USA CUN16 SOIL Strawberry Fruit Open Field Page 1 of 11

NOMINATING PARTY : The United States of America

FILE NAME: USA CUN1 6 SOIL STRAWBERRY FRUIT Open Field

BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methyl Bromide Critical Use Nomination for Preplant Soil Use for Strawberry Fruit Grown in Open Fields ( Submitted in 201 4 for the 201 6 Use Season)

CROP NAME (OPEN FIEL D OR PROTECTED): Strawberry Fruit Open Field

QUANTITY OF METHYL B ROMIDE NOMINATED:

T ABLE 1: Q UANTITY OF M ETHYL N OMINATED

Year N OMINATION A MOUNT

201 6 231

, 54 0 kg

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy U.S. Department of State
2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A. Telephone: (202) 647

- 3819

Fax: (202) 647

- 1052

E

- mail: SanMartiniFM@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for this
use would result in a significant market disruption

. ■ Yes  No

Signature Name Date

Title:

(Details on this page are req uested under Decision Ex. I/4(7) for posting on the Ozone Secretariat website under Decision Ex. I/4(8).)

This form is to be used by holders of single

- year exemptions to reapply for a subsequent year’s exemption (for example, a Party holding a single

- year exemption for 2005 and/or 2006 seeking further exemptions for 2007). It does not replace the format for requesting a critical

- use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on which the Party’s first

- year exemption was approved, as well as any supplementary information provided by the Party in

relatio n to that original nomination. As this earlier information is retained by MBTOC, a Party need not re

- submit that earlier information.USA CUN16 SOIL Strawberry Fruit Open Field Page 2 of 11

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Yu

- Ting Guilaran

Title: Acting Director

Address: Biological and Economic Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460

U.S.A. Telephone: (703) 308

- 0052

Fax: (703) 308

- 8 0 91

E

- mail: Guilaran.Yu

- Ting@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE:

1. PAPER DOCUMENTS: Title of paper documents and appendices No. of pages Date sent to Ozo ne Secretariat

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming convention see notes above) No. of kilobytes Date sent to Ozone

Secretariat

USA CUN1 6 SOIL STRAWBERRY FRUIT

* Identical to paper documentsUSA CUN16 SOIL Strawberry Fruit Open Field Page 3 of 11



### METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE ( OPEN FIELD OR PROTECTED ENVIRONMENT)

STRAWBERRY FRUIT

1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE

This critical use exemption (CUE) nomination for methyl bromide (Table 1) is for strawberry production area s in California where the re is a critical need for methyl bromide to treat fields 1)

where a transition period is needed for the use of broadcast 100% chloropicrin in fields with high

pest pressure

, in particular

, with Macrophomina and Fusarium (e.g., Koike and Bolda, 2013; Gordon et al., 2011) and 2) where 1,3

- dichloropropene (1,3

- D) is limited by township caps

. While t here is a critical need for methyl bromide th rough 2016

, t he U.S. methyl bromide nomination continues to be reduced and the 2016 nomination is the smallest amount yet nominated (Table 2). This sector will complete its transition to alternatives by the end of 2016, in time for the 2017 use

- season (please see Appendix I

— Transition Plan for California Strawberry Fruit Production )

.

2. SUMMARIZE WHY KEY AL TERNATIVES ARE NOT F EASIBLE

A critical use exemption for methyl bromide is needed for use in 2016 to allow additional time to implement commerci al application of straight chloropicrin at rates up to 392 kg/ha (350 lb/acre) as well as other promising alternatives. Extensive research over the years by California scientists has indicated that alternative methods of treating soil should ultimately be able to manage key pests

. However, a critical use of methyl bromide is needed for some additional time to work out practical

and technical aspects associated with the application of high rates of straight chloropicrin, as well technical aspects affecting the efficacy of other alternatives such as a naerobic soil disinfestation (ASD) and steam

. For example, results of recent studies show some problems

, as well as the potential

, of methyl bromide alternatives:

1. Inconsistency in application of fumigants has resulted in difficulties in managing important pathogens (apparent escapes) in some production locations . R ecent research indicate s , for example, that Macrophomina and Fusarium pathogens may not be fully exposed to fumigation treatment s leaving infested strawberry crowns as a source of inoculum in fumigated fields (Daugovish et al., 2013a). Researchers found that inoculum below drip tapes in strawberry beds did not survive treatment with PicClor 60, but bed shoulder areas contained high levels of pathogens. F lat (broadcast) fumigation , which has been considered the most effective method of fumigation, provided 90% reduction of Macrophomina and

79% reduction of Fusarium populations with 100% chloropicrin

. Future research to address

this issue will investigate how finely infested crowns should be broken down to allow fumigants to kill pathogens, the effect of crop rotation and management, and the effect of increasing the number of drip tapes and their placement

.

2. Anaerobic soil disinfestation (ASD) remains a potential non

- chemical treatment whose efficacy continues to advance as research efforts evaluate the variables that affect its effic acy (Shennan et al., 2013) . Choices of organic matter, soil temperatures and the addition of nitrogen all affect efficacy in managing soil fungal pathogens. I nputs such as nitrogen andUSA CUN16 SOIL Strawberry Fruit Open Field Page 4 of 11

s ome organic matter (e.g., rice bran) continue to be examined to determine if less expensive organic matter and reduced fertilizer applications ca n be effective. Daugovish et al. (2013b) found that insufficient anaerobic conditions may be partially responsible for ASD’s limited effect on soil pathogens in some studies ( although in these tests final yiel d was comparable to chloropicrin treatments)

. This suggested that the method provide d some beneficial effects on plant growth, especially early in the season. Conditions such as h eavy soil s with large soil clumps may allow Macrophomina and other soil

- borne pathogens to escape from anaerobic

conditio ns, and therefore, reduce the effectiveness of the control method.

3. A limited

- time exemption for methyl bromide is critical to allow further innovations in the

efforts to commercial ize soil treatment with steam. Studies with steam

- generating prototypes

indicate d that progress has been made toward commercialization of steam soil disinfestation (Fennimore et al., 2013) . Steam and steam + mustard seed meal gave positive results when yields, weed control, Py thium control, and improved nitrogen availability were measured. Costs of steam were considered comparable to methyl bromide treatments given a certain price of fuel, and returns exceeded costs of steam treatments. Further work is needed to develop equip ment, to improve methods of applying the steam under various field conditions (including reduced application time) , and to ensure the commercial viability of this method.

4. Klonsky et al. (2013 ) found that there is potential to increase net revenue with steam as applicators learn how to use the new technology more efficiently. This learning phase would result in a shorter application time and decreased costs. Overall, steam shows promise as a fumigant, especially in large buffer areas where costs and r eturns have been shown in study plots to be comparable to chemical fumigants. However, because steam is an energy

intensive technology, the price of fuel (usually propane) greatly influences the economic feasibility. Other f

actors impacting the cost of s team include machine cost ( e.g., machine

manufacturer's cost s , repair costs, hours of life, and hectares treated per year) and operating costs ( e.g., liters per treated hectare, labor hours and cost per hour, and transportation of

steam machine ). F or smal l areas to be treated, transportation costs for steam application may be prohibitive. In addition, steam applicators have not been approved for commercial use by

the U

. S

. Occupational Safety and Health Administration (OSHA). At present second

generation prototype applicator s are under development

.

3. IS THE USE COVERED B Y A CERTIFICATION ST ANDARD?

There is no certification standard for strawberry fruit production.USA CUN16 SOIL Strawberry Fruit Open Field Page 5 of 11

4. PROPORTION OF CROP USING METHYL BROMIDE

T ABLE 2. P ROPORTION OF T OTAL H ECTARES W HE RE M ETHYL B ROMIDE I S A C RITICAL N EED

R EGION WHERE METHYL

BROMIDE USE IS REQUE STED T OTAL CROP

AREA 1 ( HA ) A REA NOMINATED FOR

METHYL BROMIDE USE

IN 201 6 (H A ) P ROPORTION OF TOTAL

CROP AREA TO BE

TREATED WITH CUE

METHYL BROMIDE (%)

California 15, 240 1 36 2 9

. 0

1 California Strawberry Commission 2013 Survey showed a total production of 40,192 acres (16,265 ha)

, less organic production acres (2532 acres; 1,025 ha) ( http://www.calstrawberry.com/com mission/asurvey.asp )

5. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDI CATE

THE REASON WHY METHY L BROMIDE IS NOT USE D IN THE OTHER AREA, AND

IDENTIFY WHAT ALTERN ATIVE STRATEGIES ARE USED TO CONTROL THE

TARGET PATHOGENS AND WEEDS WITHOUT METHYL BROMIDE THERE

.

Methyl bromide is not used on the majority of strawberry production fields (Table 2) . Alternatives

are e ffective and currently used 1) on soils where alternatives have been effective and/or where soils

have below

- threshold pathogen populations so that disease impact on fruit production is low

, 2 ) on soils where township caps do not restrict 1,3

- D use , and 3 ) on soils where broadcast 100% chloropicrin has been effective

.

Regulations in California Currently all of the county agricultural commissions where strawberry fruit is grown now have a process in place to allow the use of chloropicrin at r ates of up to 392 kg/ha (350 lb/ acre). The specific location, topography, and proximity to sensitive sites will imp act the granting of a permit.

The use of up to 392 kg per ha of chloropicrin can provide enhanced efficacy where plant pathogens

are difficult to control. The California Department of Pesticide Regulation (Cal DPR) is currently reviewing the registration of chloropicrin and 1,3

- D

. Cal DPR revisions of the regulations on the use of chloropicrin and 1,3

- D (e.g. buffers, reentry intervals, tarps, use rate, etc.) could occur before

201 6 . In addition, a review of 1,3

- D could lead to changes in how the 1,3

- D township caps are

calculated.

6. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COV ER

AT LEAST PART OF THE CROP THAT HAS REQUES TED USE OF METHYL

BROMIDE? WHAT CHANGE S WOULD BE NECESSARY TO ENABLE THIS?

For the remainder of strawberry produc tion where methyl bromide is considered critical, t he final

transition from methyl bromide will be effective as of the 2017 use

- season. For specifics regarding

the transition from methyl bromide, p lease see Appendix I

— Transition Plan for California Strawberry Fruit Production

.USA CUN16 SOIL Strawberry Fruit Open Field Page 6 of 11

7

. ECONOMIC FEASIBILITY OF ALTERNATIVES

N et revenue is calculated here as gross revenue minus operating costs. This calculation is known as a partial budget analysis and is a good measure to describe the direct losses of income that may be suffered by the users. The net revenue presented here does not represent net income to the users. Net income, which is an indication of the profitability of an operation of an enterprise, is gross revenue minus the sum of operating and fixed costs. Net income should be smaller than the net revenue measured in this study. Fixed costs were not included because they are often difficult to

determine and verify.

Summary of Economic Feasibility

The critical need for methyl bromide is for strawberry production land where 1 ) a transition period is needed for the use of broadcast 100% chloropicrin, especially to control Macrophomina and

Fusarium and 2) 1,3

- D use is limited by township caps

. The economic analysis of strawberry fruit

pro duction compared data on yields, crop prices, revenues and costs using methyl bromide and using alternative pest control regimens in order to estimate the loss of methyl bromide availability. T he primary fumigant alternative s are 1,3

- D/ c hloropicrin (225/123 lb/acre; 252/138 kg/ha) (e.g., Pic

- Clor
60, 33 gal / acre ; 310 l/ha ) or c hlor o picrin at 300

- 350 lb per acre ( 336

- 392 kg/ha)

. Pic

- Clor 80 is not registered for use in the United States.

The economic analys i s (see Table 3 ) indicate s fumigant

- treated soils can result in gains or losses to net revenues that range from

- 29 % (with drip Pic

- Clor 60) to 2 % (with 100% broadcast chloropicrin), based on the cost of the individual fumigant and estimated yield loss. For the 2012

- 13 growing sea son , chloropicrin has been approved for use in all production areas at a maximum rate of 350 lb per acre (392 kg per ha), although county permits are subject to change. Technical and regulatory issues reduce the feasibility of 1,3

- D use for a portion of s trawberry production fields in

California.

The economic factors that support the critical need for methyl bromide for nominated areas are 1)

where additional time is needed to transition to high rates (393 kg/ha) of straight chloropicrin, 2) regulations restrict the use of 1,3

- D

, 3 ) where increased production costs are incurred for alternatives, 4 ) where there are additional pest control requirements due to the lower efficacy of alternatives, and/or 5 ) where there are resulting shifts in other production or harvesting practices and yield losses. The feasibility of alternatives as compared to methyl bromide is dependent on maintaining yield and fruit quality at a competitive cost.

Measures Used to Quantify the Impacts of a Loss of Methyl Br omide Crop budgets were to determine the likely economic impact if methyl bromide were unavailable. Various measures were used to quantify the impacts, including the following:

(1) Loss per Hectare. For crops, this measure is based on yield impact and closely tied to income. It is relatively easy to measure, but may be difficult to interpret in isolation.

(2) Loss /Gain per Kilogram of Methyl Bromide

. This measure indicates the value of methyl bromide to crop production and is calculated by multiplyin g the loss/gain of methyl bromide by theUSA CUN16 SOIL Strawberry Fruit Open Field Page 7 of 11

number of fumigation cycles (i.e., one) and then dividing the quantity by the number of kilograms of methyl bromide used to treat a hectare.

(3) Loss as a Percentage of Gross Revenue. This measure has the advantag e that gross revenues are usually easy to measure, at least over some unit, e.g. , a hectare of land or a storage operation. However, high

- value commodities or crops may provide high revenues, but may also entail high costs. Losses of even a small percent age of gross revenues could have important impacts on the profitability of the activity.

(4) Loss as a Percentage of Net Operating Revenue . Net cash revenues are defined as gross revenues minus operating costs. This is a very good indicator of the direc t losses of income that may be suffered by the owners or operators of an enterprise. However, operating costs can often be difficult to measure and verify.

(5) Operating Profit Margin . Operating profit margin is defined as net operating revenue divided by gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be difficult to measure and

fixed costs even more difficult

. However, fixed costs are considered to be identical for all alternative scenarios, therefore, fixed costs were not included in the analysis.

These measures represent different ways to assess the economic feasibility of methyl bromide alternatives for strawberry fresh fruit producers. Because producers (suppliers) represent an integral part of any definition of a market, the threshold of signif icant market disruption is met if there is a significant impact on commodity suppliers using methyl bromide. These economic measures provide the basis for making that determination.

The analysis presented in Table 3 compares the costs of three different fumigation options and a steam treatment to the cost of treating with methyl bromide . The analysis compared the impacts

between the baseline methyl bromide and the alternatives which include: steam, broadcast chloropicrin at 300 pounds per acre

, broadcas t 1,3

- D plus chloropicrin (Pic

- Clor 60 (59/39 ) )

, and drip

- applied 1,3

- D plus chloropicrin (Pic

- Clor 60 (56/37) )

. Costs consist of all operating costs including labor, equipment , application, and material. Y ield losses may be 5 % for soils treated with

Pic

- Clor 60 drip or broadcast applications based on field observations

, due to the increased prevalence of disease

. Where township caps limit the use of 1,3

- D

, losses could be as high as 13%, according to the C alifornia S trawberry C ommission

.

Steam is a promising option and California researchers are experimenting with mobile and stationary steam applicators ( Shennan et al., 2013; Fennimore et al., 2013; Klonsky et al., 2013)

. T he analysis presented below ( Table 3 ) is based on small plot production ( 4 ha or less) and

, therefore

, may not be

an accurate scenario for larger commercial

- scale production

. The cost of fuel is the primary driver

for the cost of s team. Current diesel prices in California average around $4. 2 5 per gallon as quoted by Pricelock.c om on December 3

, 201 3 ( www.pricelock.com/index )

.USA CUN16 SOIL Strawberry Fruit Open Field Page 8 of 11

TABLE 3

. ECONOMIC IMPACTS OF METHYL BROMIDE + CHLOROPICRIN

, STEAM

, CHLOROPICRIN

, AND BROADCAST AND DRIP

- APPLIED 1,3

- D + CHLOROPICRIN

**Note that the measures in the tables above must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. Values may not calculate exactly due to rounding during conversion from $/lb to $/kg.

*** B ased on small plot production (4 ha or less) ; may not be an accurate scenario for larger commercial

- scale production. CALIFORNIA FRESH

STRAWBERRY M ETHYL
B ROMIDE + PIC

50/50 STEAM *** C HLOROPICRIN @300 LB /A

B ROADCAST P IC

- C LOR

60 GPA

B ROADCAST P IC

- C LOR

60 EC 25

GPA D RIP

P RODUCTION L OSS (%) 0% 0% 0% 5 % 5%

P RODUCTION PER H ECTARE ( KG / HA ) 50,091 50,091 50,091 47,586 47,586

**P RICE PER U NIT ( US $) $3.17 $3.17 $3.17 $3.17 $3.17

= G ROSS R EVENUE PER
H ECTARE ( US $) $159,021 $159,021 $ 159,021 $ 151,070 $ 151,070

- O PERATING C OSTS PER
H ECTARE ( US $)** $132, 562 $ 132,513 $131, 142 $ 131,383 $ 127,818

= N ET R EVENUE PER
H ECTARE ( US $) $26

, 459 $ 26,508 $26 ,879 $ 19,687 $23,252

*L OSS M EASURES *

1. L OSS /G AIN PER H ECTARE ( US $) $0 $ 49 $ 420 $ ( 6,822 ) $( 3,207 )

2. L OSS /G AIN PER K ILOGRAM

OF M ETHYL B ROMIDE ( US $) $0 $ 0.29 $ 2.47 $ (4 0.12 ) $ ( 18.86 )

3. L OSS /G AIN AS A
P ERCENTAGE OF G ROSS
R EVENUE (%) 0% 0 % 0%

- 4 %

- 2%

4. L OSS /G AIN AS A
P ERCENTAGE OF N ET
O PERATING R EVENUE (%) 0% 0 % 2 %

- 2 6 %

- 12 %

5. O PERATING P ROFIT
M ARGIN (%) 17 % 17 % 17 % 13 % 15 %USA CUN16 SOIL Strawberry Fruit Open Field Page 9 of 11

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

The USG has applied a transition rate to the alternatives , which is reflected in the nomination

amount and detailed in Table 4 . The amount requested reflects time to transition to straight chloropicrin at the recently approved high

- use rates, adjustments for areas with high pest pressure,
1,3

- D/c hloropicrin (TeloneTM) township caps, and local regulatory restriction s on the use of chloropicrin.

TABLE 4

. N OMINATION A MOUNT :USA CUN16 SOIL Strawberry Fruit Open Field Page 10 of 11

9. CITATIONS

Daugovish, O., Gordon, T.

, Koike, S., Subbarao, K. 201 3 a

. Fusarium oxysporum and Macroph o mina phaseolina persistence in fumigated soil and management approaches

. International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (201 3 ). http://mbao.org/2013/Proceedings/66DaugovishOPathogen%20persistence.pdf

Daugovish, O., Fennimore, S., Gordon, T., Koike, S., Muramoto, J., Shennan, and C., Subbarao, K.

201 3 b . Non

- fumigant treatments for management of Fusarium oxysporum and Macrophomina phaseolina on strawberry cultivar San Andreas. International Research Conference on Methyl

Bromide Alternatives and Emissions Reductions (201 3 ). http://mbao.org/2013/Proceedings/18DaugovishO%20treatmentssummary.pdf

Fennimore, S. Miller, T., Goodhue, R., Dorn, N., Broome, J., Muramoto, J., Shennan, C. and Martin,

F. 201 3

. Evaluation of an automatic steam applicator in strawberry : 2012

- 13 results . Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (201 3 ). http://mbao.org/2013/Proceedings/11FennimoreS.pdf

Gordon, T. R., Koike, S. T., Daugovish, O., Shaw, D. V., and Larson, K. D. 2011. A comprehensive approach to management of wilt diseases caused by Fusarium oxysporum and Verticil lium

dahlia . California Strawberry Commission Annual Production Research Report. http://www.calstrawberry.com/fileData/docs/Gordon_2010_11_Mac_Fus.pdf

Koike, S. and Bolda , M. 2013. Charcoal rot of strawberry: Increasing problem in California. University of California Extension. http://ucanr.edu/blogs/blogcore/postdetail.cfm?postnum=11043

Klonsky, K.

, Goodhue, R., Xu, Y., Fennimore, S., Shennan, C., and Muramoto, J. 201 3 . Economic feasibility of non

- fumigant systems in CA strawberry buffer zones

. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (201 3 ). http://mbao.org/2013/Proceedings/17KlonskyK.pdf

Shennan, C., Muramoto, J., Baird, G., Koike, S., Bolda, M., and Mazzola, M. 201 3 . Optimizing

anaerobic soil disinfestation for soilborne disease control

. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (201 3 ). http://mbao.org/2013/Proceedings/13ShennanC.pdfUSA CUN16 SOIL Strawberry Fruit Open Field Page 11 of 11

APPENDIX I

.

Trans ition Plan for California Strawberry Fruit Production

Th e transition from methyl bromide (Appendix Table 1) has been undertaken as research and experience has led to the effective use of alternative methods of pest management. C ounty agricultural commissioners have been observing the effect of broadcast applications of high rates of chloropicrin o n large tracts of land that ha ve transitioned from methyl bromide . The shift of production away from sensitive sites and the necessity to incorporate any new restrictions for chloropicrin currently being considered by Cal DPR require the optimization of practices and techniques that will ensure the long

- term efficacy of broadcast applications of straight chloropicrin

to manage the soilbo rne disease issues in California.

Appendix Table 1. Transition from methyl bromide use ( 2012 to 2017 ) for California

s trawberry f

ruit

. CUE Requests, Transition ed,

Nominated & Granted Use Season

2012 2013 2014 2015 2016 2017

MB nominated (kg) 7 49,0 5 5 531,737 415,067 373,660 231,540 0

Hectares nominated 4,4 06 4,406 2,442 2,198 1,362 0

MB granted (kg) 673,085 461,186 415,067 373,660

--- ---
Hectares granted 4,421 2,713 2,442 2,198

--- ---