+--------------------+-------------------------------------------------+
| **[Nominating      | # The United States of America                  |
| Par                |                                                 |
| ty:]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+
| **[Brief           | Methyl Bromide Critical Use Nomination for      |
| Descriptive Title  | Preplant Soil Use on Strawberries Nurseries     |
| of                 | Grown in Open Fields or in Protected            |
| Nominati           | Environments                                    |
| on:]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+
| **[Document        | CUN 2003/060, Usc6N12                           |
| Num                |                                                 |
| ber]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+
| **[D               | August 12, 2004                                 |
| ate]{.smallcaps}** |                                                 |
+--------------------+-------------------------------------------------+

**[[Critical Need for Methyl Bromide]{.underline}]{.smallcaps}**

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

+-----------+----------------------------+----------------------------+
| **[Region | **[Key disease(s) and      | **[Specific reasons why    |
| where     | weed(s) to genus and, if   | methyl bromide is          |
| methyl    | known, to species          | needed]{.smallcaps}**      |
| bromide   | level]{.smallcaps}**       |                            |
| use is    |                            |                            |
| reques    |                            |                            |
| ted]{.sma |                            |                            |
| llcaps}** |                            |                            |
+-----------+----------------------------+----------------------------+
| Sou       | **Weeds:** Yellow nutsedge | None of the available      |
| theastern | (*Cyperus esculentus*),    | alternatives provide an    |
| US        | Purple nutsedge (*Cyperus  | acceptable level of        |
|           | rotundus*)                 | control of nutsedge; the   |
|           |                            | affected states'           |
|           | **Diseases:** Black root   | regulatory requirements to |
|           | rot (*Rhizoctonia* and     | meet certification         |
|           | *Pythium spp.*); Crown rot | standards which amount to  |
|           | (*Phytophthora cactorum*); | virtually complete control |
|           | root-knot nematodes        | of fungal diseases and     |
|           | (*Meloidogyne spp.*)       | nematodes, is only         |
|           |                            | attainable with methyl     |
|           |                            | bromide                    |
+-----------+----------------------------+----------------------------+
| C         | **Diseases**: Phytophthora | The State mandatory        |
| alifornia | Crown and Root Rots        | certification program has  |
|           | (*Phytophthora spp.*); Red | strict requirements for    |
|           | Stele (*Phytophthora       | control of diseases and    |
|           | fragariae*); Verticillium  | nematodes which amount to  |
|           | Wilt (*Verticillium        | virtually complete control |
|           | dahliae*); and possibly    | of the key pests. Given    |
|           | others                     | the growing situations     |
|           |                            | encountered over the       |
|           | **Nematodes:**             | course of the 5-year       |
|           |                            | transplant production      |
|           | Root-knot (*Meloidogyne    | cycle (a different growing |
|           | spp.*); sting              | location is used each      |
|           | (*Belonolaimus spp.*);     | year), none of the         |
|           | dagger (*Xiphinema spp.*); | alternatives have thus far |
|           | lesion (*Pratylenchus      | been shown to be           |
|           | spp.*); foliar             | consistently perform at a  |
|           | (*Aphelenchoides spp.*);   | highly effective level at  |
|           | needle (*Longidorus        | soil depths to 3 feet.     |
|           | spp.*); stem (*Ditylenchus |                            |
|           | spp.*)                     | Methyl iodide is           |
|           |                            | considered by most         |
|           | **Weeds:** numerous weeds  | researchers to be viable   |
|           | listed (e.g., annual       | potential alternative,     |
|           | bluegrass, bur clover,     | which is currently         |
|           | carpetweed, chickweed,     | proposed for registration  |
|           | field bindweed, goat       | in the US.                 |
|           | grass, hairy nightshade,   |                            |
|           | lambsquarter, malva,       |                            |
|           | nutsedge, pig weed,        |                            |
|           | portulaca, prostate        |                            |
|           | spurge, puncture vine,     |                            |
|           | purslane, vetch)           |                            |
+-----------+----------------------------+----------------------------+

**[[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]{.smallcaps}**
  (kg)]{.smallcaps}**   (kg)]{.smallcaps}**   

  54,988                56,291                We estimated a more representative
                                              average historical use for 2006 than
                                              2005. Research amount included in
                                              increase.
  --------------------- --------------------- --------------------------------------

**[Figure 1. U.S. Requested, Quarantine and Preshipment and Nominated
Hectares of Strawberry Nurseries]{.smallcaps}**

![](media/image1.wmf)

Footnote: The requested hectares are sum total of all acreages in the
CUE applications. QPS = number of hectares qualifying as quarantine and
pre-shipment. 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}**

*MBTOC Comment - A large amount (88%) of MB use has been exempted to
meet certification requirements for QPS as determined under U.S.
regulatory controls. Technical data provided with the nomination
indicates that metam-sodium and chloropicrin are providing effective
disease control for runner production, but 1,3-D/Pic or 1,3-D alone
followed by metam-sodium, are reported not to be fully effective."*

*MBTOC Question 1 - The Party is requested to clarify how that part of
the nomination that is not classified under the QPS exemption differs
from that categorized as QPS. In particular information is sought on
whether it is required to meet the same performance standards as that
categorized as QPS.*

**US Response -** The same quality standards apply to the non-QPS
nursery stock as the QPS plants, since in-county or in-state fruit
grower customers would not want to purchase lesser quality plants and
would be expected to obtain high quality plants elsewhere in the country
to ensure they were the most robust specimens. This is based in part on
available data that seems to indicate that runner plants produced in
fields where lower yields and/or smaller plants were produced as a
result of using less effective alternatives results in carryover losses
at the fruit production level. Additionally, if one or more growers in
the same general production area were trying to produce two quality
levels of plants they would run the risk of having the mobile pests
moving from the lesser quality plants to the high quality plants and
possibly lose their certification status on the high quality plants.

*MBTOC Question 2 - Clarification is requested on why metam sodium and
chloropicrin as an alternative cannot be adopted more widely. The Party
is requested to supply data to support the claimed lack of effectiveness
of 1,3-D/Pic to the necessary depth.*

**US Response -** The data summarized in the nomination document, which
appear to indicate that metam-sodium and chloropicrin are suitable
alternatives, are derived from tests which all lacked a full spectrum of
the potential pest types (weeds, nematodes, diseases) and generally did
not appear to have adequate and uniform levels of those pests that were
present. This weakness appears to be true for all or most of the
available studies designed for strawberry nursery uses, as well as those
designed for fruit production situations. Accordingly, the results from
such studies will give a number of false-positives for certain
alternatives simply because they were able to provide adequate control
when limited pest species were present, or when non-uniform or low pest
levels were present. Numerous studies exist for strawberries and other
crops that indicate the strengths and weaknesses of the various
alternatives under different pest control situations. Collectively these
data have value in providing an overview of the strengths and weaknesses
of each potential alternative. The U.S. has not been able to find a
comprehensive analysis of this nature. Such an analysis would be
extremely time consuming, but would be the only way to validate the
comparative performance opinions of the available researchers.

Although fumigation in the Southeastern States is generally accomplished
in the fall, delays associated with a late harvest of the preceding crop
and/or cold weather often necessitate that fumigation be conducted in
March and April, which is immediately prior to planting. A similar
situation exists in California. Use of the alternative metam-sodium will
result in an additional 1-2 week plant back delay when applied alone and
longer planting delays when applied sequentially before/after another
fumigant (e.g., Telone, chloropicrin). Southeastern States have
historically experienced 10-15% plant yield (runner) losses as a result
of a 1-week planting delay.

Therefore even greater losses are possible with the longer plant back
delays associated with metam-sodium use, even if metam-sodium were
capable of providing levels of pest control comparable to methyl bromide
at the required soil depths.

Another consideration is that certain studies indicate that chloropicrin
can increase nutsedge weed populations rather than control them.
Nutsedge is the principal weed pest in the Southeastern States and it is
projected to become a problem in California nurseries when methyl
bromide is no longer available.

Long term performance of these alternatives is still not available. The
applicants in California stated that they intend to look for additional
studies, which better, defined the comparative efficacy and/or
performance of chloropicrin, metam-sodium, and other alternatives at the
deeper soil depths. They intend to submit such studies with their next
application.

*MBTOC Question 3 - The rate of MB used in the Southeastern States in
MB/Pic mixtures is very high (413 kg/ha) by world standards.
Clarification is sought as to why such a high rate is required and what
scope there is for reduction to more normal levels, perhaps combined
with emission reduction technologies such as barrier film use. \[Note:
Originally this comment was linked with Michigan growers; subsequently
MBTOC was contacted and it was learned that this comment pertained to
the SE States, rather than Michigan\]*

**US Response -** The methyl bromide rates currently used in the
Southeastern States (413 kg/ha) are about 57 percent higher than those
currently used in California (263 kg/ha). The applicant has stated that
the higher use rate is required because of their need to control
nutsedge. This weed is currently not present in California nurseries.
Their experiences have shown that in many cases rates as high as 487
kg/ha of methyl bromide have been needed to control nutsedge.
Previously, the Southeastern states indicated that they intend to
evaluate the performance of methyl bromide rates as low as 310 kg/ha, so
that growers could conceivably switch from the 67:33 to the 50:50
formulation. However, until these performances are fully evaluated, it
would not be possible to lower methyl bromide rates and ensure efficacy.
In any case, all methyl bromide use is done under tarps, and emissions
and use have been controlled to the extent feasible.

**References**

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