is requested to explain why no large-plot studies have yet
    been performed to show commercial feasibility of available
    alternatives in US peppers

18. Will the farm demonstration plots will be implemented in 2005? If
    yes, please give more details: number, distribution, alternatives
    etc..

19. The alternative implementation is scheduled for 2010. What will be
    the strategies to reduce the use and emission of MB during the
    coming years? (crop rotation, raised crop beds, black plastic, and
    foliar fungicides. Use of virtually impermeable film (VIF) etc..

20. What is the importance use of HDPE (high density polyethylene) to
    minimize use and emissions of MB.

21. What are the cultural practices used by the farmers to minimize use
    and emissions of MB.

#### US Eggplant

1.  Experimental results has shown that for the control of
    *Phytophthora* on eggplant in Michigan, 1,3 D + chloropicrin is a
    key alternative with efficacy comparable to MB. According to the
    CUN, the main problem for its adoption is a potential delay in
    planting as long as 28 days low soil temperatures. Fumigation
    operations need to be completed by the first week of May to capture
    an early market window. In Michigan, Soil temperatures in April vary
    between 10-15 °C. 1,3 D+Pic can be applied when soil temperature is
    higher than 5°C as it is the case in Michigan in April. Therefore,
    can we consider soil temperature as a limiting factor for the soil
    fumigation with 1,3D+Pic ?.

2.  Important reductions may be obtained by calculating the area with
    Karst geology where MB can be replaced by Metham Sodium and Pic.
    What percentage of US eggplant production occurs in Karst geology ?

3.  In Michigan, the formulation 50:50 has been introduced. What are the
    constraints to increase the use of this formulation in Michigan and
    also in Florida and Georgia?

4.  In some states, e.g. Georgia, eggplant is generally double-cropped
    with a cucurbit crop (muskmelon, cucumber, or squash). MB is applied
    every year. The requested quantity can decrease if MB is applied
    every two years, as it is the case in Michigan. Are there any
    constraints to adopt this frequency in Florida and Georgia?

5.  The MB formulation adopted in Florida and in Georgia is 67:33. Could
    the formulation 50:50 be adopted in these two eggplant producing
    regions?

6.  The party is requested to explain why no large-plot studies have yet
    been performed to show commercial feasibility of available
    alternatives in US eggplants

7.  Will the farm demonstration plots will be implemented in 2005? If
    yes, please give more details: number, distribution, alternatives
    etc.

8.  What are the strategies to be adopted in the near future to reduce
    the use and emission of MB? etc..

9.  What is the importance use of HDPE (high density polyethylene) to
    minimize use and emissions of MB in eggplant production.

10. No reference about grafting on Solanum torvum rootstock is provided.
    This alternative is widely used and expanding very quickly in the
    Mediterranean and the Netherlands, as an MB alternative and to
    increase production. Solanum torvum is fully resistant to fusarium
    and nematodes, with no problems due to high temperatures. It is used
    in Central America under very hot conditions. Please clarify the
    situation in the US?

#### Double-cropping

1.  For Florida, Table 11.1 indicates that most, possibly all, of the
    CUN crop is double-cropped (page 13). Please clarify what percentage
    of the eggplant CUN area practices double-cropping in Florida. What
    are the most common rotational crops in Florida? Table 11.1
    indicates peppers, cucurbits; whereas page 7 mentions several other
    crops as well.

**Citations list (section 26)**

2.  The citations list does not include new research, new communications
    or other developments since 2003. With only one exception, the
    citations (including personal communications) in the citations list
    are dated December 2003 or earlier. Have there been any trials,
    activities or developments related to eggplant and issues relevant
    to Decision IX/6 since 2003? If so, please provide information.

**Combination treatments with herbicides**

3.  In Questions sent to the Party on eggplant in June 2003, MBTOC
    stated that "MBTOC is concerned that much of the research conducted
    on uses of alternatives is conducted on peppers or tomato and
    extrapolated to eggplant production, particularly on the impact of
    nutsedge infestation." Since this is the 3^rd^ year of a CUN request
    for eggplant in the USA, it is expected that very substantial
    progress will have been made in research in eggplant by now. Please
    clarify?

4.  The section on Florida (pages 13-20) does not give sufficient
    consideration to combinations of several fumigants + herbicides/weed
    control methods. The only fumigant combinations considered in the
    section on Florida are (a) 1,3-D+ pic (page 13, 17), and (b) 1,3-D +
    pic + Devrinol + trifluralin (page 15). Although Table C.1 mentions
    metham with or without pic (page 17) the citation Locascio et al
    1997 in fact covers metham alone, therefore Table C.1 relates to
    metham alone. Please provide information about any other combination
    treatments, such as several fumigants + herbicides/weed control
    methods that have been trialled for eggplant in Florida?

5.  The CUN for Georgia provides information on several combinations of
    fumigants (page 25) but does not provide data/information on
    combinations of fumigants + herbicides/weed control methods. If such
    combinations have been tested in eggplant, please provide copies of
    studies or citations?

**Yield loss analysis**

6.  The tables of yield loss analysis for Florida (Table C.1 page 17)
    and Georgia (Table C.1 page 27) do not appear to be relevant or
    sufficient. The yield loss table considers only 1,3-D + pic, and
    metham (alone). (Table C.1 is based only on Locascio et al 1997
    (pages 17, 25; Table 16.1 on pages 18, 28) which carried out
    small-scale trials in another crop (tomato) for 1,3-D+pic, and
    metham. Although Table C.1 appears to cover metham sodium with or
    without chloropicrin, the CUN text about the study by Locascio et
    al (1997) indicates that metham alone was tested.) It is very
    surprising that by 2005 the CUN does not provide any yield results
    for eggplant, nor for combinations of fumigants + herbicides/weed
    control methods, in Florida and Georgia.

7.  The sections on yield in Florida and Georgia in the current CUN
    still rely strongly on other crops. Please provide more information
    about yield (preferably copies of studies or research reports) of MB
    alternatives in eggplant in Florida and Georgia, particularly
    focussing on the following: combinations of fumigants + weed
    control, using improved application methods which became available
    in recent years.

8.  The table of yield loss analysis for Michigan (Table C.1, page 36)
    appears to be based entirely on Hausbeck and Cortwright \[sic\]
    (2003), a study which is not in the citations list. Table C.1 (on
    page 36) does not appear to take account of a more recent study by
    Cortright and Hausbeck (2004), which indicates that 1,3-D + pic
    provided a higher yield of eggplant than MB (Table 16.2 on page 37).
    Table C.1 also suggests that the range of yield loss from use of
    1,3-D + pic was as high as 95% (page 36). However, experience in use
    of 1,3-D + pic, in commercial practice and in trials, does not
    support this degree of loss when appropriate application methods are
    used, and nutsedge weeds are not key target pests. Please clarify?
    (The key target pests in Michigan are listed as *Phytophthora
    capsici* and *Verticillium* spp. only (page 31))

**Progress in registrations**

9.  What progress has been made in registering products for
    eggplant: (a) iodomethane, (b) herbicides for nutsedge, (c)
    furfural, (d) others?

**Copies of studies**

10. Please provide a copy of the following studies:

\(a\) Study by Culpepper and Langston performed in 2004 in Georgia (CUN
pages 19 and 30). There is no citation for this study in the list of
citations in the CUN (section 26).

\(b\) Study by Culpepper (2004) cited on page 29. There is no citation
for this study in the list of citations in the CUN (section 26).

\(c\) Study by Hausbeck and Cortwright (2003) cited in Table C.1, which
forms the justification for the yield loss data summary. There is no
citation for this study in the list of CUN citations in the CUN (section
26).

\(d\) Study by Cortright \[or Cortrright\] and Hausbeck (2004,
Evaluation of fumigants for managing Phytophthora crown and fruit rot of
solanaceous and cucurbit crops) which is summarised on page 37. Since
this appears to be an unpublished study, it would be useful for MBTOC to
see the technical details.

**Area affected by moderate to severe nutsedge pressure**

11. Please provide survey evidence, or similar supporting evidence, on
    the prevalence of moderate to high nutsedge pressure in eggplant
    production regions (or eggplant CUN areas) in Florida, by county.

12. The section on Georgia says the area affected by moderate to high
    nutsedge pressure is considered to be approximately 58% and cites
    Culpepper (2004) (page 29). MBTOC has requested a copy of this study
    in the question above. If Culpepper (2004) does not provide data or
    survey results, or similar supporting evidence, to substantiate the
    estimated CUN areas subject to moderate to severe nutsedge pressure
    in Georgia, then please provide additional data.

**Telone label relating to Karst geology or topography**

13. In March 2004 DAS sent the following information to MBTOC (Executive
    Summary of Key Issues Pertinent to Use of Telone Products as
    Alternatives to Methyl Bromide in the US, DAS, March 2004.)

-   "A 'karst geology' statement appears on all Telone labels. This
    statement is intended to restrict the use of Telone products in
    areas where applications or seepage from applications may infiltrate
    groundwater.

-   Use of Telone C-35 (and all other Telone products) is permitted in
    areas where there is an impeding layer (such as a spodic or argillic
    layer) that supports seepage irrigation and prevents ground water
    infiltration. Refer to label wording.

-   The term 'karst geology' does not have a clear definition nor can an
    area of 'karst geology' be recognized from the growers' perspective
    or from an enforcement perspective.

-   Dow AgroSciences (DAS) and the Florida Department of Agriculture and
    Consumer Services (FL DACS) have agreed to change this confusing
    wording from 'karst geology' to 'karst topography' which is
    definable and recognizable from both a growers perspective and
    enforcement perspective (see Appendix 2).

"DAS has worked with the Florida Department of Agriculture and Consumer
Services (DACS) to clarify this confusion. The proposal is to change the
terminology to 'karst topography.' This is a definable term and 'karst
topography' can be recognized by such surface features as sink holes or
disappearing streams which are characteristic of karst areas. Florida
DACS agrees with this refinement and has written a letter to the EPA in
support of the proposal to amend and clarify the label in this way. A
copy of DACS letter to EPA and the proposed wording for the label
amendment are provided...."

That was the status as reported by DAS in March 2004. The Party is
requested to clarify if Florida DACS and the EPA have amended the labels
for Telone products so that its use is restricted to areas of 'karst
topography' as described above.

14. The table below indicates soils in 7 counties of Florida, based on
    SSURGO and row cropland use from the Florida Geographic Data
    Library. Source: ABG. 2002. Analysis of Methyl Bromide Replacement
    with Telone in Strawberries in California and Florida and Tomatoes
    in Florida. Report commissioned by DAS. Does the Party agree with
    the analysis in the table below? If not, please send corrections or
    alternative data.

15. What proportion of the eggplant CUN area in (a) Florida and (b)
    Georgia has an underlying impeding layer (eg. spodic, argillic
    layers)?

Analysis of Florida soils in 7 counties, based on SSURGO and row
cropland use from the Florida Geographic Data Library. ABG, 2002.

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**Market windows**

13. The CUN section on Michigan states that fumigation practices must be
    completed by first week of May to allow growers to "capture the
    early market (July -- September)" (page 32). Does "first week" mean
    that planting needs to take place during the first week, or during
    the 2^nd^ week of May? Does the entire period of July-September
    comprise the "early" market? Please provide price data for
    [eggplant]{.underline} during the weeks of harvest in Michigan.
    Since market window is a major basis for the eggplant CUN it is not
    appropriate to use price data for peppers as stated in the CUN (page
    45).

14. Eggplant growth is curtailed at temperatures below 16°C (page 7),
    and cold temperatures injure this crop. In Michigan the outside
    temperature is reported to be 12°C on average in May, the month when
    eggplant is planted (page 32). When using MB at present, what is the
    date of first harvest, and yield at first harvest, if eggplant is
    planted in (a) the 1^st^ week of May, (b) the 2^nd^ week of May,
    and (c) 3^rd^ week of May?

**Clarification of BUNI data**

15. The BUNI (page 51) lists metham + pic as the marginal strategy used
    for Florida and Georgia in the yield loss analysis. However,
    according to the CUN text sections on Florida and Georgia, metham
    (alone) was used in the analysis (as described above in Q5).

The BUNI mentions frequency of MB treatment as 1/year for Michigan (page
51), however the CUN states "1 time every 2 years" (page 31).

Please clarify.

#### Fruit, Nut and Flower Nurseries

Please respond to these questions for the fruit, nut, and flower nursery
production remaining in the nomination after subtractions were made for
QPS and growth adjustments. Please answer for each of the 3 categories
"Raspberries", "Fruit and Nut Trees", and "Roses".

[Certification Questions]{.underline}

1\. Is 100% of this nomination for certified propagative material?

2\. Is participation in the certification program mandatory or
voluntary? Please provide copy of certification requirements

3\. Are the requirements of the certification program specified in
local, regional, or national regulations?

3.  Is the certification required to export the propagative material
    within regional, State or international countries (Please specify)?

5\. What are the certification standards? For example, must be free of
specific pests or pathogens, must be free of all pests and pathogens,
tolerance levels, plant must be of a certain size, etc.

6\. Is the use of methyl bromide mandated for certification? Is a
minimum rate of methyl bromide specified?

7\. Are there soil disinfestation measures other than MB that are
approved for certification either for specific crops/growing conditions
or broadly for many crops/growing conditions? Why can't these be used in
the circumstances of the nomination?

8\. Please provide data demonstrating that MB results in
pest/pathogen-free propagative material. Some data are presented in
Section 16 for nematodes on roses and trees, but no pest data is
presented for raspberries.

9\. Please provide data showing that MB alternatives either can or
cannot meet pathogen/pest-free level required for certification by
providing data comparing pest/pathogen populations on propagative
materials grown in 1) soil treated with methyl bromide, 2) untreated
soil, 3) 1,3-D and chloropicrin alone and in combination,
[and]{.underline} 4) other relevant alternatives. While plant growth
data are useful, they do not substitute for pest/pathogen data if the
certification requirement is for pest/pathogen-free propagative
material. Some data are presented in Section 16 for nematodes on roses
and trees, but no pest data is presented for raspberries.

10\. What are the consequences of not meeting the pest/pathogen-free
standards? For example, propagative material cannot be sold, material
can be sold as lower quality/lower price, propagative materials must be
treated before selling to kill pest/pathogen (e.g. hot water dips,
etc.), etc.

11\. If certification isn't mandated by law or regulation, is it used as
a quality standard demanded or expected in order to market the crop? Why
can't MB alternatives be used to meet the quality standard?

12\. What are the consequences of not meeting the quality standard? For
example, inability to sell crop, lower price for crop, etc.

 

[General Questions]{.underline}

13\. 90% of raspberry, 99% of rose, and 100% of Fruit & Nut tree's
original requests were removed from the nomination as meeting the
criteria of QPS. What is the difference between QPS and non-QPS
raspberry, fruit and nut tree, and rose nursery production?

14\. Party states the proportion of the crop grown with MB is not
available. However this information is very important. Can the Party
make an "educated guess" at the crop proportion grown with (or without)
methyl bromide?

15\. Iodomethane might be registered soon by the EPA. Party is requested
to provide information on the possibility of reducing methyl bromide use
in 2007 if iodomethane is registered.

[Raspberry Questions]{.underline}

16\. In section 11ii, Party states "Soil moisture is an important
determinant of capacity of 1,3-D efficacy (5)." (5) appears to be a
reference for this statement, but no corresponding list of numbered
references is provided. Please provide this reference.

17\. Section 13 states that 1,3-D could possibly be considered a cost
effective alternative where soil conditions and township caps allow.
BUNI does not indicate any adjustments for Regulatory Issues or Soil
conditions (unsuitable terrain?) for raspberries. Does this mean that
there are no regulatory or soil conditions restricting use of 1,3-D for
the raspberry production areas in this CUN? If there are no restrictions
on 1,3-D and it is effective, why is methyl bromide needed? If there are
regulatory or soil conditions restricting use of 1,3-D, please state %
of nomination impacted by these restrictions.

18\. Party states "container-grown plants produce shorter or curved
roots. . . .any reduction in surface area would reduce the number and/or
quality of new canes." Please supply a reference for this information.

[Fruit and Nut Tree Questions]{.underline}

19\. Is "incompatible soil moisture" include in the "Unsuitable Soil
Terrain" column of the BUNI?

20\. Text states that 65% of the area cannot be treated with 1,3-D
because of incompatible soil moisture or soil type, or township caps,
but BUNI does not show any adjustments for Regulatory Issues or
Unsuitable Terrain. Please provide information on the % of the
nomination for Trees that is impacted by township caps and soil
moisture/soil type restrictions.

21\. Could a 67:33 formulation of methyl bromide:chloropicrin be used to
reduce the amount of methyl bromide use in fruit and nut tree nursery
production? If not, why?

[Rose questions]{.underline}

22\. Table 13 indicates that 1,3-D could be an alternative if no
restrictions apply. It further states that "US nomination is for areas
where 1,3-D is not effective". Does the Party mean "not available"? If
1,3-D is considered not effective, state the conditions under which it
is not effective and the % of the nomination impacted by these
conditions. No adjustments for Unsuitable Soils is given in BUNI. If
soil moisture or soil type is restricting uptake of alternatives, please
state the percentage of the nomination impacted by these restrictions.

23\. Could a 67:33 formulation of methyl bromide:chloropicrin be used to
reduce the amount of methyl bromide use in rose nursery production? If
not, why?

24\. Although Party states that 1,3-D is a technically feasible
alternative wherever restrictions do not limit its use, no economic
analysis is included with the nomination. Such an analysis is essential
for MBTOC to carry out an economic feasibility analysis. Is it the
position of the Party, that if 1,3-D is technically feasible for this
CUN, it is also economically feasible?

25\. Party is requested to clarify what measures will be taken to reduce
and phase-out MB use in the coming years.

 

#### US Forest Seedlings 

Please respond to these questions for the forest seedling production
remaining in the nomination after subtractions were made for QPS,
double-counting, growth, and rate adjustments.

[Certification Questions]{.underline}

1\. What % of this nomination is for certified forest seedlings? If 0%,
please go to question #13 below.

2\. Is participation in the certification program mandatory or
voluntary?

3\. Are the requirements of the certification program specified in
local, regional, or national regulations?

4\. Is the certification required to export the forest seedlings?

5\. What are the certification standards? For example, must be free of
specific pests or pathogens, must be free of all pests and pathogens,
plant must be of a certain size, etc.

6\. Is the use of methyl bromide or other alternatives mandated for
certification? Is a minimum rate of methyl bromide or other alternatives
specified?

7\. Are there soil disinfestation measures other than MB that are
approved for certification either for specific crops/growing conditions
or broadly for many crops/growing conditions? Why can't these be used in
the circumstances of the nomination?

8\. Please provide data demonstrating that MB results in
pest/pathogen-free propagative material.

9\. Please provide data showing that MB alternatives either can or
cannot meet pathogen/pest-free level required for certification.

10\. What are the consequences of not meeting the pest/pathogen-free
standards? For example, propagative material cannot be sold, material
can be sold as lower quality/lower price, propagative materials must be
treated before selling to kill pest/pathogen (e.g. hot water dips,
etc.), etc.

11\. If certification isn't mandated by law or regulation, is it used as
a quality standard demanded or expected in order to market the crop? Why
can't MB alternatives be used to meet the quality standard?

12\. What are the consequences of not meeting the quality standard? For
example, inability to sell crop, lower price for crop, etc.

 

[General Questions]{.underline}

13\. Table 16 reports data for numerous weed control trials. Only 2
trials report data on disease control, both of which show alternatives
providing good control. Are there other data that show less disease
control with alternatives, or is the basis for this CUN primarily the
need for weed control?

14\. Are there published references to the data reported in Table 16?

15 . Does Table 16 report results across all regions in the CUN? If not,
what regions are the data from?

16\. Methyl bromide use rates reported in Section 9 of the CUN vary from
21.0 to 39-7 g/m^2^. The lower rates are being used by regions who are
using a higher % of chloropicrin in the formulation. Why can't the
higher chloropicrin % and lower methyl bromide rates be used in all
regions?

17\. 0-50% of each applicant's original request was removed from the
nomination as meeting the criteria of QPS. What is the difference
between QPS and non-QPS forest seedling production?

18\. Is halosulfuron or trifloxysulfuron registered for weed control in
forest seedling production? If not, is future registration planned? If
not, why?

19\. Several regions fumigate only once every 2, 3, or 4 years, rather
than annually and point out that use of an alternative might require
annual fumigation which could impact cost and increase the amount of
pesticides in the environment. Please present economic data showing the
projected impact of more frequent fumigations with alternatives. Besides
economic and environmental burdens, are there any other reasons that
annual fumigation with a methyl bromide alternative would not be
feasible?

20\. In section 13, inconsistent results in weed control with dazomet
and metham sodium are cited. Is the inconsistent weed control a problem
in the 1^st^, 2^nd^, 3^rd^, and/or 4^th^ crop following fumigation?

21\. The Weyerhauser-West region mentioned control of *Phytophthora
ramorum* as one reason methyl bromide is needed. Isn't this pathogen a
quarantine pathogen?

22\. The amounts of methyl bromide stated in tables 8.2, 8.3, 8,5 8.6,
8.7 and 8.8 are not consistent with the amounts stated in table A.1.
Please clarify the correct amounts.

23\. Actual dose rates of region B (Page 22) and D (Page 27) increased
in 2003 compared to 2002. Please explain why the dose rates increased.

24\. In region D, a formulation of 90:10 methyl bromide:chloropicrin was
used during 2000-2002. Why did use return to the 98:2 formulation in
2003?

25\. Party considers containerized or substrate production too expensive
for tree seedlings and includes some economic considerations. However,
there is no specific validation of the economics for herbaceous
perennials (e.g. Delphinium, Hostas, Phlox) also included in this
nomination. These species are different from trees with respect to
cropping cycle, use, etc, and are propagated in plug trays or liners
with different kinds of substrates in many countries and even in the
United States (e.g. see reference below).  Please present information on
why the containerized or substrate production cannot be used foe the
specific circumstances of this nomination.

 Reference: Styer, R.C. and D.S. Koranski 1997. Plug and Transplant
production - a Grower\'s Guide. Ball Publishing, USA, 373 pp.

#### US Orchard replants

1.  Based on the information in the text and in the BUNI, it appears
    that methyl bromide is nominated for critical use in 3 situations:

-   where the "key pest" is/are the causal agent(s) of Replant Disorder
    which has an unknown etiology (35-50% of the stone fruit area, 35%
    of the grape area, 85% of the walnut area, and 35-50% of the almond
    area);

```{=html}
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```
-   where the primary pests are nematodes and maximum allowed rate of
    1,3-D is not effective due to fine-textured soils and/or inability
    to sufficiently the dry the soil at the deeper depths to the level
    required for effective use of 1,3-D (35-50% of area for all 4 crops
    )

```{=html}
<!-- -->
```
-   where primary pests are nematodes and Township caps prevent the use
    of 1,3-D, which would otherwise be expected to be effective (2-8% of
    area for all 4 crops)

> Please confirm if this is a correct understanding of the nomination.
> If it is not correct, please clarify.

1.  For those areas, where the primary pests are nematodes, but 1,3-D
    cannot effectively be used (situations #2 and #3 above), please
    clarify why metham sodium, alone or combined with chloropicrin, is
    not an effective MB alternative and provide references.

2.  In Table 7.1, Average Total Replant Area in 2001 and 2002 and
    Proportion of Total Replant Area Treated with Methyl Bromide are
    given only for almonds and are designated as "Not Available" for
    stone fruit, grape, and walnut. Has this information become
    available in the time since the nomination was prepared? If so,
    please provide this info.

3.  In Table 8.1 (and in the BUNI), the footnotes indicate that some of
    the stone fruit and almond area is strip fumigated. Please clarify
    if the application rate of active ingredient (336 and 364 kg/ha) in
    the table is the rate per treated unit of area in the strips or how
    this value was calculated.

4.  What were the primary pests in the trial in table 16.1 Stone fruit
    -- specific nematodes, specific fungi, or the unknown replant
    disorder causal agent(s)?

5.  In table 11.1 Grapes, the soil type is given as "light", but BUNI
    shows that 35-50% of the grape area is impacted by Unsuitable Soil.
    Since it is not due to fine-textured soils, is the Unsuitable Soil
    due to inability to dry down the deeper soil depths? Please clarify.

6.  In Table 11.1 Walnut, soil type is given as 40% medium and 30%
    heavy. BUNI states that 35-50% of the area is impacted by unsuitable
    soils. Does that mean that some of the area with medium soil types
    can use alternatives? Which alternatives have been successfully
    used?

7.  In Section 11ii Walnut, the nomination states that 70% of walnut
    orchard situations are impacted by soil moisture restrictions and
    township cap restrictions. BUNI shows 35-50% impacted by Unsuitable
    Soils and 2-8% impacted by Regulatory Issues. If there was no
    overlap between the two areas, the maximum in the BUNI for
    Unsuitable Soil and Regulatory restrictions would be 58%. What
    alternatives are being used in the remaining 12% of the area? Please
    clarify.

8.  Is the soil moisture restriction mentioned in section 11ii-Walnut
    due to surface soil conditions as stated here, or due to deeper soil
    moisture conditions as described elsewhere in the CUN, or to some
    combination of both? Please clarify.

9.  Table 16.1 Walnuts refers the reader to Table 16 for stone fruit,
    grapes and almonds. Are there no data for Replant Disorder or
    nematode control available on walnuts? If such data are available,
    please provide.

10. Table 10.1-Almonds states that 30% of the area is impacted by
    Township caps and 65% by soil moisture issues. BUNI states that only
    2-8% of the requested area is impacted by Township caps and 35-50%
    impacted by Unsuitable Soil issues. What alternatives are being used
    on the 22-28% of the area impacted by Township Caps, but not
    requesting critical use MB and on the 15-30% impacted by soil
    moisture issues, but not requesting MB? Why can these alternatives
    not be used on the remaining area?

11. In Table 16.1 -- Almond, what were the primary pests in the trial --
    specific nematodes, specific fungi, or the unknown replant disorder
    causal agent(s)?

12. In Section 23, the nomination states that orchard replant research
    will require 1658 kg per year of MB for 2005 and 2006. This is the
    2007 nomination, and BUNI shows a research amount of 1658 kg, so is
    it accurate to say that 1658 kg of MB is also needed for research in
    2007?

#### us Ornamentals

1.  MBTOC is still not clear as to the proportion of the cropping area
    that is presently treated. In the BUNI form at the end of the
    nomination there is a column labeled \"regional areas\" where 11% is
    indicated for California and 90% for Florida. Party is asked to
    clarify if this corresponds to the treated area.

2.  Acreages submitted by Party for the American Flower industry do not
    seem to coincide with those appearing in official publications such
    as **USDA *Floriculture and Nursery Crops Situation and Outlook
    Yearbook/ FLO- 2004/Junie, 2004*
    [www.ers.usda.gov](http://www.ers.usda.gov/)**

 

#### IN CALIFORNIA

3.  Party states that regulatory constraints such as township caps
    restrict MB use in California. MBTOC is not clear as to what
    percentage of the cropping area is affected by this restriction.
    Party states that \"It is expected that about 30% of the 2000
    fumigated area could not have used 1,3-D at the current 2x cap which
    is expected to apply through at least 2004". MBTOC requests Party to
    confirm that this holds for 2007. The BUNI form states that township
    caps (regulatory issues) affect between 31 and 44% of area.

 

**IN FLORIDA**

4.  Party states that buffer zones restrict use of 1,3-D because often
    flowers are produced on small parcels of land, often near homes.
    1,3-D cannot be used in greenhouses. Party is asked to confirm what
    proportion of the cropping area is affected by this issue. On p. 55
    Party states that buffer zones \"will reduce cropping area by 10%\".
    The BUNI however allocates a 0 under the buffer zone column for both
    California and Florida, although it cites karst topography as
    affecting 40% of area in Florida.

**USA strawberry fruit**

**Data on MB usage**

1.  On page 38, the dosage rate of MB active ingredient in kg/ha in 2003
    is shown as increased to 24.7kg/ha from 18.5kg/ha in the previous
    year. The Party is requested to provide MBTOC with information on
    the reason why.

2.  Page 11 stated that the formulation of MB/CP is 98:2 in Florida,
    while Page 76. stated is 67:33 or 50:50. Which formulation is
    correct?

3.  The CUN does not explain fully why this sector cannot adopt 50:50
    MB/Pic in Florida and eastern states, and 57:43 (or 50:50 if
    registered) in California.

4.  What statistics are available on the use of 1,3-D, chloropicrin,
    metham, other combinations of fumigants or chemicals, and other
    types of alternatives, for strawberry fruit in Florida, California
    and eastern states for 2002, 2003 and 2004? MBTOC would appreciate
    information on recent trends.

**VIF**

5.  VIF has been in commercial use in most regions of the EC for several
    years, because it has been a legal requirement for four years.
    Substantial trials were conducted in several countries and climates.
    At this stage, there is little technical justification for not
    adopting VIF, since there is substantial practical experience with
    this technology in many different types of cropping systems. What
    are the limiting impediments (if any) to the widespread adoption of
    this proven emission reduction technology?

**Economic issues**

6.  Concerning table 21.1, table 22.1 and table E.1,E.2 andE.3:

\(1\) Please check the accuracy of Table 21.1 (copied in Annex 2 below).
Are the operating costs the same for methyl bromide and other
alternatives? Are the operating costs the same over three years? For
example, in this period it is likely that the cost of MB will increase.
Please provide the actual costs in 2004 and 2005 and estimated cost in
2006..

\(2\) Concerning Table E.1 (Page 50) for California, if the figure of
table 21.1 is as it is, the figure of table E.1 should be changed as
shown in red colour in Annex 2 below. Please check it whether it is
appropriate or not.

\(3\) Concerning the Table E.2 (Page 51) for Florida and Eastern United
States, figures should be changed to the ones written in red below.

7.  What prices and doses were used for each alternative chemical
    product in the economic tables? What are the current commercial
    prices of these products in 2005, in each region?

#### 

####  Efficacy / yield loss

8.  Could the Party please indicate the treated area percent proportion
    compared to one hectare in Eastern USA and Florida with bed/strip
    treatment system? Is MB bed/strip treatment effective for the
    control of nematodes and nutsedge?

9.  In Table 16.1 on effectiveness of alternatives for 'key pest 1
    yellow nutsedge' (page 21-22) the first study indicated that MB/CP
    (at 392 kg/ha) gave no significant difference in native weed biomass
    compared with alternatives chloropicrin and 1,3-D/CP (especially at
    higher rates, and/or with VIF), in control of 'Key pest yellow
    nutsedge'. The second and third study in Table 16.1 indicated that
    certain doses of alternatives, chloropicrin, 1,3-D/CP and MS (35 gal
    drip) provided higher yield than MB/CP. However, the estimates of
    yield loss in Table C.1 in California, eastern states and Florida
    (pages 23, 33 and 43) appear to be taken only from Shaw and
    Larson (1999) and Locascio (1999). More recent studies, using
    improved application methods and other combinations of
    fumigants/chemicals have been carried out since that time. Such
    studies, using the better application methods and know-how currently
    available, should form the basis for the yield analysis.

**Steep slopes**

10. On steep slopes, it is feasible to use shank injection for
    alternative fumigants. This is the method currently used for MB,
    according to the CUN (page 15). The CUN does not adequately explain
    why shank injection could not be used for alternatives on steep
    slopes.

**Dates of planting, harvest, rotational crops**

11. Please provide more precise dates of planting and harvest (start /
    finish) and key market windows for: Northern California, southern
    California, Florida and eastern states. Where rotational crops are
    common, please identify them and provide planting and harvest dates,
    for each region.

**Nutsedge**

12. Could the Party please give more information about the way in which
    nutsedge propagates or is spread? MB itself provides incomplete
    control. Which cultural control practices have been investigated for
    nutsedge control in strawberry fruit?

13. Why is it not considered feasible to use herbicides to control
    nutsedge before transplanting strawberry? The CUN does not provide a
    detailed update on progress in examining and registering herbicides
    for the control of nutsedge in strawberry fruit. Please provide an
    update.

**Nematicides**

14. Fosthiazate, a nematicide, was registered by USEPA a couple of years
    ago. The Party is requested to provide MBTOC with the information on
    registration and deployment in the strawberry industry, in each
    relevant region (California, Florida, eastern US).

**Supporting data on area affected by moderate to severe pest pressure**

15. The previous CUN stated that the area (hectares) affected by
    moderate to severe key pests (eg. nutsedge) was derived from
    informal sources such as websites, discussions with researchers and
    growers etc. Is additional data now available to substantiate these
    informal sources? Have any surveys been carried out on the extent
    and severity of key target pests that form the basis of the CUNs
    in (a) Florida, (b) eastern states, and (c) California? If so, MBTOC
    would be grateful to receive copies of the detailed survey results.

**Regulatory restrictions on 1,3-D**

16. MBTOC recognizes that regulatory restrictions restrict the use of
    1,3-D in certain regions. Some other fumigants/chemicals have been
    found effective in controlling the key nematode species affecting
    strawberry fruit production. To what extent can these techniques be
    adopted in the areas where 1,3-D cannot be used for regulatory
    reasons? Please re-calculate the CUN tonnage to take full account of
    other available treatments/combinations in areas affected by
    regulatory restrictions on 1,3-D.

17. Are there different definitions for 'karst geology' and 'karst
    topography'? The CUN cites a Registration Eligibility Decision for
    1,3-D from 1998 (page 45). We understand that some label changes
    were proposed relating to karst topography. Have any changes been
    made in the federal, state or county restrictions, labels or other
    controls relating to karst geology/topography in the last few years?
    If so, what are the current restrictions relating to karst? If these
    changes will mean that 1,3-D can be used on a larger area than
    estimated in the CUN, please provide up-dated calculations of
    hectares.

**Information relating to potential adoption time (Annex I of Prague
MOP)**

18. For each region (California, Florida and eastern states), please
    estimate: (a) the number of fumigation companies that currently
    provide MB fumigation services to growers, (b) the estimated number
    of growers in each region, and (c) the number and types of
    government and private training and extension facilities and
    personnel available to the strawberry sector.

**Other information**

19. If you are aware of any additional information that would assist
    MBTOC/TEAP to make a complete technical and economic evaluation of
    the CUN, as defined in Decision IX/6, we would be very grateful to
    receive the information.

ANNEX 1

**Amount of MB USED/REQUESTED, no of years Requested & HISTORIC USE:**

<table>
<colgroup>
<col style="width: 11%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 13%" />
<col style="width: 11%" />
</colgroup>
<tbody>
<tr class="odd">
<td><h2 id="section-1"> </h2></td>
<td><strong>1998</strong></td>
<td><strong>1999</strong></td>
<td><strong>2000</strong></td>
<td><strong>2001</strong></td>
<td><strong>2002</strong></td>
<td><strong>2003</strong></td>
<td><strong>2004</strong></td>
<td><strong>2005</strong></td>
<td><strong>2006</strong></td>
<td><h4 id="formulation">Formulation</h4></td>
<td><strong>Proportion of Use</strong></td>
</tr>
<tr class="even">
<td><strong>California</strong></td>
<td>1,928</td>
<td>2,264</td>
<td>1.919</td>
<td>1,611</td>
<td>1,592</td>
<td>1,651</td>
<td></td>
<td></td>
<td>1087</td>
<td>Mostly 67:33 (Flat Fume)</td>
<td></td>
</tr>
<tr class="odd">
<td><strong>MB Dosage rate g/m<sup>2</sup></strong></td>
<td>26</td>
<td>27.5</td>
<td>24.4</td>
<td>19.1</td>
<td>20.1</td>
<td>20.1</td>
<td></td>
<td></td>
<td>20.1</td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td><p><strong>MB+CP</strong></p>
<p><strong>Dosage rate g/m<sup>2</sup></strong></p></td>
<td>38.8</td>
<td>41.0</td>
<td>36.4</td>
<td>28.5</td>
<td>30.0</td>
<td>30.0</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="odd">
<td colspan="12"></td>
</tr>
<tr class="even">
<td><strong>Eastern USA</strong></td>
<td>317</td>
<td>239</td>
<td>254</td>
<td>274</td>
<td>283</td>
<td>320</td>
<td></td>
<td></td>
<td>230</td>
<td>67:33 (Bed)</td>
<td></td>
</tr>
<tr class="odd">
<td><strong>Dosage rate g/m<sup>2</sup></strong></td>
<td>22</td>
<td>15.1</td>
<td>15.0</td>
<td>15.1</td>
<td>15.1</td>
<td>15.1</td>
<td></td>
<td></td>
<td>15.1</td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td><p><strong>MB+CP</strong></p>
<p><strong>Dosage rate g/m<sup>2</sup></strong></p></td>
<td>32.8</td>
<td>22.5</td>
<td>22.4</td>
<td>22.5</td>
<td>22.5</td>
<td>22.5</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="odd">
<td colspan="12"></td>
</tr>
<tr class="even">
<td><strong>Florida</strong></td>
<td>551</td>
<td>464</td>
<td>471</td>
<td>486</td>
<td>516</td>
<td>708</td>
<td></td>
<td></td>
<td>296</td>
<td>98:2 (strip)</td>
<td></td>
</tr>
<tr class="odd">
<td><strong>Dosage rate g/m<sup>2</sup></strong></td>
<td>22.0</td>
<td>18.5</td>
<td>18.8</td>
<td>18.5</td>
<td>18.5</td>
<td>24.7</td>
<td></td>
<td></td>
<td>18.5</td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td><p><strong>MB+CP</strong></p>
<p><strong>Dosage rate g/m<sup>2</sup></strong></p></td>
<td>22.4</td>
<td>18.9</td>
<td>19.2</td>
<td>18.9</td>
<td>18.9</td>
<td>25.2</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
</tbody>
</table>

ANNEX 2

  -----------------------------------------------------------------------
  **21. [Operating]{.smallcaps} [Costs of Alternatives Compared to Methyl
  Bromide Over 3-Year Period:]{.smallcaps}**

  -----------------------------------------------------------------------

**Table 21.1: Operating Costs of Alternatives Compared to Methyl Bromide
Over 3-Year Period**

  -------------------------- ------------------------------- --------------------------- ------------------ ------------------ ------------------
  **[Region]{.smallcaps}**   **[Alternative]{.smallcaps}**   **[Yield\*]{.smallcaps}**   **[Cost in year    **[Cost in year    **[Cost in year
                                                                                         1]{.smallcaps}**   2]{.smallcaps}**   3]{.smallcaps}**
                                                                                         *(US\$/ha)*        *(US\$/ha)*        *(US\$/ha)*

  **California**             **Methyl Bromide**              **100%**                    **\$65,888**       **\$65,888**       **\$65,888**

                             Chloropicrin + Metham sodium    73%                         \$65,683           \$65,683           \$65,683

                             1,3-D + chloropicrin            86%                         \$65,664           \$65,664           \$65,664

                             Metham Sodium                   70%                         \$65,684           \$65,684           \$65,684

  **Florida**                **Methyl Bromide**              **100%**                    **\$44,254**       **\$44,254**       **\$44,254**

                             1,3-D + chloropicrin            86%                         \$43,030           \$43,030           \$43,030

                             Chloropicrin + Metham Sodium    73%                         \$39584            \$39584            \$39584

                             Metham Sodium                   70%                         \$38,818           \$38,818           \$38,818

  **Eastern United States**  **Methyl Bromide**              **100%**                    **\$29,482**       **\$29,482**       **\$29,482**

                             Chloropicrin + Metham sodium    73%                         \$30,555           \$30,555           \$30,555

                             1,3-D + chloropicrin            86%                         \$31,658           \$31,658           \$31,658

                             Metham Sodium                   70%                         \$30,270           \$30,270           \$30,270
  -------------------------- ------------------------------- --------------------------- ------------------ ------------------ ------------------

*\* As percentage of typical or 3-year average yield, compared to methyl
bromide.*

  -----------------------------------------------------------------------
  **22. [Gross and Net Revenue]{.smallcaps}**

  -----------------------------------------------------------------------

**Table 22.1: Year 1, 2, 3 Gross and Net Revenue**

+----------+--------------------+------------------+------------------+
| #### [Y  |                    |                  |                  |
| ear 1, 2 |                    |                  |                  |
| , 3]{.sm |                    |                  |                  |
| allcaps} |                    |                  |                  |
+----------+--------------------+------------------+------------------+
| **[Regio | **[Alternati       | **[Gross revenue | **[Net Revenue   |
| n]{.smal | ves]{.smallcaps}** | for last         | for last         |
| lcaps}** |                    | reported         | reported         |
|          | *(as shown in      | yea              | yea              |
|          | question 21)*      | r]{.smallcaps}** | r]{.smallcaps}** |
|          |                    |                  |                  |
|          |                    | *(US\$/ha)*      | *(US\$/ha)*      |
+----------+--------------------+------------------+------------------+
| **Cali   | **Methyl Bromide** | **\$76,252**     | **\$10,363**     |
| fornia** |                    |                  |                  |
+----------+--------------------+------------------+------------------+
|          | Chloropicrin+      | \$55,664         | (\$10,020)       |
|          | Metham sodium      |                  |                  |
+----------+--------------------+------------------+------------------+
|          | 1,3-D chloropicrin | \$65,548         | (\$3,840)        |
+----------+--------------------+------------------+------------------+
|          | Metham Sodium      | \$53,376         | (\$12,307)       |
+----------+--------------------+------------------+------------------+
| **F      | **Methyl Bromide** | **\$55,168**     | **\$10,914**     |
| lorida** |                    |                  |                  |
+----------+--------------------+------------------+------------------+
|          | 1,3-D +            | \$47,224         | \$4,194          |
|          | chloropicrin       |                  |                  |
+----------+--------------------+------------------+------------------+
|          | Chloropicrin +     | \$40,273         | \$689            |
|          | Metham Sodium      |                  |                  |
+----------+--------------------+------------------+------------------+
|          | Metham Sodium      | \$38,728         | (\$90)           |
+----------+--------------------+------------------+------------------+
| *        | **Methyl Bromide** | **\$51,892**     | **\$22,410**     |
| *Eastern |                    |                  |                  |
| United   |                    |                  |                  |
| States** |                    |                  |                  |
+----------+--------------------+------------------+------------------+
|          | Chloropicrin+      | \$37,881         | \$7,327          |
|          | Metham sodium      |                  |                  |
+----------+--------------------+------------------+------------------+
|          | 1,3-D chloropicrin | \$44,608         | \$12,950         |
+----------+--------------------+------------------+------------------+
|          | Metham Sodium      | \$36,624         | \$6,054          |
+----------+--------------------+------------------+------------------+

  -----------------------------------------------------------------------
  **[[Measures of Economic Impacts of Methyl Bromide
  Alternatives]{.underline}]{.smallcaps}**

  -----------------------------------------------------------------------

**[California - Table E.1: Economic Impacts of Methyl Bromide
Alternatives]{.smallcaps}**

+--------------------------------+--------+--------+--------+--------+
| **California**                 | **[    | *      | **[    | **[    |
|                                | Methyl | *[Pic+ | 1,3-d+ | Metham |
|                                | Brom   | Metham | pic]{. | Sod    |
|                                | ide]{. | Sod    | smallc | ium]{. |
|                                | smallc | ium]{. | aps}** | smallc |
|                                | aps}** | smallc |        | aps}** |
|                                |        | aps}** |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[Yield Loss                  | 0%     | 27%    | 14%    | 30%    |
| (%)]{.smallcaps}**             |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[Yield per Hectare           | 48,438 | 35,359 | 41,639 | 33,906 |
| (Fresh)]{.smallcaps}**         |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[\* Price per Unit           | \$1.71 | \$1.62 | \$1.62 | \$1.62 |
| (us\$)]{.smallcaps}**          |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[= Gross Revenue per Hectare | \$     | \$     | \$     | \$     |
| (us\$)]{.smallcaps}**          | 76,252 | 55,684 | 65,548 | 53,376 |
+--------------------------------+--------+--------+--------+--------+
| **[- Operating Costs per       | \$     | \$     | \$     | \$     |
| Hectare (us\$)]{.smallcaps}**  | 65,888 | 65,888 | 65,888 | 65,888 |
+--------------------------------+--------+--------+--------+--------+
| **[= Net Revenue per Hectare   | \$     | \$-    | \$-340 | \$-    |
| (us\$)]{.smallcaps}**          | 10,364 | 10,204 |        | 12,515 |
+--------------------------------+--------+--------+--------+--------+
| ##                             |        |        |        |        |
| ## [Loss Measures]{.smallcaps} |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[1. Loss per Hectare         | \$0    | 17,792 | 11,817 | 19,474 |
| (us\$)]{.smallcaps}**          |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[2. Loss per Kilogram of     | \$0    | 88.19  | 58.57  | 96.52  |
| Methyl Bromide                 |        |        |        |        |
| (us\$)]{.smallcaps}**          |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[3. Loss as a Percentage of  | 0%     | 24%    | 16%    | 26%    |
| Gross Revenue                  |        |        |        |        |
| (%)]{.smallcaps}**             |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+
| **[4. Loss as a Percentage of  | 0%     | 131%   | 87%    | 144%   |
| Net Revenue (%)]{.smallcaps}** |        |        |        |        |
+--------------------------------+--------+--------+--------+--------+

**[Florida - Table E.2: Economic Impacts of Methyl Bromide
Alternatives]{.smallcaps}**

  --------------------------------- ------------------------ ----------------------------- ----------------------- -----------------------
  **Florida**                       **[Methyl                **[1,3-d+pic]{.smallcaps}**   **[Pic+Metham           **[Metham
                                    Bromide]{.smallcaps}**                                 Sodium]{.smallcaps}**   Sodium]{.smallcaps}**

  **[Yield Loss (%)]{.smallcaps}**  0%                       14%                           27%                     30%

  **[Yield per                      5,046                    4,319                         3,683                   3,542
  Hectare]{.smallcaps}**                                                                                           

  **[\* Price per Unit              \$10.93                  \$10.93                       \$10.93                 \$10.93
  (us\$)]{.smallcaps}**                                                                                            

  **[= Gross Revenue per Hectare    \$55,168                 \$47,224                      \$40,273                \$38,728
  (us\$)]{.smallcaps}**                                                                                            

  **[- Operating Costs per Hectare  \$44,254                 \$43,030                      \$39,584                \$38,818
  (us\$)]{.smallcaps}**                                                                                            

  **[= Net Revenue per Hectare      \$10,914                 \$4,194                       \$689                   \$―90
  (us\$)]{.smallcaps}**                                                                                            

  **[Loss Measures]{.smallcaps}**                                                                                  

  **[1. Loss per Hectare            \$0                      \$6,720                       \$10,225                \$11,004
  (us\$)]{.smallcaps}**                                                                                            

  **[2. Loss per Kilogram of Methyl \$0                      \$33                          \$51                    \$55
  Bromide (us\$)]{.smallcaps}**                                                                                    

  **[3. Loss as a Percentage of     0%                       14.4%                         27.0%                   29.8%
  Gross Revenue (%)]{.smallcaps}**                                                                                 

  **[4. Loss as a Percentage of Net 0%                       62%                           94%                     101%
  Revenue (%)]{.smallcaps}**                                                                                       
  --------------------------------- ------------------------ ----------------------------- ----------------------- -----------------------

**[Eastern United States - Table E.3: Economic Impacts of Methyl Bromide
Alternatives]{.smallcaps}**

  --------------------------------- ------------------------ ----------------------- ----------------------------- -----------------------
  **Eastern United States**         **[Methyl                **[Pic+Metham           **[1,3-d+pic]{.smallcaps}**   **[Metham
                                    Bromide]{.smallcaps}**   Sodium]{.smallcaps}**                                 Sodium]{.smallcaps}**

  **[Yield Loss (%)]{.smallcaps}**  0%                       27%                     14%                           30%

  **[Yield per                      22,417                   16,364                  19,270                        15,692
  Hectare]{.smallcaps}**                                                                                           

  **[\* Price per Unit              2.59                     2.59                    2.59                          2.59
  (us\$)]{.smallcaps}**                                                                                            

  **[= Gross Revenue per Hectare    51,892                   37,881                  44,608                        36,324
  (us\$)]{.smallcaps}**                                                                                            

  **[- Operating Costs per Hectare  29,482                   30,555                  31,658                        30,270
  (us\$)]{.smallcaps}**                                                                                            

  **[= Net Revenue per Hectare      22,410                   7,327                   12,950                        6,054
  (us\$)]{.smallcaps}**                                                                                            

  **[Loss Measures]{.smallcaps}**                                                                                  

  **[1. Loss per Hectare            \$0                      14,942                  9,319                         16,215
  (us\$)]{.smallcaps}**                                                                                            

  **[2. Loss per Kilogram of Methyl \$0                      99.49                   62.05                         107.96
  Bromide (us\$)]{.smallcaps}**                                                                                    

  **[3. Loss as a Percentage of     0%                       29%                     18%                           31%
  Gross Revenue (%)]{.smallcaps}**                                                                                 

  **[4. Loss as a Percentage of Net 0%                       67%                     42%                           73%
  Revenue (%)]{.smallcaps}**                                                                                       
  --------------------------------- ------------------------ ----------------------- ----------------------------- -----------------------

####### US Strawberry nurseries

1.  What are the constraints to much wider use of VIF, combined with MB
    and other fumigants as 1,3-D and Pic, where applicable combined with
    solarization.

**Certification:**

2.  Is 100% of this nomination for certified propagative material?

3.  Has part of the nomination been exempted under QPS? Specify
    amount/proportion XXt(eg 80%)?

4.  Is participation in the certification program mandatory or
    voluntary? Please provide copy of certification requirements

5.  Are the requirements of the certification program specified in
    local, regional, or national regulations?

6.  Is the certification required to export the propagative material
    within regional, State or international countries (Please specify)?

7.  What are the certification standards? For example, must be free of
    specific pests or pathogens, must be free of all pests and
    pathogens, tolerance levels, plant must be of a certain size, etc.

8.  Is the use of methyl bromide mandated for certification? Is a
    minimum rate of methyl bromide specified?

9.  Are there soil disinfestation measures other than MB that are
    approved for certification either for specific crops/growing
    conditions or broadly for many crops/growing conditions? Why can't
    these be used in the circumstances of the nomination?

10. Please provide data demonstrating that MB results in
    pest/pathogen-free propagative material.

11. Please provide data showing that MB alternatives either can or
    cannot meet pathogen/pest-free level required for certification by
    providing data comparing pest/pathogen populations on propagative
    materials grown in 1) soil treated with methyl bromide, 2) untreated
    soil, 3) 1,3-D and chloropicrin alone and in combination,
    [and]{.underline} 4) other relevant alternatives. While plant growth
    data are useful, they do not substitute for pest/pathogen data if
    the certification requirement is for pest/pathogen-free propagative
    material.

12. What are the consequences of not meeting the pest/pathogen-free
    standards? For example, propagative material cannot be sold,
    material can be sold as lower quality/lower price, propagative
    materials must be treated before selling to kill pest/pathogen (e.g.
    hot water dips, etc.), etc.

13. If certification isn't mandated by law or regulation, is it used as
    a quality standard demanded or expected in order to market the crop?
    Why can't MB alternatives be used to meet the quality standard?

14. What are the consequences of not meeting the quality standard? For
    example, inability to sell crop, lower price for crop, etc.

####### US Tomatoes

1.  Please discuss the suitability of 1,3-D + Pic injected in areas
    where field topography make it difficult to use drip application

2.  Please discuss the potential for using reduced dosage of 1,3-D +
    Pic + VIF and/or solarization as an alternative to MB?

3.  Combination of fumigants and herbicides are reported as a promising
    alternative but no clear data (total area, costs, etc.) are given.
    Please specify?

4.  VIF testing goes back to 2003. Is the final data available yet? What
    are the constraints to much wider use of VIF, combined with MB and
    other fumigants as 1,3-D and Pic, where applicable combined with
    solarization.

#### US Turf

1.  The CUN notes that primary MB alternatives for sod production are
    metham sodium and dazomet, often in combination with chloropicrin
    and in some cases, depending on pests, 1,3-D (CUN page 7). The CUN
    also states that "dazomet and metham sodium with chloropicrin have
    looked as good (statistically) and nearly as good (numerically) in
    control of nutsedge and weedy grasses as MB at the high use rates
    for turf (560 kg/ha) (e.g. Unruh and Brecke, 2001; Unruh et al.,
    2002)" (page 9). It is noted that barrier sheets can also increase
    the efficacy of metham. The CUN states in several places it is
    unable to determine yield or quality loss resulting from
    alternatives "since research shows variability even among MB
    treatments, depending on location of trials and pest type" (page
    13). However, the BUNI takes account only of dazomet (alone). It
    would be appropriate to revise the BUNI to take account of the
    leading alternatives for this sector.

2.  Q2. The use of improved application methods for metham and dazomet
    are important, as noted in the CUN. Improved equipment for the
    application of dazomet for turf. Improved equipment for more uniform
    distribution of metham sodium is being used in Europe, South America
    and Africa (eg. rotating-spading injection equipment); and for
    dazomet in Europe. Has similar equipment that provides a uniform
    distribution in soil, been examined or used in the USA for
    turfgrass?

3.  Q3. For each state (California, Florida, Georgia, Alabama and Texas)
    please specify the key target pest species for which alternatives
    are considered not available, and the precise reasons for the CUN.

4.  Q4. Table 14.1: The section pre or post emergent herbicides refers
    the reader to item 13. However, Item 13 does not appear to provide
    any discussion on herbicides. Please provide information about pre
    and post emergent about herbicides.

###### Certified sod

5.  Do the sod certification standards in the main CUN states
    (California, Florida, Georgia, Alabama and Texas) specifically
    require MB fumigation as a condition of certification? If the
    certification standards for these states have not been sent to MBTOC
    previously, please provide copies.

###### Industry structure

6.  How many fumigation companies provide MB as a service to the turf
    producers in the CUN? Do the current metham sodium users apply
    metham themselves, or do they use a fumigation company?
    Approximately how many growers/turf producers are covered by this
    CUN?

###### Minimizing MB use and emissions

7.  This sector appears to have made little or no progress in minimizing
    MB use and emissions, in contrast with some other sectors/countries.
    The turf sector wishes to continue using MB:Pic 98:2 in 2007 (Table
    8.1 page 8). The sector wants to use a high dose of MB (480 kg/ha)
    which is similar to the rate used in 1998 (488 kg/ha). We note that
    the EPA has reduced the nominated dose to 300 kg/ha. Is it
    technically feasible to make further reductions prior to or during
    2007? If so, please provide details.

8.  Barrier films have not been adopted. The CUN mentions that the
    requesting consortia identified future plans for examining high
    density polyethylene to reduce MB emissions (page 15), however the
    CUN does not provide any timelines for introduction of barrier
    films.

###### Economic impact

9.  The economic assessment compares MB with dazomet only. This is
    surprising because research information in the CUN indicates that
    metham sodium + chloropicrin (+ PV tarp) is a leading alternative.
    Please provide economic data for this alternative combination, and
    all other leading combinations.

10. Please provide the current cost of MB (US\$/ha) in 2005, and
    indicate expected price trends for 2007.

###### Actions to rapidly develop and deploy alternatives

11. The CUN does not provide information on what actions will be taken
    to rapidly develop and deploy alternatives. Please provide this
    information and timeline.

**Sod Production**

Please respond to these questions for the sod production remaining in
the nomination after subtractions were made for use rate and growth
adjustments.

[Certification Questions]{.underline}

1\. Is 100% of this nomination is for certified propagative material?

2\. Is participation in the certification program mandatory or
voluntary?

3\. Are the requirements of the certification program specified in
local, regional, or national regulations?

4\. Is the certification required to export the sod?

5\. What are the certification standards? For example, must be free of
specific pests or pathogens, must be free of all pests and pathogens,
plant must be of a certain size, etc.

6\. Is the use of methyl bromide mandated for certification? Is a
minimum rate of methyl bromide specified?

7\. Are there soil disinfestation measures other than MB that are
approved for certification either for specific growing conditions or
broadly for many growing conditions? Why can't these be used in the
circumstances of the nomination?

8\. Please provide data demonstrating that MB results in
pest/pathogen-free sod.

9\. Please provide data showing that MB alternatives either can or
cannot meet pathogen/pest-free level required for certification by
providing data comparing pest/pathogen populations on propagative
materials grown in 1) soil treated with methyl bromide, 2) untreated
soil, 3) 1,3-D and chloropicrin alone and in combination, 4) metham
sodium/dazomet, [and]{.underline} 5) other relevant alternatives. While
plant growth data are useful, they do not substitute for pest/pathogen
data if the certification requirement is for pest/pathogen-free
propagative material.

10\. What are the consequences of not meeting the pest/pathogen-free
standards? For example, sod cannot be sold, material can be sold as
lower quality/lower price, propagative materials must be treated before
selling to kill pest/pathogen (e.g. hot water dips, etc.), etc.

11\. If certification isn't mandated by law or regulation, is it used as
a quality standard demanded or expected in order to market the crop? Why
can't MB alternatives be used to meet the quality standard?

12\. What are the consequences of not meeting the quality standard? For
example, inability to sell crop, lower price for crop, etc.

 

[General Questions]{.underline}

13\. The Amount of Nomination (76,112 kg) shown in Table A1 of the
Executive Summary does not appear to include the 1,928 kg shown for
research in the BUNI. Other U.S. CUNs have included the research amount
in the amount shown in the Executive Summary table. Is the nominated
amount 76,112 kg or 76,112+1,928 kg = 78,040 kg?

14\. Are halosulfuron or trifloxysulfuron registered for use to control
nutsedge or other weeds in sod production? If not, will the products be
registered in the future?

15\. The rate of 48 g/m^2^ of methyl bromide is higher than that
required by several other certified nursery uses of methyl bromide. What
circumstances of the sod production represented in this CUN require the
high rate of methyl bromide? Please present data showing that lower
rates are not sufficient.

16\. Can a formulation with a higher rate of chloropicrin be used for
some or all of the circumstances of this nomination, i.e., instead of
98:2, use 70:30 methyl bromide:chloropicrin?

17\. The BUNI includes some columns not present in some of the other
U.S. nominations, and not explained in the attached footnotes. Please
explain what the "% adopt" under the heading "% Adopt New Fumigants"
means. Please describe how the value for "% per year" under "% Adopt New
Fumigants" was reached.