USG Preplant Replies Spring 2009 Page 1

MBTOC Questions Concerning USA CUNs, Soils UNITED STATES

TABLE OF CONTENTS

USA GENERAL

................................ ................................ ................................ ............................. 1

USA CUCURBITS

– FIELD

................................ ................................ ................................ .......... 6

USA EGGPLANT

- FIELD

................................ ................................ ................................ ............ 7 USA FRUIT, NUT, AND FLOWER NURSERIES

................................ ................................ ....... 8

USA FOREST NURSERY

................................ ................................ ................................ ............. 9

USA ORCHARD REPLANT

................................ ................................ ................................ ....... 12

USA ORNAMENTALS

................................ ................................ ................................ ............... 18

USA STRAWBERRY FRUIT

- F IELD

................................ ................................ ........................ 20

USA STRAWBERRY RUNNERS

................................ ................................ .............................. 23

US SWEET POTATO TRANSPLANTS

................................ ................................ ..................... 27

USA TOMATOES

- FIELD

................................ ................................ ................................ ......... 29 APPENDIX A (Strawberry Fruit)

................................ ................................ ................................ . 31 APPENDIX B (Strawberry Fruit)

................................ ................................ ................................ . 33 APPENDIX C (Strawberry Fruit)

................................ ................................ ................................ . 36 APPENDIX D (References)

................................ ................................ ................................ ......... 46

US A GENERAL

I, In 2006 the Party stated that"... While many field re search studies in the eastern US indicate that use of LPBF in conjunction with lower rates of methyl bromide can control a number of pests...we have been unable to find information from large scale field studies, efficacy data on some of the key pests, and data on pest control and yield for the second crop on the same plastic mulch (as part of the double cropping system). Without this addition information the technical feasibility is still in question. The US is unable to estimate the total economic impact of this type of fumigation practice without this information. In terms of field emissions there are several laboratory and small scale field

studies indicates t h at fumigant emissions can be substantially reduced with the use of LPBF's. However, the few la rge scale field studies that are available do not demonstrate reductions in emissions with the use of LPBF".

It is two years since these studies commenced, and MBTOC understands medium and/or large scale field studies were underway in California directed by UC's Dr. Ajwa under a California Strawberry Commission research program. Can the Party please report progress on these studies and relevance to the recent nominations and the above

statement?

USG Response

None of these papers addresses durability of h igh barrier (= low permeability) films, so the articles by Ajwa do not directly answer MBTOC question. A search of  ̳Current Contents‘ does

not reveal any other papers by Ajwa in 2008 or 2009. Culpepper et al‘s work on VIF and itsUSG Preplant Replies Spring 2009 Page 2

durability seem to still be relevant. Charles Hall and Culpepper also stated the following in a

recent e

- mail: ―...these mulches are coming under much [grower and extension service] scrutiny because of their short life span and extremely high cost.‖

Ajwa H., J. Hunzie, S. Shem

- To v, D. Sullivan, R. Segawa, P. Wofford, S. Gao, and D. Shatley. 2008. Fumigant Emissions Reduction by Using Low Permeability Film and Thiosulfate

Water Seal. Available online at: http://www.mbao.org/

Ajwa. H. 2008 Testing Film Permeability to Fumigants Under Laboratory and Field Conditions.

Available online at: http://www.mbao.org/

Khan A., W. Ntow, and H. Ajwa. 2008. Behavior of Methyl Isothiocyanate in Soil After Applicati on of Metam Sodium and Metam Potassium. Available online at: http://www.mbao.org/

1. California)! DPR data show r s substantial increase in consumption of metham potassium for use in California. In 2006, approximatel y 3 million pounds were used. Could the Party please clarify for which crops this product has been used? Could you also please advise whether the adoption of metham potassium for a number of crops in California was taken into account during assessment for CUNs, if so for which crops and if not why?

USG Response

MBTOC is correct that metam

- potassium usage is up in California when considering all use sites (see Table 1) and only CUE use sites (see Table 2). In discussions with California Department

of Pest icide Regulation (Cal DPR) is appears that some users do not accurately describe the product used as metam

- sodium versus metam

- potassium. Consequently, the usage of metam

sodium versus metam

- potassium may not be accurately tracked. In Table 2 the amount of metam both types (K + Na) is a more consistent amount from year to year than are the metam

- sodium or

metam

- potassium amounts. When individual CUE crops are evaluated it appears that some of

the increased metam

- potassium usage is due to replacing metam

- sodium with metam

- potassium.

Table 1. California Fumigant Usage, All Sites Including Soil and Postharvest ( kg )

Active Ingredient 2003 2004 2005 2006 2007

CHLOROPICRIN 2,236,983 2,332,728 2,211,340 2,278,549 2,487,001

METAM

- POTASIUM 867,911 4 05,960 905,309 1,454,109 1,719,252

METAM

- SODIUM 6,726,807 6,668,865 5,892,174 5,158,518 4,414,444 METAM (K + Na) 7,594,718 7,074,825 6,797,483 6,612,628 6,133,696

METHYL BROMIDE 3,355,722 3,232,870 2,955,232 2,959,937 2,863,232

Gr and Total 13,187,423 12,640,423 11,964,055 11,851,114 11,483,930

Note: U sage of fumigants in California from 2003

- 2007. Fields include kilograms of active ingredient applied for both postharvest and soil sites. Data from California Department of Pe sticide Regulation

available online at http://calpip.cdpr.ca.gov/cfdocs/calpip/prod/main.cfmData

Table 2. Soil Fumigant Usage

- CUE Crop Sites Only (kg)

Active Ingredient 2003 20 04 2005 2006 2007

CHLOROPICRIN 1,723,173 1,725,506 1,679,155 1,733,960 1,849,674USG Preplant Replies Spring 2009 Page 3

METAM

- POTASIUM 14,752 44,687 10,990 131,051 139,563

METAM

- SODIUM 406,556 423,337 424,841 261,954 252,897 METAM (K + Na) 421,309 468,024 435,832 393, 004 392,460

METHYL BROMIDE 2,502,480 2,297,553 2,143,612 2,115,985 1,848,784

Grand Total 4,646,961 4,491,082 4,258,598 4,242,949 4,090,918

Note: U sage of fumigants in California from 2003

- 2007. Fields include kilograms of active ingredient applied for potential CUE crops, no unknown Cal DPR sites or units treated categories for commodity or

structural uses. Data from California Department of Pesticide Regulation available online at http://calpip.cdpr.ca.gov/cfdocs/calpip/prod/main.cfmData

2. Could you also provide the comparative data used to support, assessments and also the references used to support the CUN?

USG Response

Reference s for each individual Critical U se Nomination are found in the back of each document

. Consolidated references can be found in Appendix D.

3. Please provide an update of the timelines and progress towards registration of MI in California?

USG Response

The California Department of P esticide Regulation has stated that they will complete their

review of the iodomethane (Midas ®) registration by this summer. The USG will apprise MBTOC of additional developments when the occur

.

4. Also, in many nominations there is data which shows e conomic analysis for MI and
1,3D+Pic+ metham (3 way) to be a suitable alternative to MB. Could you please provide the assumptions behind these comparisons (i e the application rate per hectare, the product costs and other variable costs used to calculate the se outcomes)? We assume a similar cost structure was used for several nominations, if not please show the different cost structures for each commodity.

USG Response

The MBTOC correctly points out that MI and the Georgia 3

- Way are both technical and

econo mic alternatives in certain circumstances. The assumptions behind the analysis is provided below. For the economic analysis, similar cost structures were used.

The application rate per hectare for the Georgia 3

- Way is chloropicrin at 1 01 kg/ha broadcast

, metam sodium at 215 kg/ha broadcast and 1,3

- D at 11 5 kg/ha broadcast all under VIF or metallized (high barrier) tarps

. The iodomethane + chloropicrin rate of the 50:50 formulation is 80+80 pounds using highly retentive film (HRF).

Georgia Three Way A pplication Rate

Chemical Rate in Treated Band Broadcast Rate (60% of area treated)USG Preplant Replies Spring 2009 Page 4

Chloropicrin 168 kg/ha (150 lb/acre) 101 kg/ha

Metam

- sodium 358 kg/ha (320 lb/acre) 215 kg/ha 1,3

- dichloropropene 191 kg/ha (171 lb/acre) 115 kg/ha

Fumigant costs used in the analysis are:

Methyl Bromide: $ 4.00 per lb Chloropicrin: $ 3.00 per lb

MB/Pic 50:50 mix $ 3.50 per lb

Iodomethane $ 14.00 per lb

MeI/Pic 50:50 mix $ 8.00 per lb Telone (1

- 3,D): $ 1.25 per lb

Metam Sodium: $ 1.00 per lb

Tarp P rices: $500 per acre for VIF or similar High Barrier (low permeability) Films and $300 per

acre for Standard Films

Costs were also adjusted for the number of ―passes‖ , for example the  ̳Georgia Three Way‘ requires two passes, the first being two fumigant s and the second being the remaining fumigant and the tarp, while MB and Pic can be applied with a single pass. Consequently, the application cost for the labor component for the  ̳Georgia Three Way‘ is twice that for an MB application.

5. No question # 5 was provided in our document.

6. In the new BUNNIs, how were the transition levels from 2010 baseline adjusted value

calculated?

USG Response

The transition is determined by conducting a Delphi analysis. Two parameters are determined at

this time: the maximum amount of acreage that can transition given the key pests, regulatory issues, other constraints such as topography, and, over what time period this transition can take place. Both biologists and economist have a role in this determination so t hat both technical and economic feasibility are properly considered. The outcome of the process is both an upper bound and a time profile over which the adjustment occur.

This analysis is complex and considers all relevant factors. In determining the pa rameters the biologists and economists make use of all information available, both open source and confidential. Some examples of information used include: price of methyl bromide and anticipated future price of methyl bromide, prices of alternatives and projections of future prices, anticipated market shares of alternatives, current levels of use of alternatives, etc.

The transition calculation integrates a progressive series of adjustments based on differing

availabilities of alternatives and other cons traints, if known. The complexity of the process makes it impossible to use the Party

- determined amount as a starting point although theUSG Preplant Replies Spring 2009 Page 5

incorporation of the transition amount always results in a request that is below the previous total US request reflect ing the growing uptake of alternatives until the point where a technical or

economic maximum is reached

.

When a new alternative become s available, or when new information from full

- scale commercial trials become available, a new Delphi process is conducte d to determine whether this new alternative can be used in circumstances where no alternative had previously been available and thus whether there is a change in the maximum amount of transition that can occur. At this time

there is also an assessment of whether the previously determined time line is still relevant or must be altered in light of the new information.

7. The use of resistant varieties and rootstocks is a common non chemical alternative all over the world particularly for nematodes affecti ng the following crops (tomato, cucurbits, eggplants, pepper, ornamental, fruit trees...).Could a complete list of nematodes affecting the crops above for which MB is required please be provided?

USG Response

For the crops listed in the question, the fol lowing table lists the key nematode species for which MB is required. This information is compiled from CUE requests for 2007 and 2008.

Crop Nematode species Notes

Fruit trees Helicotylenchus dihystera (spiral), Tylenchus mexicanus (Tylenchus), Tylencho rhynchus spp. (stunt), Trichodorus spp. (stubby root) Nematodes listed are for California stone fruit, the only tree fruit included in

this sector‘s 2008

nomination

Ornamentals (includes California, Florida, New York, various ornamentals) Meloidogyne hap la, Meloidogyne incognita, Pratylenchus spp., Ditylenchus spp. Due to the diversity of ornamental plants covered in the sector, many nematode species are target pests. Therefore genera are

identified here. Eggplants Florida: root

- knot nematodes (Meloidog yne spp). Georgia: (Meloidogyne incognita; Pratylenchus spp) There are many Meloidogyne species

distributed across North American vegetable producing regions. According to Eisenback and Triantaphyllou (1991), the species of major economic importance are M. javanica, M. arenaria, M. incognita, Cucurbits Root knot n ematodes (Meloidogyne spp) Pepper Root knot nematodes (Meloidogyne spp)

Tomato Root knot nematodesUSG Preplant Replies Spring 2009 Page 6 (Meloidogyne spp) M. hapla. Several other species can also attain economic importance on occasion. These species are likely targets of MB application in all the regions covered by the vegetable

sector nominations.

US A CUCURBITS

– FIELD

a. In the 2007 round of MBTOC questions, the Party stated that "... the USG has been Informed by The Flori da Fruit and Vegetable Association that individual vegetable growers are trying metalize d films, sometimes in combination with 50/50 methyl bromide mixtures. Many cucurbit growers in Georgia have also reported using 53 % methyl bromide: 47 % chloropicrin m ixtures recently. However, they have apparently not yet begun testing metalized films. Mr. Terrey Kel iey, of the University of Georgia, provided, this information. He also reported th at "VIF is still virtually unavailable in the U.S. and

the cost continues to be extremely high as compared to other films". Research on combinations of methyl bromide alternatives and metaliz ed films is currently underway in south eastern US cucurbit crops (Dr. S. Culpeper, University of Georgia). In addition,

similar research including low permeability films is ongoing in other crops, including strawberries and tomatoes (Dr. Frank Louws, North Carolina State Univ., personal communication). It is possible that results from that work may also be applicable to cucurbit crops."

US G Response

See response to b. below.

b. Can the Party please report updated progress in these regions with the use of LPDF films to reduce emissions in cucurbit crops, besides de 'UGA 3 way"?

USG Response

USG assumes that items  ̳a‘ and  ̳b‘ above ar e part of the same question, and will respond to both together . To quote from a recent update [received March 11, 2009] from the Georgia CUE applicants and Dr. Stanley Culpepper of the University of Georgia: ― Alternatives to the 3

- WAY include approximately 20 to 30% of the acreage treated with MB and about 20% of the acreage

treated with MIDAS [iodomethane] . High barrier mulches have been used with all MIDAS applications and on about 80% of the MB applications. These high barrier mulches are adopted

beca use they allow growers to reduce the rate of MB or MIDAS by approximately 40%.

H owever, these mulches are coming under much scrutiny because of their short life span and extremely high cost ‖ (Hall 2009). Based on past discussion with regional CUE applicant s and past CUE reviews, the USG believes that the above description of high barrier tarp use probably applies to cucurbit production in the rest of the southeastern US as well.USG Preplant Replies Spring 2009 Page 7

c. MBTOC notes that recent publications are available on grafting as a suc cessful alternative for cucurbits, particularly in Georgia. What is the scope for adoption of this alternative in the near future?

USG Response

While there has been some progress in research to identify rootstock that can be grafted to

commercial cucurbi t varieties to enhance disease resistance, there remain significant obstacles to commercial adoption of grafting even for these target pests, in the US. Moreover, there are no commercially feasible cucurbit rootstocks that confer resistance to weeds to the extent that grafting could be considered a feasible methyl bromide alternative for managing weeds such as nutsedge. According to Georgia extension and researchers ― Currently grafting has had absolutely no impact on our ability to control weeds and this is not expected to change ‖ (Hall 2009).

Dr. T. Kelley of the University of Georgia offers the following current assessment: ―As far as the grafting work, we do get exceptional resistance to Fusarium wilt when a commercial scion is grafted onto a resistant r ootstock. However... [a major] drawback to grafted transplants in watermelons or any other crop is the cost. In watermelons we have calculated the costs to be around US$1.00 per transplant. This is compared to a cost of US$0.25 per transplant for

traditional seedlings. This has the potential to raise the cost of production per acre on watermelons by almost US$1,200.00 per acre. Since net profit on watermelons is barely US$1,500.00 per acre with traditional production means, using grafted transplants becomes a

cost

- prohibitive alternative to growers even for control of Fusarium wilt‖ (Kelley 2009).

The USG further emphasizes that Fusarium wilt is only one of several critical pests targeted by methyl bromide applications in cucurbits. As stated earlier, graftin g does not yet offer a technically and economically feasible control option for nutsedges, other weed pests, or fungal

diseases such as Phytophthora capsici

.

Sources cited

Eisenback, J. D. & Triantaphyllou, H. H. 1991 Root

- knot Nematodes: Meloidogyne spe cies and races. In: Manual of Agricultural Nematology, W. R. Nickle. (Ed). Marcel Dekker, New York. pp 281

- 286.

Hall, C. 2009. Personal e

- mail communication to USEPA, March 11, 2009. Based on input from several regional growers and University of Georgia extension and research staff.

Kelley, T. 2009. University of Georgia extension horticulturist. Personal e

- mail communication to USEPA, March 13, 2009.

US A EGGPLANT

- FIELD

I. The first paragraph on page i 1 states:USG Preplant Replies Spring 2009 Page 8

In Georgia and Florida, using t he Georgia 3

- Way on spring plantings is believed to be a technically (and thus economically) feasible alternative to methyl bromide, although some limitations exist'. MBTOC economists disagree with this statement. Technical feasibility is a necessary but n ot sufficient condition to establish economic feasibility.

Was it your intent to assert that alternatives that are economically feasible are necessarily technically feasible? Similar statements appear in other CUNs.

USG Response

This statement was inco rrect and MBTOC economists are correct. This statement should read:

― In Georgia and Florida, using the Georgia 3

- Way on spring plantings is believed to be a technically and economically feasible alternative to methyl bromide, although some limitations

exi st ‖. Where the statement as described above occurs in other nominations it should be corrected to remove the ―thus‖ and parentheses. USG appreciates having this called to our

attention.

The same paragraph refers to gross revenue in tables 4 and 5. Pleas e confirm that this should be tables 3 and 4. The same sentence in the paragraph says "loss of gross revenue using Georgia 3

- Way is negligible for Florida in comparison to methyl bromide, while gains in gross revenue are expected in Georgia." These state ments are not consistent with the entries in the tables 3 and 4 that show no change in gross revenues. Confirm that you intend to refer to net revenue. Several CUNs appear to confuse gross revenue and net

revenue.

USG Response

MBTOC is correct. The tabl e reference should be to tables 3 and 4 and the loss is to net revenue not gross revenue. The corrected section should read as follows:

Referring to Tables 3 and 4, the loss of net revenue using the Georgia 3

- Way is negligible for Florida in comparison t o methyl bromide, while gains in net revenue are expected in Georgia. Unlike spring plantings, however, yield losses are expected in fall plantings, with studies in Georgia‘s application showing 50% yield losses. The Georgia

3

- Way also cannot be used on eg gplants that are grown in karst soils since it contains
1,3

- D. Therefore, for fall plantings and areas with karst soils, the use of methyl bromide is critical to Georgia‘s and Florida‘s eggplant production. Note that data describing Georgia eggplant produc tion is based on double cropping production practices.

US A FRUIT, NUT, AND FLOWER NURSERIES

1. Rose propagators everywhere in the world are moving towards substrate systems for all rose plant types (garden roses, cut flower roses, green house, open field even rose trees), The initial investment is costly, but the production cycle is much shortened, grafting i s easier and a much higher number of plants can be produced per unit area. Are there anyUSG Preplant Replies Spring 2009 Page 9

studies or trials being conducted in this respect? MBTO C knows of at least one rose plant grower who has used containerized production for a portion of the crop. Could this be a "viable option for at least for part of the nomination and if not, what prevents other growers from adopting them?

USG Response

Exp erts from the Garden Rose Council commented (through J. Wells; personal communication

email 3

- 17

- 09):

A significant portion of garden rose production has moved to substrate systems as containerized product. Those plants, however, are not replacements for all garden rose products. Container grown garden roses could not economically be grown to the same grade standard or level of maturity as field grown garden roses. Current estimates put the number of field grown garden roses at over 30 million plants. These plants are grown with

an in

- row spacing of six to seven inches [15

- 18 cm] . The plants are marketed based on ANLA grade standards with the vast majority of the overall production sold and shipped as bare root plants.

Industry members are constantl y seeking ways to reduce growing and shipping costs. The

United States does not concur that more plants of a comparable grade could be produced per unit area in containers relative to field production. The statement that the "production cycle is much sh ortened" by producing in containers is also erroneous. It is true that the growing cycle for own

- root varieties is shorter than that of budded varieties; however, the reduced production cycle has nothing to do with containerized versus in

- ground productio n. In fact, it is the experience of the garden rose industry that limiting the area available for root development, as is the case in containerized production, slows the development of garden rose plants. Garden Rose Council member companies have found

t hat many economically important varieties cannot be produced on their own roots. The garden rose industry continues to do research on reducing production cycle time and on alternate methods of production through both in

- house research and in cooperation w ith

USDA/ARS researchers.

USA F OREST NURSERY

1. Can the Party disaggregate the areas to be treated by State as different rules seem to be applied by individual States? If disaggregation to the state level is not possible, can the Party at least disaggre gate into those areas where iodomethane is registered and those areas where it is not registered?

USG Response

Iodomethane is registered and labeled for use in ―nurseries (including strawberries, stone fruits, tree nuts and conifer trees)‖ in all of the states listed below, except Washington. States where nominated forest seedling nurseries are located are:USG Preplant Replies Spring 2009 Page 10

Southern States : Alabama, Arkansas, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia

Western States : Oregon, Washington

Eastern States : Illinois, Indiana, Kentucky, Maryland, Michigan, Missouri, New Jersey, Ohio, Pennsylvania, West Virginia, and Wisconsin

However, the current iodomethane (Midas ®) does not allow its use for deciduous tree nurser ies.

2. Does the use of MB covered by a certification standard (p.5 (3)) specifically mandate the use of MB?

USG Response

Certification requirements are regulated by state authorities, not by the federal government. MB may not be specified as ―mandat ed‖, although because many potential alternatives to MB have not been proven of sufficient efficacy to meet pest

- free standards, MB in many cases is considered an effective treatment that satisfies certification requirements. Treatments without the long h istory of use in the nursery industry as MB do not have the consistency of effectiveness to warrant equal status. Nursery researchers are currently trying to identify alternative treatments that may be used, but variable soil conditions complicates the br oad adoption of any replacement of methyl bromide, which has shown efficacy in wide ranging soil types, moisture, and depth.

3. Could the Part

y ' please indicate the area to be treated on the basis of mandatory use of MB and those requiring the crop to b e "apparently free from plant pests"?

USG Response

The requirement for pest

- free status of nursery seedlings requires numerous steps of production, including periodic fumigation to ensure healthy seedlings. The industry has used MB successfully for many years yet is doing its best to identify methods (including alternative chemicals) that can replace MB. After several years of field trials with alternative treatments, the industry generally is beginning to identify possible replacements for MB. As MBTO C is aware, alternative methods to achieve similar efficacy as MB are difficult to find due to stricter use requirements. One of the most tested chemicals, 1,3

- D, has important use restrictions including soil moisture thresholds and soil texture limitatio ns. It may be true that some nurseries can meet these criteria and successfully use alternatives but the nominated amount is for

circumstances where the alternatives can not be used . But any lack of regulatory specificity in methods to achieve pest

- free seedlings is designed to encourage integrated methods to achieve success. The Party maintains that the request for MB for this industry is reasonable and necessary whether state government agencies have or have not designated specific measures for

nursery seedling production.USG Preplant Replies Spring 2009 Page 11

4. Pages 5 and 10 of the CU N states the M idas label does not make clear if use is allowed for production of deciduous tree seedlings. It would seem that USEPA could answer this question for growers and MBTOC and remove any uncertain ty. Ca n iodomethane be used for the production of deciduous tree seedlings? What assumption regarding use on deciduous tree seedlings underlies the nominated amount of MB?

USG Response

Two items are relevant

— one is the registered use of iodomethane, the other is the support and confidence by the registrant (Arysta) for use of their product (MIDAS) on forest nursery crops. As mentioned above, iodomethane is registered and labeled for use in ―nurseries (including
strawberries, stone fruits, tree nuts and c onifer trees)‖ in all of the above

- listed states, except Washington. The registrant, however, appears not to be confident of the efficacy of the product for this nursery use, including conifer production. Yes, the product legally may be used on soils

gro wing conifers, and likely may be used on deciduous seedlings, but Arysta stated recently that

―w e are doing follow up work with the SE forest nurseries to look at formulations and rates

.. . Based on the work this year we can re

- visit the results in the Fal l. ‖ Research plots are only beginning to detail rate and efficacy information that might support the use of iodomethane for this industry. Regardless of the label use status, without support from the registrant and strong efficacy field trial data, no on e in the industry will risk their crop on a new product.

5. Can the Party please report on progress made with research and adoption of LPBF in those areas of the nomination where their use is permitted? What trials have been conducted with barrier films?

USG Response

The Party keep s apprised of research efforts for alternative methodologies to reduce or eliminate the use of methyl bromide. The USDA Forest Service assists the industry with technology transfer, technical assistance and training ( http://www.fs.fed.us/r8/foresthealth/programs/nursery/nursery.shtml )

. They also have been instrumental in acquiring information on alternatives to methyl bromide through technolo gy development projects and collaboration on research studies. In the recent CUN several references were cited that indicate long

- term ongoing research efforts. For example, the Southern Forest Nursery Management Cooperative has reported on research incl uding a large production trial that includes three fumigants and two types of tarps (Starkey, T., Enebak, S., and McCraw, D. 2007. Seedling quality and weed control with dazomet, methyl bromide and methyl iodide at the Glennville Regeneration Center 2005

- 2 006. Research Report 06

- 05, Southern Forest Nursery Management Coop., Auburn, AL. http://www.mbao.org/2006/06Proceedings/040StarkeyTMBAOMIMBrBasamidTES.pdf ). Some

of their conclusions were:

1. VIF tarping reduced significantly more fungal colonies than HD at the second sampling period.USG Preplant Replies Spring 2009 Page 12

2. There were no significant differences between HD and VIF related to fungal genera

recovered on selective media.

3. VIF tarping of MBr a t 150 lbs/acre produced seedlings similar to the 300 lbs/acre MBr under HD plastic.

4. There is still no operational method for using VIF in broadcast (flat tarp) system as used

in forest

- tree nurseries.

Many multi

- year studies are being conducted for fore st seedling nurseries and are only published as data are analyzed. For example, Weyerhaeuser Corp. has been involved for several years in testing various alternatives and the Party has cited some of these studies over the years in the CUN (for example, se e the CUN submitted in 2008). In the 2009 submission, the Party cited several personal communications with private and government forestry specialists detailing information on methyl bromide and alternatives that may have potential for the forest seedling nurseries. For example, Weyerhaeuser Corp. stated (Cheryl Talbert, Director of Forestry and Regeneration, Weyerhaeuser Corporation, Western Timberlands, personal communication. October 31, 2008):

Currently, we are an active participant in an ongoing USD A/ARS Oregon State University Nursery Coop study evaluating a range of treatments including MI

- Pic (VIF and HDPE), Metam

Sodium

- Pic (HDPE), DMDS

- Pic (HDPE) in comparison to MB

- Pic (HDPE) in three bare

- root
nurseries. Results from this trial are still awai ting completion of post

- treatment pathogen isolation; however, early observations suggest that MI

- Pic (50:50) at a 244 lbs/ac rate under VIF was less effective against buried Fusarium inoculum than MB

- Pic 67:33 (350 lbs/ac) and other

treatments in one of the three facilities. Perhaps the most important take

- away from the study to date has been the major issues that remain with gluing and instability of the VIF film throughout the study. Some 40% of the VIF film degraded within 14

- 20 Abcdefg8 days post

- fu migation period, compared to 0% for HDPE. While VIF may be academically interesting, for the time being the product is very difficult to obtain and the technology for operational use does not exist. We see at least 3

- 5 years before those issues are reso lved, perhaps longer, and the cost is currently prohibitive.

As the Party has described in the CUN, there is beginning to be progress toward gluing high barrier films, but research has not established this technology as fully available for commercial

use.

USA O RCHARD REPLANT

1. Can the Party provide MBTOC with figures on areas specifically under township caps in

this nomination?

USG Response

The use of 1,3

- dichlropropene (1,3

- D or Telone® ) is controlled by the California Management Plan: 1,3

- Dichloro propene updated in 2002. Under that plan townships are permitted to use up to 90,250 adjusted pounds 1,3

- D per township per year. Some townships have been granted permission to increase their single year usage of 180,500 adjusted pounds 1,3

- D per townshi p per year. Dow has proposed to the California Department of Pesticide Regulation to allow some townships to establish a baseline allocation of up to 270,750 adjusted pounds 1,3

- D per townshipUSG Preplant Replies Spring 2009 Page 13

per year. Between 2002 and 2005 there were eight counties (Fr esno, Imperial, Madera, Merced, Monterey, Stanislaus, Tulare, and Ventura) which exceeded 135,375 adjusted pounds 1,3

- D per township per year . Because individual townships can have 1X, 2X or even 2.5X allowances for
1,3

- D the USG has not attempted to trac k individual township exceedances. The USG has relied on discussions with Cal DPR and users to determine the estimated amount of methyl bromide

needed.

2. MBTOC notes research is being conducted on non

- chemical alternatives and IPM for managing rep lant disease (e.g. Browne etal, 2004, 2007,2008; Niczepyr and Rodnguez
Kabana, 2007; Tanner e tal, 2006). Could a successful 1PM program be developed for at least part of the nominated area, for example those areas where township caps prevent use of 1,3

- D?

USG Response

According to researchers involved in orchard replant studies, including those who were cited by MBTOC in the above question, a successful IPM program may be developed through strategies

identified as a result of research efforts. As Browne et al. (2008;

http://mbao.org/2008/Proceedings/012BrowneGmbao2008fin.pdf ) noted , ―Orchardists have shifted heavily
towards use of 1,3

- dichloropropene (1,3

- D) instead of MB for soil fumigation, but this transition does not appear to be stable in a regulato ry sense or completely effective in terms of resulting crop performance. Use of 1,3

- D is subject to township caps, and 1,3

- D alone has not controlled

PRD [Prunus replant disease] adequately. Despite these challenges, there are good prospects for completin g and stabilizing the industries‘ transition to MB alternatives using integrated chemical and cultural approaches.‖

IPM work integrating MB alternatives is in the research phase. Browne et al. (2008) stated the objectives of their multi

- season trials, 1) To develop and demonstrate optimized integrated pest management (IPM) strategies for control of almond and stone fr uit replant problems without MB; 2) Provide comprehensive economic assessments of alternative replant management strategies; 3) Educationa l outreach. Similar efforts are being carried

- out by numerous researchers. The CUN for the orchard replant sector is considered critical until research results are clear as to how to replace MB and maintain orchard health and productivity.

3. Please pr ovide full cites to studies referenced in the CU N but not included in the Citations. Page 9 refers to Carpenter et al. (2000) and Buchner et al. (2002). Page 12 refers to Buchner et al. (2001). Page 13 refers to Bruchner et al (2001). Is this a spelling problem? Page 14 refers to McKenry (1999) but the two references in the Citations for McKenry et al, are from 2006 and 2007. Table 7 lists Vasquez et al. (2004) as a source but Vasquez et al. is not found in the Citations.

USG ResponseUSG Preplant Replies Spring 2009 Page 14

Buchner, R., J. E dstrom, J. Hasey, W. Krueger, W. Olson, W. Reil, K. Klonsky and R. De

Moura. 2002. Sample costs to establish a walnut orchard and produce walnuts, Sacramento Valley, University of California Cooperative Extension, at http://www.agecon.ucdavis.edu/outreach/crop/cost

- studies/WalnutSac2002.pdf

Buchner R. J. Edstrom, W. Krueger, W. Olson, W. Reil, K. Klonsky, and R. De Moura. 2001. Sample costs to establish a prune orchard and produce prunes. University of California Cooperative Extension publication PU

- SV

- 01, 15pp. Available at http://coststudies.ucdavis.edu/files/prunesac2001

. Carpenter J, Gianess i L, Lynch L. 2000. The Economic Impact of the Scheduled Phase

- out of Methyl Bromide in the U.S. Washington, DC: National Center for Food and Agricultural Policy. 466 p. www.ncfap.org/ McKenry, M. V. 1999. The replant problem and its management. Contr actor for California Association of Nurseryman. Prepared for California Department of Pesticide Regulation. Catalina Publishing, Fresno, California, USA. Vasquez, S. J., Hashim, J. M., Leavitt, G. M., Peacock, W. L., Dokoozlian, N. K., Klonsky, K.
M., K atayama, D. G., DeMoura, R. L. 2004. Sample cost to establish and produce table

grapes

- Thompson Seedless. http://coststudies.ucdavis.edu/outreach/cost_return_articles/grapetbltssj2004.pdf

4. We cannot reproduce the Gross Revenues calculated in Table 2 on page 10. Using entries for yield and price, we find MB + Pic results in $2,152/ha and the alternative $2,066/ha. Is Harvest Cost included in Operating Costs? If not, net operating revenue is negative for MB 4 Pic and the alternative. If included, the Net Operating Revenues based on MBTOC calculated Gross Revenues are $749/ha for MB 4 Pic and S663/ha for the alternative and the percent change from the MB + Pie system is roughly \ 1.5%.

US Response

We introduced mistakes in Table 2 when converting into metric. The correct version of Table 2 is reproduced here:USG Preplant Replies Spring 2009 Page 15

Table 2 . Gross revenue, operating costs, and net operating revenues, California walnuts

orchard at full production. methyl

bromide + chloropicrin 1,3

- D +

chloropicrin (% change) 1

Yield ( kg / h ectare ) 3,718 3,569 (

- 4.0% ) Price ($/kg ) 1.43 1.43

Gross Revenue ($/ hectare ) 5,316 5,104 (

- 4.0% ) Operating Costs ($/ hectare ) 1,404 1,404

Harvest Costs ($/ hectare ) 893 868 (

- 2.8% )

Net Operating Revenue ($/ hectare ) 3,019 2,832 (

- 6.2% )

Source: USDA NASS (2002

- 2006), Buchner et al. (2002), BEAD calculations. Figures may not sum due to rounding.

1 Percent change in comparison to methyl bromide with chloropicrin

.

5. Because we are not confident in the entries in table 2 and unable to access Buchner et al. (2002), we are concerned that the analysis is table 3 may be flawed. Furthermore., we are unable to reproduce the NPV and IRR using the entries in table 3. This may be a problem with our computational algorithm. Also, table 3 reports the NPV is th e same for the MB + Pic treatment and the alternative, $9,495. while the subsequent paragraph claims the MB 4 Pic treatment is about §530 more per hectare.

USG Response

Buchner et al. (2002) can be found here:

at http://coststudies.ucdavis.edu/files/walnutsac2002.pdf

.

The citation is: Buchner, R., J. Edstrom, J. Hasey, W. Krueger, W. Olson, W. Reil, K. Klonsky, and R. De Moura. 2002. Sample costs to establish a walnut orchard and produce walnuts. University of California Cooperative Extension publication WN

- SV

- 02, 19pp. Available

at http://coststudies.ucdavis.edu/files/walnutsac2002.pdf

.

Table 3 had the same problems as Table 2; mistakes in conversion. The correct version of T able

3 is here:USG Preplant Replies Spring 2009 Page 16

Table 3

. Net operating revenue, net present value (NPV) , and internal rate of return (IRR)

of a walnut orchard.

Year Stage Methyl

bromide + chloropicrin 1,3

- D +

chloropicrin

0 Field Preparation

- 586

- 586 Fumigation 1

- 3,128

- 2,229

1 E stablishment

- 3,791

- 3,791

2 Non

- bearing 2

- 978

- 1,019

3 Non

- bearing

- 897

- 897

4 Initial production 3

- 638

- 657

5 Partial production 4

- 418

- 457

6 Partial production 5

- 106

- 165

7 Partial production 6 1,331 1,213

8 Full production 3,019 2,832

9

- 25 Full production 3,019 2,832
NPV (7% discount rate) 10,805 10,597

IRR 13.8 % 14.4 %

Source: Buchner et al. (200 2 ), and B EAD calculations. Net operating revenues are not discounted; negative numbers represent costs greater than income. Net present valu e is calculated assuming 7%

discount rate.

1 Fumigation costs include chemical costs and application costs.

2 In addition to operating costs, non

- bearing costs include replanting trees.

3 Initial production is 10% of full production.

4 Production in th e fifth year is 20% of full for combination treatments.

5 Production in the sixth year is 30% of full for combination treatments.

6 Production in the seventh year is 60% of full production for combination treatments.

Please note that the net present value is different for the two treatments, and fumigation is more expensive with methyl bromide, by almost $900 per hectare, however the net present value for is higher with methyl bromide, by about $200 per acre.

6. Please confirm that references to ta bles E. 1 (page \ 0), E.2 (page 10), E,3 (page 12), E.4 (page 13), E.5 (page 16), and E.6 (page 16) should read tables 2, 3, 4, 5, 6, and 7.

USG Response

That is correct.

7. Page 13 refers to NPV and IRR in table E.4 (presumably table 5) for prune orch ards under four treatment options. However, table 5 shows only 2 treatment options. Please report the data for the other two options.

USG ResponseUSG Preplant Replies Spring 2009 Page 17

Results for the other two treatment options were not reported, because the returns to growers

were lower. T herefore, we assumed that growers would us 1,3

- D + Chloropicrin as the primary alternative to methyl bromide. However, as requested, the other treatment options are shown in

the below table.

Table 5

. Net operating revenue, net present value (NPV) , an d internal rate of return (IRR)

of a prune orchard.

Year Stage Methyl

bromide + chloropicrin 1,3

- D +

chloropicrin 1,3

- D +

Metam 1,3

- D

alone

0 Field Preparation

- 618

- 618

- 618

- 618 Fumigation 1

- 2,519

- 2,025

- 3,878

- 1,692

1 Establishment

- 3,137

- 3,137

- 3,137

- 3,137

2 Non

- bearing 2

- 995

- 1,018

- 1,067

- 1,139

3 Non

- bearing

- 1,294

- 1,294

- 1,294

- 1,294

4 Initial production 3

- 1,336

- 1,361

- 1,387

- 1,294

5 Partial production 5

- 1,023

- 1,072

- 1,121

- 1,430

6 Partial production 6 2

- 82

- 164

- 1,208

7 Full p roduction 6 1,028 904 779

- 310

8

- 40 Full production 7 1,028 904 779 562
NPV (7% discount rate)

- 874

- 1,529

- 4,399

- 5,489

IRR 6.3% 5.7% 3.7% 2.0%

Source: Buchner et al. (200 1 ), and BEAD calculations. Net operating revenues are not discounted; negative numbers represent costs greater than income. Net present value is calculated assuming 7%

discount rate.

1 Fumigation costs include chemical costs and application costs. Methyl bromide and 1,3

- D can be applied with chloropicrin as a single product, but 1,3

- D and metam sodium must be applied separately.

2 In addition to operating costs, non

- bearing costs include replanting trees.

3 Initial production is 20% of full production. On

- set of production is delayed one year if 1,3

- D is used

alone.

4 Production in the fifth year is 40% of full for combination treatments. Production is 20% of full production with 1,3

- D alone.

5 Production in the sixth year is 67% of full for combination treatments. Production is 40% of full production with 1,3

- D alone.

6 Produc tion is 67% of full production with 1,3

- D alone.

7 Production ceases one year earlier with 1,3

- D alone.

8. Page 1 5 states; As shown in Table E.5, methyl bromide shows no benefit over 1,3

- D once a vineyard is in production. In places where 1,3

- D cannot be used, the loss of methyl bromide would be extremely costly. Fumigating with methyl bromide and chloropicrin is worth $270per hectare relative to melam sodium, and almost $400 per hectare more than, no fumigation.USG Preplant Replies Spring 2009 Page 18

Please explain how to use the information in Table E.5 (apparently meaning Table 6) to find the S270 and $400 values. It is not the difference in Gross Revenues nor is it the difference in Net Operating Revenues. However, the statement in the first paragraph on page 16 referrring to increased valu e for MB + Pic over metam sodium and no fumigation

is consistent with the table 6.

USG Response

The $270 and $400 values are incorrect, because they refer to value per acre, not value per hectare. The correct values are given in the first paragraph of p age 16.

USA ORNAMENTALS

1. For the New York greenhouse use, is there any specific information on why steam, and substrate systems that are used elsewhere in the US (as well as other countries) cannot be adopted?

USG Response

Yes, there are specific reasons why steam and substrate systems cannot be adopted by the New York ornamental grower in his greenhouse operation.

With regard to substrates, the grower‘s operation is physically incompatible with a substrate system. Substrate systems can be ad opted in greenhouses that grow plants in containers and/or on benches. However, the New York greenhouse in question does not have benches; it is a set of enclosures open to the ground on the bottom. Plants are grown directly in the soil on the ground. Adopting a substrate

- based cropping system would require completely overhauling their current infrastructure and growing practices. Therefore, establishing a substrate system would be cost prohibitive. And as mentioned on page 5 of the nomination, even substrate systems are usually fumigated. Moreover, additional costs may be incurred by the grower due to different fertilization and watering practices.

As mentioned on page 18 of the nomination, steam can be a technically feasible pest control option for open field or greenhouse growers. Moreover, as mentioned on page 5 of the nomination, steam sterilization appears to be the best currently available alternative to methyl bromide for the New York greenhouse producer. However, there are many costs to convert existing greenhouse infrastructure to accommodate steam as a pest control measure, as discussed on page 6 of the nomination. Furthermore, as discussed in Table 3 on page 8 of the nomination, there is no current research on yield losses resulting f rom switching from methyl bromide to steam sterilization. Due to this uncertainty, our nomination considered 0%, 10%, and 20% yield loss scenarios. Even with a 0% yield loss projection, there would be a significant (approximately 9%) loss of net operati ng revenue.

Table 3: New York A nemones

- Economic Impacts of Methyl Bromide Alternatives *USG Preplant Replies Spring 2009 Page 19

New York Cut Flowers

– Anemones Methyl Bromide

Steam Steam Steam

Yield Loss (%) 0 0 10 20

Yield per Hectare 247,105 247,105 222,395 197,684

* Price per Unit (U.S.$) 3.75 3.75 3.75 3.75
= Gross Revenue per Hectare (U.S.$) 926,644 926,644 833,980 741,315

- Operating Costs per Hectare (U.S.$) 34,595 115,781 115,781 115,781

= Net Operating Revenue per Hectare (U.S.$) 892,050 810,863 718,199 625,53 4

1. Loss per Hectare (U.S.$) 0 81,186 173,851 266,515

2. Loss per Kilogram of Methyl Bromide (U.S.$) 0 110,86 237.38 364

3. Loss as a Percentage of Gross Revenue (%) 0 8.8 18.8 29

4. Loss as a Percentage of Net Operating Revenue (%) 0 9.1 19.5 30

* Due to a lack of research on steam sterilization as a methyl bromide alternative for pre

- plant fumigation for ornamentals in enclosures, yield loss estimates do not exist. Scenarios were therefore calculated with 0%, 10%, and 20% yield loss estimate s.

2. Table 4 on page 9 reports identical yields, prices, gross revenues and operating costs for MB and MI 4 Pic yet reports Net Operating Revenue is lower for the MI + Pic alternative. Please explain what adjustments were made to lower the Net Operati ng Revenue for the

MI 4 Pic treatment?

USG Response

There was a typo for the operating costs per hectare for MI + Pic in Table 4. It is corrected as

shown in red in Table 4 below.USG Preplant Replies Spring 2009 Page 20

T ABLE 4 : F LORIDA C UT F LOWERS

- L ILIES

- E CONOMIC I MPACTS OF M ETHYL B ROMI DE
A LTERNATIVES

Florida Cut Flowers

- Lilies M ETHYL
B ROMIDE IODOMETHAN

E + PIC (98:2)

Y IELD L OSS (%) 0 0

Y IELD PER H ECTARE 3 1

, 135 3 1

, 135

* P RICE PER U NIT (U.S.$) 10 10

= G ROSS R EVENUE PER H ECTARE (U.S.$) 311,353 311,353

- O PERATING C OSTS PER H E CTARE (U.S.$) 262,715 264,445

= N ET O PERATING R EVENUE PER H ECTARE (U.S.$) 48,638 46,908

1. L OSS PER H ECTARE (U.S.$) 0 1,730

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE (U.S.$) 0 4

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0 1

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

USA STRAWBERRY FRUIT

- FIELD

1. In Florida, what has been the transition rate to iodomethane in 2008?

USG Response

Remember that iodomethane was not registered for use in Florida until July of 2008 although

there was s ome earlier use as part of an experimental use permit. Information on the amount used in Florida is not yet available. In any case it is unclear how this information could be obtained as Florida does not track pesticide use and NASS (USDA‘s national agri cultural statistical service) no longer collects these data. It might be possible to collect some information from pesticide distributers although these data would be confidential and if there are more than

nine distributers in the State of Florida we wou ld be required to obtain permission to conduct a survey from the Office of Management and Budget, a process that could take a year.

2. I n Eastern region, what has been the transition, rate to iodo m ethane in. 2008?

USG Response

It is unclear how this information could be obtained as states other than California do not track pesticide use and NASS (USDA‘a national agricultural statistical service) no longer collects these data. It might be possible to collect some information from pesticide distribute rs although

these data would be confidential and if there are more than nine distributers in the states of the eastern region we would be required to obtain permission to conduct a survey from the Office of Management and Budget, a process that could take a year.USG Preplant Replies Spring 2009 Page 21

3. The C U

N mentions issues with iodomethane use rates, formulation, availability

- please clarify?

USG Response

Page 4 of Strawberry CUN addresses this point : ―High

- percent iodomethane formulations (98:2) have not been tested rigorously to sup port research findings. Identifying effective use rates and effective formulation ratios are only beginning to be addressed after the 2008 registration. Equipment adaptation and product availability are concerns for growers who have no experience

with th e product. Consequently, while iodomethane may be a promising soil treatment, there remains a critical need for methyl bromide until issues of concern are satisfactorily resolved for

iodomethane.‖

4. It is encouraging to see a Californian initiative being funded, called “Farming without fumigants”. What alternatives are they testing on strawberry fruit in California?

USG Resp o nse

D. Legard (personal communication; email, 3

- 18

- 2009) of the California Strawberry

Commission commented:

We are taking a combination approach with the realization that development and implementation of these alternatives may well take 15 or 20 years. We are exploring methods to manage pathogens in soil through modified production practices and the use of

amendments. This approach is not likely to yield usable results in the foreseeable future. The second approach is to adapt methods used in Europe for substrate production systems to California. This includes using substrates and developing a method to reduce the

amount of soil used to produce strawberries, thereby reducing the amount that needs to be treated by fumigants or other alternatives like steam. We are currently looking at what we call the raised bed trough system, where soil or substrate is placed in a trough pressed into a raised bed. The trough is lined with mulch to prevent pathogens in the soil of the bed from contaminating the substrate or the treated soil in the trough. We are in the early stages of working out the kinks of this production system and it looks like a key will be learning how to replace the substrates used in these systems with soil and how to effectively treat the soil.

5. The loss Tables 3

- 5 do not provide a good overview of production losses and costs and benefits and some figures do not add up. Please provide a reference for this

documentation?

USG Response

See note above. The column in Table 5 labeled ―Pic + MB ―should not have been included for California as it is not a viable option. Unfortunately the numbers for operating cost s and grossUSG Preplant Replies Spring 2009 Page 22

revenue were transposed in that column so that a l though the result was correctly reported as a loss, the transposition appeared to lead to a positive result in terms of net revenue

.

6. If possible, could you please provide a copy of the emai l information sent by Toth (2008)?

USG Response

Please see Appendices A, B, and C attached to this document.

7. Could you please provide the list of specific references used to support production losses for 1,3D/Pic and MB/Pic in California and 1,3D/Pi c in the Florida regions?

USG Response

The Party included three columns in the economic section for California, listing methyl bromide, chloropicrin + methyl bromide, and 1,3

- D + chloropicrin. The center column, chloropicrin + methyl bromide was inadver tently included and is not relevant to this sector. For California, we considered only 1,3

- D + chloropicrin as a current alternative to methyl bromide.

Production loss figures were derived based on numerous multi

- year, multi

- location research

trials co mparing various fumigant treatments. The primary alternative for California and Florida (it is still unknown what effect the recent registration of iodomethane will have on fumigation needs) has been 1,3

- D, frequently used with chloropicrin. As described in the CUN, the production land requiring critical use of methyl bromide for strawberry fruit does not have the option of 1,3

- D due to soil conditions or regulatory restrictions. Land amenable to 1,3

- D treatment was not nominated for methyl bromide criti cal use.

Yield loss estimates were calculated based on pest pressure, location differe nces, cultivar differences, and, especially for 1,3

- D, soil moisture and texture characteristics . Consequently,

while there are alternatives in some trials that may p rovide similar efficacy to methyl bromide, the assessment was made that overall, there were still factors that caused losses as described in

the CUN. As described in the CUN, in California, the emergence of Macrophomina phaseolina

and Fusarium oxysporum i n fields that have been treated with non

- MB fumigants has further increased the calculation of some crop losses with alternative chemicals. This may be caused by an increase in drip application versus traditional broadcast application of methyl bromide.

Citations for fumigant trials were included in the reference section of the CUN, which includes efficacy studies use to calculate overall losses that are believed to be relevant to adoption of

alternatives for 201 1

. In addition, data from a meta

- analysis of numerous studies was considered in estimating overall losses with alternatives (Shaw V.S., and Larson K.D., 1999. A Meta

Analysis of Strawberry Yield Response to Preplant Soil Fumigation with Combinations of Methyl Bromide

- chloropicrin and Four Alterna tive Systems. HortScience 34:839

- 845).

8. In the BUNN1E (Table 6) there is an inconsistency: For California, the area and quantity increase from 2010 to 201! even though the application rate comes down and there is a statement of 0% transition. Please cl arify?USG Preplant Replies Spring 2009 Page 23

USG Response

There is no increase in California over the amount requested for 2010.

9. Please clarify the difference between Methyl Bromide and PIC + MB in table 5 analysis for California? Does Pic + MB cover all mixtures with MB+PI C?

USG Respo nse

This column should have been deleted from the analysis

. This is not a viable alte r native in California given the large buffers that are currently required by the State of California when Pic

is used. The corrected table is below:

T ABLE 5. C ALIFORNI A : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

CALIFORNIA M ETHYL
B ROMIDE 1,3 D + PIC

P RODUCTION L OSS (%) 0% 14%

P RODUCTION PER H ECTARE 49,410 42,475

* P RIC E PER U NIT ( US $) $ 1.37 $ 1.37

= G ROSS R EVENUE PER H ECTARE ( US $) $ 67,537 $ 58,057

- O PERATING C OSTS PER H ECTARE ( US $)** $ 66,849 $ 66,100

= N ET R EVENUE PER H ECTARE ( US $) $ 688 ($ 8,042)

1. L OSS PER H ECTARE ( US $) $ 0 $ 8730

2. L OSS PER K ILOGRAM OF M ET HYL
B ROMIDE ( US $) $ 0 $ 43.51

3. L OSS AS A P ERCENTAGE OF G ROSS
R EVENUE (%) 0% 13%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 1269%

5. O PERATING P ROFIT M ARGIN (%) 4%

- 14%

**Note that the measures in the tables below must be interpret ed care fully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs.

USA S TRAWBERRY RUNNERS

1. On page 4 of the nomination it states that 'The certification requirements for strawberry nurseries (e.g., CDFA, 2003; TDA, 1999; NCDA, 1985} located in the states requesting critical use exemptions for methyl bromide are strict (zero tolerance for an)' damaging diseases and plant

-

parasitic nematodes) i n order to minimize the prospect of spreadingUSG Preplant Replies Spring 2009 Page 24

these pests to othe r states and countries where these plants arc shipped'. Further it claims that 'State authorities may determine appropriate measures to achieve pest

- free designation.' On the bottom of page 4 Further it claims that plants must be "essentially free of insec t pests and plant diseases' and on page 5 'only a few of the plains in any lot or Mock of nursery stock or on the premises show any infestation or infection,'.

Could the party please explain (full details of the practical process) of how zero

tolerance is presently determined with MB/Pic use and show supporting data (references) to clarify that zero tolerance is obtained with MB?

Also, could an explanation of how tolerance (especially zero tolerance) for the alternatives is being evaluated?

USG Response

Regulations pertaining to individual state agricultural certification programs are written in different ways by respective state authorities. They address various, sometimes unique, problems and interests, and, therefore, are likely not to be verbatim l anguage. All nursery regulations, however, attempt to provide growers with healthy stock plants that ensure grower

confidence that unfit starting material will not end their season before it begins.

Progress is being made by researchers. However, unti l research has validated efficacy studies of various alternatives to MB for nurseries, there remains a critical need for MB, currently the only proven treatment that is widely accepted as effective in meeting nursery standards (e.g., García

Méndez et al

., 2008; Fennimore et al. , 2008).

According to the National Plant Board (an organization comprised of representatives of plant pest regulatory agencies of each state):

( http://natio nalplantboard.org/policy/guidelines.html#risk ) Nursery Stock Registration and Certification Programs Many state governmental agencies responsible for nursery stock regulatory activities also have developed registration and certification programs for vario us kinds of nursery stock. Programs exist for avocado, caneberry (e.g. raspberry), citrus, deciduous fruit and nut tree, garlic, grapevine, seed potato, strawberry, and vegetable transplant nursery stock.

The purpose of these programs is to deal with pes t and other problems that cannot be effectively managed via the standard nursery regulatory program of visual inspection. These programs are, instead, based on official inspection, sampling, testing, and record

keeping aimed at assuring that the finished plant products meet specified requirements. Typically, laboratory testing, using well established diagnostic procedures, is the basis for determining disease or pest freedom. Targeted pests typically are viral, bacterial, and other plant pathogens; plant disorders; and soil

- borne pests such as nematodes. Participation in registration and certification programs normally is voluntary and participants pay fees to cover the additional and special inspection and testing required. Nursery stock meeting theUSG Preplant Replies Spring 2009 Page 25

req uirements of such programs is typically identified by tags, seals, or other indicia of certification affixed to the individual plants, bundles, cartons, or other units of sale.

Registered or certified nursery stock should meet the basic nursery standards as well as those separately established by the state's registration and certification rules or regulations. The much greater freedom from pests and diseases in some cases also may satisfy quarantine requirements.

References :

Fennimore, S. A., Duniway, J . M., Browne, G. T., Martin, F. N., Ajwa, H. A., Westerdahl, B.B., Goodhue, R. E., Haar, M., and Winterbottom, C. 2008. Methyl bromide alternatives evaluated for California strawberry nurseries. California Agriculture 62(2):62

- 67. http://repositories.cdlib.org/cgi/viewcontent.cgi?article=3194&context=anrcs/californiaagriculture

Garc í a

- M é ndez, E., Garc í a

- Sinovas, D., Becerril, M., De Cal, A., Melgarejo, Pl, Mart í nez

- Trece ñ o, A., Fennimore, S. A., Soria, C., Medina, J. J., and L ó pez

- Aranda, J. M. 2008. Chemical alternatives to methyl bromide for weed control and runner plant production in strawberry nurseries. HortScience 43(1):177

- 182.

2. W hat sampling procedure is used to support the present certification with MB?

USG Response

State regulations assign experts to determine appropriate measures that satisfy agricultural standards of the respective state authorities. These may vary accordin g to individual conditions.

3. On page 5 it claims that in Tennessee „sites shall be fumigated or otherwise sterilized using materials and methods prescribed or accepted by the Director of Entomology and Plant Pathology of the Tennessee Department of A griculture‟.

Could you please provide a copy of this prescription?

USG Response

State regulations assign experts to determine appropriate measures that satisfy agricultural standards of the respective state authorities. These may vary according to ind ividual conditions (e.g., whether certified or registered plants). Please refer to state regulations ( http://state.tn.us/sos/rules/0080/0080

- 06/0080

- 06

- 02.pdf ).

4. In Nor th Carolina it claims that 'A plant inspection certificate shal l be issued after the nursery has ; been inspected by an inspector of the North Carolina Department of Agriculture, found apparently free of injurious plant pests, and the proper fee paid. An

i nspection shall be conducted at least once annually prior to September 30 of each year.USG Preplant Replies Spring 2009 Page 26

The inspection in North Carolina appears to be by visual inspection. Can you please clarify if this is correct and if so, how are tolerance levels for plant pathogens and

nematodes determined?

USG Response

Depending on individual nursery situations, certification procedures may vary. See, http://www.nccrop.com/files/Strawberry%20C ertification%20Standards.pdf ; http://www.ncagr.gov/plantindustry/plant/nursery/lictbl.htm ; http://natio nalplantboard.org/policy/guidelines.html#risk

.

5. Docs the use of MB covered by a certification standard (p.5 (3)) specifically mandate the

use of MB?

USG Response

Certification requirements are regulated by state authorities, not by the federal gover nment. MB may not be specified as ―mandated‖ in some instances , although because many potential alternatives to MB have not been proven of sufficient efficacy to meet pest

- free standards, MB in many cases is considered an effective treatment that satisfie s certification requirements. Treatments without the long history of use in the nursery industry as MB do not have the consistency of effectiveness to warrant equal status. Nursery researchers are currently trying to identify alternative treatments that may be used, but variable soil conditions complicates the broad adoption of any replacement of methyl bromide, which has shown efficacy in wide ranging soil types, moisture, and depth.

6. On page 6 the CUN states that 'This nomination is only for a port ion of nursery soils that produce transplant requiring methyl bromide, but not designated QPS'.

Could the Par t

y please explain the difference between the MB use amount requested under the 'critical use' process and those designated QPS.

USG Response

Und er the regulations regarding quarantine in the United States, the product must be transported across a political boundary to qualify for a quarantine exemption. For many nursery crops, however, a portion of the crop is sold for use within the bounded area (In California this is within a county, for the rest of the United States this is usually within the State.) Nursery crops sold within the bounded area (within county or within state) do not qualify for methyl bromide under a quarantine exemption and, th erefore, apply for a CUE.USG Preplant Replies Spring 2009 Page 27

7. On. page 6 the CUN claims 'That alternatives have proven as effective as MB but time and expense necessary to transfer new technology from the research stage to commercial application continues to result in the need for a crit ical use of methyl bromide'

Could the Party please provide quantification of what time and expense are incurred with adoption of alternatives, particularly Ml/Pic or 1,3D/Pic?

USG Response

Identifying effective use rates and effective formulation ratios of iodomethane and Pic

formulations are only beginning to be addressed after the 2008 registration. Equipment adaptation

, necessitated given the corrosive characteristics of iodomethane

, and product availability

, are concerns for growers who have no expe rience with the product. Consequently, while iodomethane may be a promising soil treatment, there remains a critical need for methyl bromide until issues of concern are satisfactorily resolved for iodomethane. Quantification is difficult to provide as it is dependant on the number of trials necessary to establish the (lowest) effective dose. Iodomethane is more expensive than methyl bromide and unless the cost of iodomethane were to come down it is an economically feasible alternative for methyl bromide only if it can be applied at much lower rates.

US SWEET POTATO TRANSPLANTS

1. Table 6 indicates that use of chloropicrin results in an 11% increase in production over methyl bromide. Hand weeding costs are greater with chloropicrin (Table 6), but overa ll, production increase outweighs the cost increases and results in positive economic impacts. This shows chloropicrin is economically feasible. Please make clear the reason why chloropicrin is not feasible in terms of technological standpoint of view?

US G Response

The plants from the chloropicrin plots did indeed show a statistically significant numeric difference in root harvest as compared to some of the other treatments, however, it is not clear

whether that this effect was "real" or more a factor of the resolution of the statistical design. This is particularly of concern given that two other treatments also used chloropicrin at similar rates (MeBr and Pic Chlor 60). Revised cost estimates make it appear to be more economically

feasible now than at the time that the most recent CUE request was submitted (summer of 2008) in that this treatment did not cause any significant decrease in root yield. Chloropicrin alone in the hotbed area did not control weeds that well, and in the hotbeds weeds and disea se control are the main issues. The addition of either herbicide (Devrinol [napropamide] or Valor [flumioxazin]) significantly improved weed control, and this indeed could be a viable alternative. However, more than one year of data will be needed to det ermine if this is a consistent and

effective treatment.USG Preplant Replies Spring 2009 Page 28

2. MBTOC suggested in 2008 TEAP CUN final report that US is expected to consider the availability of registered nematode cultivar (Bienville) and of nor. host cover crops followed by application of registered nematicide such as ethoprop, aldicarb and metam sodium to reduce dose rate of 1,3 dichloropropene. Why are these not considered suitable

alternatives?

USG Response

Bienville, though available to California growers and supported by the Sweet Potato Council of California, has not proven to be very popular with growers because of problems with cracking and high post harvest decay losses. Two other new varieties with nematode resistance recently available include "Covington" and "Evangeline", b ut only Covington has shown large

- scale grower acceptance. Variety resistance to nematodes in the hotbeds may be a moot point, because the short duration the roots are in the ground plus grower practices of cutting plants likely reduce

the chance for subs tantial impact from nematodes (again, this last statement only applies to the hotbeds. For field production, nematode resistance is very important).

Aldicarb and the related product ethoprop are not labeled for hotbeds. Aldicarb is no longer used

in California for sweet potatoes, mainly because of the 120 day PHI and growers who want nothing to do with the potential liability this product carries. It is labeled for field production. Like aldicarb, ethoprop is also labeled for field production. Unli ke aldicarb, it is used in California. But either product does not have a place in the hotbeds (and not labeled as such), and probably would not be considered anyway because nematodes are not a major concern. However, metam sodium (or metam potassium) co uld be used effectively in the hotbeds, either alone or combined with 1,3

- D. This is one of the treatments in the current research trials, and for 2009 the rate of both Vapam (metam sodium) and Telone (1,3

- D )were reduced as compared to 2008. In fact, we re it not for the cap, VOC issues, and (now) production problems with Telone (1,3

- D), this would be an excellent alternative from a cost/effectiveness standpoint. If Telone is unavailable this summer, the contingency plan is to experiment with tarped Vapa m (metam sodium) and/or a Vapam (metam sodium) + Pic combination, either of which should control

weeds and disease.

3. In page 6, research has been presented on the alternative application of Botran & Mertec applied in Fe brua r

y 28, 2008 and Devrinol & V alor applied March 7,2008. Are these

results available.

USG Response

Yes. There were no differences between the fungicide treatments and the untreated plots because there was very little disease or root rotting problems noted in the test plots. Good management (proper irrigation, temperature management, good seed) and prior fumigation were probably important factors in keeping disease pressure very low.

Devrinol (napropamide) and Valor (flumioxazin) significantly improved weed control in those

tre atments where fumigation did not (Pic, Solar, and Untreated). Valor (flumioxazin) was more effective, but also caused some crop phytotoxicity. The figure on the left shows results of handUSG Preplant Replies Spring 2009 Page 29

weeding times, which clearly shows the solar and untreated plots n eeding the most time; the figure on the right gives total weed counts after hand weeding. These results suggest that the combination of fumigation + herbicides may be an effective alternative to MeBr. More likely, it will also include fumigation timing a nd field rotation. In only another 1.5 years we hope to be

able to provide that answer.

4. Fosthiazate is an effective nematicide. Is there any prospective for it to be registered as an alternative to apply sweet potato? If not, why?

USG Response

Fosthiazate is currently registered only for tomatoes in the U.S. However, we are unable to find any evidence of current state registrations of fosthiazate in the U.S. which suggests that it is not currently being marketed in the U.S. The U.S. does not have any further information on the companies intention to register the product on any other crop.

USA TOMATOES

- FIELD

1. Text referring to tables 6

- 14 states:

We conclude that

, at present, iod o methane would be the economically feasible alternative

to methyl bromide for use in Eastern US tomato production in areas exhibiting karst topographical features'. The tables show loss measures as a percent of Net Operating Revenue ranging from

- 34% to

- 79%. Losses of this size in net operating revenues,

su ggest inadequate or marginally adequate returns to cover non

- operating (fixed) costs. Can the US suggest a maximum percent loss in net operating revenue for methyl bromide alternatives for tomatoes (or other crops) beyond which the alternative would be

con sidered not economically feasible? Are the percent losses in net operating revenues exaggerated because the partial budget analyses do account for receipts from double cropping?

USG Response

The economic analysis represents a variety of grower operations and may not reflect an individual grower's actual returns. MBTOC is correct in observing that the percent losses in net operating revenues may be exaggerated because the partial budget analysis may not account for double cropping.

In order to determi ne whether a proposed alternative to MB is considered to be  ̳economically feasible‘ for those situations where technically feasible alternatives exist, the United States took a  ̳weight of the evidence‘ or  ̳portfolio‘ approach. Rather than rely on a single indicator or even a series of indicators, each with a  ̳bright line‘, the situation of the applicant with respect to five measures was assessed. The five measures selected for consideration were: loss per hectare; loss per kilogram of MB; loss as a percen t of gross revenue; loss as a percent of net cash returns; and change in profit margins. These measures were selected because the information was fairly readily available; they describe different aspects of potential loss and are independent of eachUSG Preplant Replies Spring 2009 Page 30

other . In cases where information was not available for one or more of the measures, the remaining measures were used. In cases where a stream of benefits was derived from a MB application, net present value was used in the calculations.

When evaluating the case made by each application, expert economic judgment was used to determine whether each loss (or change in profit margin) was significant, not significant, or borderline within the context of the applicant‘s market. Once decisions on individual measure s were reached, an overall assessment was made which included the individual measures.

2. A transitio n for 2010 is given by the BUNI ‟ s. Please explain how these tra nsition rates

were obtaine d

.

USG Response

Please see transition discussion (above).Appendix

USG Preplant Replies Spring 2009 Page 31 A PPENDIX A (Strawberry Fruit) (Email from S. Toth, 11

- 4

- 2008)

November 4, 2008

To: Christine Augustyniak

Bill Chism Stephen Smearman

From: Barclay Poling, Professor and Extension Specialist, Dep artment of Hort icultural Sci ence
,

N orth C arolina S tate U niversity Steve Toth, I PM Coordinator and Extension Entomologist

, Dep artment of Entomology, N orth C arolina S tate U niversity

Re: MBTOC‘s recommendation is unacceptable to Southeast Strawberry Consortium fruit

production members for reasons stated in t his REPLY

On 23

- October 2008 we were advised that MBTOC believes that iodomethane is both a technically and economically feasible alternative for the use of Southeast (and Eastern) Strawberry Consortium members,

and that in order for EPA to continue our critical use exemption application for methyl bromide for 2011 (this year‘s application), we must explain why iodomethane is not a suitable alternative at this time for our fruit crop producers.

Accordingly, we conducted a survey of the membership of t he Southeast Strawberry Consortium members, from Friday, October 24 to Monday, November 3, and though we received email responses that are also being conveyed separately to EPA by Steve Toth, t his document helps to further explain our reasons for wishing t o still pursue a critical use exemption application for methyl bromide in 2011 for Southeast Strawberry Consortium fruit producers.

1) Inadequate time to fully assess the potential of Iodomethane. This alternative fumigant has only recently been regist ered for commercial application in our region for a relatively short period. We are anxious to get some feedback in spring 2009 from the first grower trials with Midas 50:50 and Midas 98:2 that went out in fall 2008 (we estimate only about 2.5% of our tot al acreage was treated with iodomethane). Thus, it is still too early for us to provide MBTOC with any reliable commercial level information about whether this product will ―demonstrate yield losses (relative to methyl bromide).‖ We

are conscious of som e very promising research station data with iodomethane that has recently been compiled by Dr. Poling, NCSU, Department of Horticultural Science, at Clayton Central Crops (near Raleigh), and this report is attached. However, it must me emphasized that we still do not have any field testing experience with iodomethane, other than the 100 + acres treated last fall, and the performance of these fields will not be known until harvest in spring 2009.

2) Iodomethane’s efficacy at lower rates and nutsedge contro l. We have not even had 12 months with full registration, thus we do not have a good feel for the potential efficacy problems associated with iodomethane. However, we are eager to pinpoint in strawberries how effective iodomethane is at low

rates

, under various soil conditions/types and on sites where there is a serious nutsedge problem. We are quite concerned that in other growing areas, including Plant City, Florida, with reports that lower rates of Midas present significant challenges for control of nutsedge, and we are also concerned about increased disease pressure with these lower rates. At this time it appears to us that Midas rates need to be higher toAppendix

USG Preplant Replies Spring 2009 Page 32 gain consistent control of nutsedge, and this could significantly add to the cost of Midas usa ge. We critically need more farm research trials in our region to demonstrate the efficacy of Midas on sites with significant nutsedge pressure at various rates. Unfortunately, Dr. Poling‘s research trial at Central Crops

in 2007

- 2008 (report attached) di d not achieve a good stand of yellow nutsedge due to an untimely freeze in early November 2007.

3. Equipment problems. Furthermore, we have received reports through our industry survey of serious equipment problems being encountered by growers who are try ing to apply lower rates of Midas 98:2. Because Midas weighs more than methyl bromide this translates to a very low rate being applied and requires equipment evaluation and changes to assure that each grower can properly apply Midas with their applicatio n equipment. Even Dr. Poling‘s 2007

- 2008 trial at Clayton Central Crops experienced equipment related problems with applications of Midas 98:2. It is important to keep in mind that for 50% bed treatment, the average net volumes per acre with methyl bromi de with VIF is 7 gallons vs. only 2 to 3 gallons with Midas 98:2 with VIF. Many strawberry growers in North Carolina do not even own a flow

meter!

4. Technology transfer challenges. MBTOC and the EPA must realize that the challenges of making Midas appl ications with standard methyl bromide equipment are not insignificant. And to this end, Arysta LifeSciences sponsored a full morning workshop at the Central Crops Research Station in Clayton, NC, on August 4, 2008, and similar training programs is being planned in conjunction with the Southeastern Strawberry Expo on Saturday Nov ember 8 (Charlotte, NC). Still, these workshops have only reached a small fraction of our industry. As was pointed out to the EPA in a survey conducted by the NC Strawberry Assoc iation, most growers in the Southeastern Strawberry Consortium do their own fumigation. We are truly needing a very intensive, region

- wide educational program for growers in our consortium to help them transition to iodomethane. A professionally produced 30

- minute video covering both safety requirements and application issues for making Midas applications (with standard methyl bromide equipment) would be a good starting point, and it is quite possible that we could work through the Southern Region Small F ruit Consortium (NC, SC, GA, VA, TN, AR) to make more significant

inroads in these 6 states with In

- Service Agent Trainings focused on iodomethane application equipment, applicator safety requirements, and overall record keeping and documentation managemen t. The Southern Region Small Fruit Consortium has a long history of offering quality training programs for Extension Professionals in our region on variety of timely issues.

5. Unknown product costs. We are concerned that we still do not have a good ha ndle on what the true costs of iodomethane applications will be in our region. In Dr. Poling‘s research report (attached) he

identifies a cost of $9.00/lb for Midas 50:50 in 2008, but is there a likelihood that this cost could increase significantly nex t year as Pa ckagers and Distributors will need to recoup their extra maintenance costs on their cylinder fleet due to the product‘s corrosiveness? This would have a direct impact on the economically feasible aspects of fumigant comparisons. Because of th ese concerns, as well as our belief that higher rates of Midas will be required for sites infested with nutsedge, we are not able to accept MBTOC‘s proposition that full application costs for iodomethane and methyl bromide are approximately equivalent. I t is simply too early to tell for sure.Appendix

USG Preplant Replies Spring 2009 Page 33 A PPENDIX B (Strawberry Fruit ) Email from S. Toth, 11

- 4

- 2008

STRAWBERRY PLASTICULTURE RESEARCH WITH MIDAS 50:50 AND MIDAS 98:2 IN NORTH CAROLINA, 2007

- 2008 (Central Crops Research Station, Clayton)

E. Barclay P oling Professor and Extension Specialist (Small Fruits) Department of Horticultural Science, North Carolina State University

Rocco Schiavone

Research Associate Department of Horticultural Science, North Carolina State University

At NC State University in the Department of Horticultural Science we have been investigating various iodomethane formulations and rates since the year 2000. In this 2007

- 2008 study at Central Crops Research Station in Clayton, NC (USDA hardiness Zone 7b, lat. 35 o 7‘ N, long.

78 o 5‘ E), we primarily investigated the performance of Midas 50:50 (4 rates) compared to Midas 98:2 (4 rates), we also included a fumigant treatment with methyl bromide 50:50 for comparison to Midas. A VIF barrier film (Pliant Blockade) was used to increase th e efficacy of fumigant treatments, except for treatments 10, 11, and 12 where standard LDPE black plastic mulch was used (Table 1). Nutgrass was seeded in all plots, except treatment 14.

Table 1. Treatments in 2007

- 2008 Trial at Clayton Central Crops

Treatment 1

- Midas 98:2 @ 60 lb/A broadcast + VIF

Treatment 2

- Midas 98:2 @ 70 lb/A broadcast + VIF

Treatment 3

- Midas 98:2 @ 80 lb/A broadcast + VIF

Treatment 4

- Midas 98:2 @ 90 lb/A broadcast + VIF

Treatment 5

- Midas 50:50 @120 lb/A broadcast +VIF

T reatment 6

- Midas 50:50 @ 140 lb/A broadcast +VIF

Treatment 7

- Midas 50:50 @ 160 lb/A broadcast + VIF

Treatment 8

- Midas 50:50 @ 180 lb/A broadcast + VIF

Treatment 9

- Methyl Bromide @ 175 lb/A broadcast + VIF

Treatment 10

- Midas 98:2 @ 90 lb/A + Stand ard Black

Treatment 11

- Midas 50:50 @ 180/A + Standard Black

Treatment 12

– Control (no fume) + Standard Black

Treatment 13

- Control (no fume) + VIF

Treatment 14

- Control (no fume) + VIF + no nutgrass

Materials and Methods: The broadcast rates for M idas 98:2 were 60, 70, 80, and 90 lb/A (30, 35, 40 and 45 lb/A in

- the

- bed, respectively), and this required 1.65, 1.92, 2.0 and 2.47 lb product per 100 linear ft of bed (5 ft bed centers). The broadcast rates of Midas 50:50 were 120 lb/A, 140 lb/A, 160 lb /A and 180 lb/A (60, 70, 80, and 90 lb/A in

- the

- bed, respectively), and this required 3.30, 3.85, 4.40 and 4.95 lb product per 100 linear ft of bed. Methyl bromide 50:50 at 175 lb/A required about 4.82 lb per 100 linear ft of bed. The greatly reduced volu me of MidasAppendix

USG Preplant Replies Spring 2009 Page 34 compared to Methyl Bromide required a smaller flow meter, and the equipment of Mitchell Wrenn‘s (custom fumigator) had 0.79 MBR CAP GAL/MIN flow meter capacity. To improve application efficiency we opted to use orifice plates, and these were pr ovided by Arysta representative Bob Kreger, who was at the test site on the date of fumigation (9/20/07). Calibrations for Midas 50:50 were reliable and within 10% of the goal, but calibrations with Midas 98:2 proved to be far more difficult with our exis ting fumigation equipment (this is he reason why the Symmetry Unit was used in fall 2008), and so the results with Midas 98:2 should be viewed as preliminary data (the study was essentially repeated in fall 2008 using the Symmetry equipment from Florida).

All the plots were seeded with yellow nutsedge nutlets at 20 nutlets/square ft prior to fumigation, except for treatment no. 14. . Fertilization (N at 60 lb/A, P at 50 lb/A and K at 60 lb/A) was applied before fumigation in all plots. The experimental de signs used was randomized complete block designs with four replications, and individual fumigated plots were 80 ft in length and then these were cutback to 40 ft in length 2 weeks following fumigation. The center 20 ft were used

for harvest data collecti on in spring 2008. There were 56 plots in total.

On 10/11/07 each 20 ft raised bed was planted with two rows of plants, staggered 12‖ apart within each row (total of 40 plugs per plot). The variety was Chandler, and the source of plugs

was Aaron‘s Creek in Buffalo Jct., VA (their source of tips was from Prince Edward Island

– Westech).

Row covers were purchased for this study in case of any severe freeze protection requirements (whenever temperatures below

– 9 o C are forecasted), but the winter was rela tively mild and plant growth was excellent. In the early spring we relied on the row covers for for frost control of blossoms, and there was only one occasion when sprinkling on top of the covers was needed. Blossom losses to cold weather were very minima l.

In the spring 2008, plants were harvested two times each week from mid

- April through the end of May (usually 14 harvests). Berries were field picked and graded (less than 10 g are considered culls, and also any misshapen fruit, or berries infected wi th gray mold were also considered culls). At each harvest, total weights, cull weights and marketable fruit weight was recorded and 25 berry weights are for calculation of average berry weight. All data was recorded by Rocco Schiavone, Research Associate

.

Results and Economic Implications. Total and marketable yields were significantly greater for fumigated soil than the untreated control treatments (No. 12

- 14). Midas 50:50 at the 180 lb/A broadcast rate with standard plastic, and Midas 50:50 at the 12 0 lb/A broadcast rate with VIF had the highest yields in the study, but were not significantly different from methyl bromide at 175 lb/A with VIF (Table 2). It is very interesting that the lower rate of Midas 50:50 (120 lb/A with VIF) was significantly h igher in total and marketable yield than Midas 50:50 at the 140 and 160 rates with VIF (Table 2). Also, the 180 lb/A rate (with VIF) was 7,272 lb/A lower in marketable yield than the 120 lb/A rate of Midas 50:50 (with VIF).

The 120 lb/acre broadcast rate of Midas 50:50 would indicate that only 60 lb/acre of this product would be required for shank treatment in

- the

- bed in North Carolina, where a 5‘ row center isAppendix

USG Preplant Replies Spring 2009 Page 35 standard and the plastic mulch covered beds occupy 50% of an acre. The total cost for Midas

fum igation at this rate (120 broadcast) is $1,123/acre ($540 for fumigant and $583 for VIF). This estimate of $1,123/acre assumes a cost of $583 for VIF plastic/A (3.6 rolls 2,400 ft at $162/roll), and that Midas 50:50 is priced at $9.00/lb ($9 x 60 = $540 ). There is little economic

difference between the use of Midas 50:50 at 120 lb/A with VIF and Midas 50:50 at 180 lb/A with standard film. The total cost for Midas 50:50 at the 180 lb/A broadcast rate (90 lb for strip fume x $9/lb = $810) with standard pl astic use is about $1076/acre, or about $47 less than using

Midas 50:50 at the 120 broadcast rate with VIF.

The control with VIF (No. 13) produced a marketable yield of 17,545 lb/A, or about 60% of the yield of the M50:50@120lb VIF treatment (29,255 lb/A) . This would have led to a per acre loss in revenues of approximately $11,710/acre, assuming an average berry price of $1.00/lb. The most recent enterprise budget for the NC Strawberry Plasticulture system (October 2008) assumes a price of $1.00/lb for p ick

- your

- own and $1.50 for ready pick. Thus, the net benefit of using Midas 50:50 at 120 lb/A with VIF could easily exceed $10,000 per acre in extra profits for the grower compared to no fumigation. This much economic benefit from fumigation would not

li kely be observed on sites where good crop rotation is possible, but on sites where rotation is not possible, a serious crop reduction may occur for growers who do not fumigate. The soil at Clayton Central Crops, where this trial was conducted, is a Norfol k sandy loam, and it has had 3 years of continuous strawberries (including the 2007

- 2008 season).

Table 2. Total yield, marketable yield, berry size, crown number, root vigor and percent root discoloration of Chandler plug plants grown with 2 Midas formu lations at multiple rates, Central Crops Research Station, Clayton, NC 2007

- 2008.

Treatment No., Total yield Marketable yd Berry Crown Root % Root Product, rate,. z & film (lb/acre) (lb/acre) size (g) no. Vigor w Discolor

11. M50:50@180lb Std. 31,409 a x 29,584 a 17.7 5.8 3.9 26.2 c

05. M50:50@120lb VIF 31,216 a 29,255 a 17.6 5.3 3.2 45.0 abc

09. MeBr 50:50@175lb VIF 28,298 ab 26,560 ab 18.2 4.4 3.6 35.0 bc

06. M50:50@140 lb VIF 27,003 bc 25,227 bc 18.0 4.5 3.5 41.3 bc

07. M50:50@160 lb VIF 26,130 bcd 24,451 bcd 18.2 3.8 3.5 36.3 bc

03. M98:2@ 80 lb VIF 25,615 bcde 23,723 bcde 16.6 5.4 3.8 47.5 abc

04. M98:2 @ 90 lb VIF 24,005 cdef 22,195 cdef 16.9 4.1 2.7 70.0 ab

01. M98:2 @ 60 lb VIF 23,699 cdef 22,015 cdef 16.5 4.3 3.4 53.8 abc

08. M50:50@180 lb VIF 23,343 cdef 21,979 cdef 18.2 3.6 3.3 50.0 abc

02. M98:2 @ 70 lb VIF 23,105 def 21,351 def 16.1 5.1 3.0 57 .5 abc

10. M98:2@ 90 lb Std. z 22,374 efg 20,717 efg 16.2 4.5 2.8 47.5 abc 14. Control Std. plastic 21,343 fg 19,882 fg 15.8 4.2 3.2 55.0 abc

13. Control VIF 19,149 gh 17,545 gh 15.7 3.7 2.4 78.8 a

12. Co ntrol VIF no nutgrass 17,017 h 15,877 h 17.8 3.2 2.2 68.5 ab

z broadcast rate/acre y

y This is a subjective vigor rating are how big/extensive the root system is (5=good) (1=poor)

x Means with the same letter are not significantly differ ent ( P < 0.05)

w This is a subjective rating of the % of the root system affected/discolored.Appendix

USG Preplant Replies Spring 2009 Page 36 A PPENDIX C (Strawberry Fruit ) Email from S. Toth, 11

- 4

- 2008

Responses to Information Request from EPA Regarding Iodomethane as a Replacement

for Methyl Bromid e on Strawberries (Field and Nurseries)

From: Victor Lilley, President, Reddick Fumigants of NC

We definitely need the methyl bromide CUE for 2011. There are still a lot of unanswered questions about the efficacy (at low rates/under various soil conditio ns/types and climate) of iodomethane. Very little Midas has been applied by end users under various conditions and it will take time to evaluate these concerns and address them. The bottom line is, we have not even had 12 months with full registration thus we don't have a good feel what all the problems and cost are associated with iodomethane. WE NEED the Methyl Bromide CUE FOR 2011. It is too soon to take away the safety net.

If you feel that MBTOC‘s assumption is not correct for the specific circumsta nces of your request it would be helpful for this nomination if you would provide information as to why iodomethane is not an acceptable alternative to methyl bromide. The following kinds of information would be appropriate:

1) Trials demonstrating yield losses when iodomethane is used.

Grower's that used Midas in 2008 can't really evaluate it until June 2009. There have

been reports already of nutgrass breakthrough and inability to apply Midas accurately at low rates (e.g., equipment problems). We need more time to evaluate were the problems

are at the end user level.

2) Information on costs, including the cost of additional machinery or cost of converting machinery [This cost should be provided as a full cost per acre, taking into account

diff erences in application rates for the primary ingredient, differing costs for associated chemicals, equipment and application cost, etc. Our current information, looking at a range of methyl bromide and iodomethane rates, suggests that the full app lication costs of each chemical system (including equipment, film, chemical combination) are approximately equivalent.]

The Midas rates may need to be higher to gain consistent control of nutgrass which will drive the cost/ac up. Increase cost/ac due to respirators, training and overall record keeping

and documentation management.

3) Differences in market timing (missed market windows), fruit quality, or

4) Other information that you feel is relevant to justify your critical need for methyl br omide.

Packagers and Distributors may have to increase their selling price on Midas to cover increased

maintenance cost on their cylinder fleet due to the product's corrosiveness. This would have a direct impact on the economically feasible aspects of fum igant comparisons.Appendix

USG Preplant Replies Spring 2009 Page 37 Any other information demonstrating the comparative efficacy of other alternatives to methyl bromide would also be helpful.

Victor Lilley, President Reddick Fumigants of NC, LLC

3002 West Main Street Williamston, NC 27892

800

- 358

- 8837 O ffice

252

- 792

- 1613 Office

252

- 792

- 4615 Fax

252

- 799

- 9038 Cell www.reddickfumigants.com

www.susanskids.com

From: Cal Lewis

1) Trials demonstrating yield losses when iodomethane is used.

On farm trials have not been done long enough to confirm that Midas can consistently provide yields that are commonly achieved with Methyl bromide/pic formulations. Research trials are not enough.

2) Information on costs, including the cost of additional machinery or cost of converting machinery [This cost should be provided as a full cost per acre, taking into account differences in application rates for the primary ingredient, differing costs for associated chemicals, equipment and application cost, etc. Our current information, looking at a range of methyl bromide and iodomethane rates, suggests that the full application costs of each chemical system (including equipment, film, chemical combination) are

a pproximately equivalent.]

Present cost of using MBR/PIC with VIF plastic is $400 to $450/acre. Present cost using Midas 50/50 is $600 + per acre. Present cost using Midas 98/2 is $700/acre.

3) Differences in market timing (missed market windows), fruit q uality, or

There have been experiences with Midas that risks phytotoxicity issues on plant back if long intervals between application & planting are not observed. If this occurs in NC, then there will be no time to plant back & achieve any reasonable yiel d the following spring. There are great risks involved with many small growers livelihoods at stake.

4) Other information that you feel is relevant to justify your critical need for methyl bromide.

Midas use in Georgia and Florida this past fall for som e crops has been very poor. There are growers using it for the 1st time in any appreciable quantity & have serious issues with control of nutsedge. The rates recommended & used are too low to achieve reasonable control. If higher

rates are used that actual ly achieve control, then the cost is way out of line.Appendix

USG Preplant Replies Spring 2009 Page 38 From: Cal Lewis

I did not send you comments for strawberry nurseries but feel evenly more adamantly that we cannot lose Methyl Bromide to Midas for Strawberry nurseries. Whatever the need for

straw berries & vegetables, is even more critical for plant nurseries in my opinion.

Cal Lewis

From: Phil Brannen, Plant Pathologist, University of Georgia

I do not have information available to answer these questions. I assume that Barclay Poling and

Fran k Louws are the main sources of information relative the cost:benefit of methyl bromide vs. iodomethane, as they have done the most work in this area. I have heard that the cost is substantially greater for the iodomethane, but with the reduction in methy l bromide stocks, I do

not know that this will continue to be the case. Likewise, most efficacy data has been pretty good with iodomethane. Therefore, I do not know that you can make a ―good faith‖ argument that iodomethane can‘t replace methyl bromide. Again, I somewhat speak without knowledge on this issue, and I would defer to others that have worked directly with side

- by

- side comparisons.

Phil Brannen

From: Frank Louws, Plant Pathologist, North Carolina State University

I would find it hard to argue that iodomethane is not an economically or technically feasible alternative for fruit and nursery production in strawberries. I suspect by 2011 most of our growers will transition to other fumigants. I do not have data to show iodomethane is a probl em and we have lots of data to show it works. The main challenge is for growers to apply such low rates reliably.

It would be productive to get feedback form Katie Jennings and Barclay Poling, too.

Frank Louws

From: Katie Jennings, Weed Scientist, Ho rticulture, North Carolina State University

I tend to agree with Frank Louws; however, I would like to hear what Barclay Poling thinks and how the growers feel.

Katie Jennings

From: Nancy Kokalis Burelle, Research Ecologist, U. S. Horticultural Researc h LabAppendix

USG Preplant Replies Spring 2009 Page 39 We have been working with Mi in cut flowers in Florida and have responded to the EPA on issues specific to ornamentals but the over arching issue with mi will probably be the cost. Effective rates are in the neighborhood of 300 lbs/a without VIF (be cause of the gluing issue with VIF and floriculture uses broadcast fumigation). I know Joe Noling and Rob Welker have some data on rates in strawberries under VIF that will be more useful to you. In flowers we have also seen a higher incidence of rogues, s ome mix cultivar interactions (phyto), and some instances of crop loss.

Regards,

Nancy Kokalis Burelle Research Ecologist

U.S. Horticultural Research Lab

2001 South Rock Rd. Ft. Pierce, FL, 34945 Phone: (772) 462

- 5861

Fax: (772) 462

- 5986

email: nancy.burelle@ars.usda.gov

From: Allen Straw, Virginia Tech University

I want to respond to all of the commodities with this one e

- mail. I have evaluated methyl iodide in the past and was please with the res ults. However, that was at 400 lb per treated acre of a 67:33 mix with chloropicrin with standard film.

This past season, I was very disappointed with what I saw in the field. This was in tomatoes, but I believe it could translate to most crops. The g rower had applied 80 lb of methyl iodide and 80 lb of chloropicrin/A with VIF film. At 6 to 7 weeks after planting nematodes and root pruning pathogens were causing enough damage that visible symptoms were evident in the plants (Blossom end rotted fruit a nd uneven plant growth). The adjacent area of the field treated with 300 lb of MeBr:Pic 50:50 showed no symptoms.

The company has always indicated that approximately 150 lb of methyl iodide is needed to control insects, diseases, and weeds at levels com parable to MeBr. However, the 80 lb rate is being used to keep the price at a level growers will even consider using it. At the rate it needs to applied, growers will not use it. If growers cannot afford to use it at the appropriate rates, then it

is no t a viable alternative.

The other problem we are having is that some of the VIF films are not holding up very well. In a couple of situations we actually saw the VIF tear worse during application. In a case or two I saw a small stones cause significant holes, where the traditional non

- VIF film would have

stretched over the small stones.

Allen StrawAppendix

USG Preplant Replies Spring 2009 Page 40 From: Debby Wechsler, North Carolina Strawberry Association

Below is a survey we did this fall on fumigant use by strawberry growers. I can't really res pond to the technical issues, but maybe this will be helpful. It is clear that most growers are still using methyl bromide, and only a few have even tried methyl iodide. It is a new product and especially with all the new regulations that also have to be absorbed, it is a huge amount of information and technology transfer to accomplish in a short time. The stuff has only just been approved! But it is also clear from our survey that growers are quickly adopting VIF. I have sent this survey to EPA as part o f our comment on the worker/bystander protection regulations.

Let me know if questions.

Debby Wechsler NC Strawberry Association

1138 Rock Rest Rd. Pittsboro, NC 27312 phone: 919

- 542

- 4037

fax: 866

- 511

- 6660 email: info@ncstrawberry.com

website: www.ncstr awberry.comAppendix

USG Preplant Replies Spring 2009 Page 41 North Carolina Strawberry Association Grower Fumigation Survey

This survey was conducted between August 16, 2008 and September 25, 2008 by the NC

Stra w berry Association. Growers were contacted primarily via email, with queries going not

onl y to NCSA members but non

- member growers for whom the association had email addresses.

Add i tional efforts were made to reach growers in North Carolina, with a few dozen queries sent via mail or fax to growers who had no email addresses. The survey was also published in the

Se p tember issue of The Strawberry Grower , the newsletter of the NC Strawberry Association. Most growers responded by email or fax. A few mailed responses and a few growers who happened to be in contact with the NC Strawberry Ass o ciation b y phone for other reasons, were invited to respond over the phone.

As of late September, 76 growers had responded. Responses came from many states: 45 from NC, 9 from VA, 7 from SC, and the remaining 15 from 9 other states. One response from a

Flo r ida f arm was discarded as being outside our area of concern. These responses represent fumig a tion and plantings this fall on a total of 480 acres. It is unknown what percentage of producers in North Carolina or other states responded, but the responses appear t o be representative of the totality of producers within the NC Strawberry Associ a tion‘s network.

Summary

Most of our growers are small. The average strawberry acreage of those responding is 6.3.

M e dian acreage is 3 (i.e., half were smaller, half were lar ger). 36 had less than 3 acres, 21 had 3

– 6 acres, 11 had 6.5

– 10, and 8 had over 10 acres. If; you remove the responses from the three

lar g est growers, whose acreage totals 175 acres, the average acreage is a little over 4 acres.

Methyl bromide is stil l the predominant fumigant. The vast majority

– 63 respondents or 83

percent

– are still using methyl br o mide/chloropricrin. Four are also experimenting on part of their acreage with Telone C

- 35 and two with Midas. Five growers have switched entirely to

Mi das. One is raising part of his acreage organ i cally. Of the others, five are using no fumigation. Some indicated that they are raising their fruit

o r ganically, and a few are carrying over plants from last year. One is applying Vapam via drip,

and one is us ing Telone C

- 17. Several growers, who hire out fumigation, didn‘t know what was

b e ing used.

Growers are changing to VIF plastic. Using VIF (very impermeable film) r e duces the amount of chemical that is needed because it escapes so much more slowly. 45 gr owers (59%) are using VIF plastic mulch this year in strawberries. Suppliers have reported that for most growers, this

will be their first e x perience using VIF.

Most growers do their own fumigation. Of those who fumigate, almost three

- quarters (73%)

do t heir own fumigation. 23% hire out fumigation, and 4% trade with another grower in an informal arrangement. Even most of the growers with the smallest acreage do their own fumig a tion: 65% of growers with under 3 acres in strawberries do their own fumigation

.Appendix

USG Preplant Replies Spring 2009 Page 42 Respirators are unfamiliar to most growers. Only 29% of respondents indicated that they had familiarity with using respirators, which will be required under the new regulations (and are

a l ready required for other products, e.g. Midas). The majority of growers reported that they have

4

- 6 workers in the field during fumigation

– all of these will need to be tested to make sure they can safely wear a respirator, fitted for respirators, and trained in their use. Some growers

co m mented on respirators in thei r responses.

One grower wrote, ―Respirators would make effective and efficient communication between the fumigation o p erator (tractor driver) and helper (the man on the fumigation rig) nearly impossible AND would make fumigation operations more dangerous due to the inability to communicate. I could understand requirement to have respirators available for ―emergencies‖ but 11 years experience doing my own fumigation makes me say they are NOT nece s sary for routine fumigation procedures.‖ Another grower wrot e, ―Have these regulators ever worked 10 hours a day in 90 degree heat with a respirator on?‖

Buffer zones will not affect some growers but will be devastating for others. In the survey, we summarized buffer regulations as follows: ―Proposed regulations include numerous buffer zone requirements: Buffer zones in the new regulations vary by chemical, application rates, size of acreage, and type of tarping. For example, using standard plastic and application rates for MB/Chloropicrin, buffers extend approx imately 200 ft. around the treated area for 10 acres, 100 ft. for 5 acres, and 25 ft. for one acre. No fumigant applications will be permitted within a quarter mile of schools, licensed day

cares, nur s ing homes, hospitals, etc. Only authorized handlers who are properly equipped may be in the buffer zones for a minimum of 48 hours after fumigation is finished. Occupied buildings may not be in the buffer unless occupants voluntarily vacate the buffer

zone du r ing the entire period.

How will buffers like this affect your strawberry operation?‖

Approximately a quarter of growers reported no effect of the buffers. Another quarter either

didn‘t r e spond or didn‘t know how they would affect them. About half reported some negative effect of buffers ranging fro m ―will cut some acreage‖ to ―will put us out of the strawberry

bus i ness.‖ Several growers have fields within the quarter

- mile buffer required for schools, nursing homes, and similar institutions. The specific c o mments from growers reporting adverse

affect s of buffers are excerpted below.

Grower Comments on Effects of Buffer Zones



These buffers effectively cut our PYO operation by 30

- 40% because of the location adjacent to our market with limited ability to rotate land. If these regulations are put in effect, we could lose up to $15,000 in berry sales in addition to lower sales o f other items with less PYO traffic. If all these new buffers go into effect we will have to relocate our strawberry operation to

a n other location. We are in a small town and less than .25 miles from a school.Appendix

USG Preplant Replies Spring 2009 Page 43 At least two homes would be within a 200

- ft. buffer. There is no way they would leave for more

than a few hours.

We will no longer be able to fumigate. We have only 76 acres on the farm and we are surrounded by houses.

They [buffer zones] will shut us down.

Will not be able to fumigate because of nearby daycare.

Total devastation! We are located on a major highway with a great location. We have two fields with road frontage, and we alternate these fields. One field is 100 feet from a church the other 1000 from a supermarket and Wal

- Mart. We have invested a tremendous amount of money in these fields. How can they do this to us?

We have buildings within 25 feet of some fields.

Buffer zones will greatly affect my farm in a negative way. They will possibly make me lose up to 1/3 of my planting if t he current buffer zone restrictions go into effect. My farm is located in a quickly growing area with neighborhoods coming in on all sides of me. I am very limited in acres already and buffer zones will limit that even more.

Will make raising strawberries very difficult, almost impossible.

It will cause an increased cost of moving from road frontage fields with accompanying expense of reestablishing irrigation. It would be a major expense!

We plant within 50 ft. of a highway right of way.

We will have t o close one location because it is within 1/4 mile of a school.

May have to stop farming strawberries if a proposed daycare is built.

Proposed buffer zones will put our farm out of business. We have been growing strawberries for over 20 years n the same property. We have made significant investments of 2 large farm

buil d ings, over 20,000 feet of drainage tile and a 6 million gallon irrigation pond, moving over 30,000 cubic yards of soil.

About 5 years ago, a home for physically and mentally disadvantaged persons moved into the area. This would be within 1/4 mile of most of our fields. There needs to be a grandfather clause to protect those who have made significant investments and were there first. Any grower could be put out of business by a daycare open ing up across the street from them.

Several years ago, I read an article about people moving out of a large town into a rural area near a dairy and then complaining about the odor and trying to get the dairy put out of

bus i ness. The court ruled that the dairy was there first and it was protected by a federal law sinceAppendix

USG Preplant Replies Spring 2009 Page 44 it was there first. The same needs to happen here. Buffer zones protect those outside agriculture. What about the rights of farmers to make a living?

No more strawberries.

Currently, we pl ant within 15 feet of our property line. Any buffer at all will cut down on the size of our planting.

It will make many of the fields planted now unusable because of size and closeness to

subdiv i sion. It will hamper my rotation, and will cause me to plan t strawberries in fewer fields, therefore increasing my use of fumigants. It could even cause me to rethink and possibly stop raising strawberries or stop farming totally. As I get older developers‘ prices look better compared to the constant regulatory r estraints imposed on farms and farming operations. If my own home, my personal residence, is in a buffer zone are you telling me I can not sleep in my own home on my own farm if I choose to plant strawberries in the field next to my

driv e way?

50% of fiel ds will have to be cut 20% to 40 %. Profit margin will be cut 10 to 20%, already operating @ less than 10% profit margin. Bottom line is that this regulation on top of all the others that we have to comply with could actually put our farm out of business. Have these regul a tors ever worked 10 hours a day in 90 degree heat with a respirator on?

The requirement about homes and buildings may negatively affect our operation.

These buffer zones will kill my business. I have a school and nursing home across the street. Of course, we were here first, so I don‘t know if we could get grandfathered in or not. I kind of doubt it. In a time where local govt. agencies are pushing for local produce to be produced near the consumers, I think this is "over kill‖ on rules and regulations. This should be fought with all due vigor! Maybe, on a compromise, the small acreage could come into play. Saying the "no

f u migant" rule apply to acreages application over 5 acres or so. My entire farm is within a quarter mile of this area.

It would force me to buy other land for my Strawberries. We have a church school nearby and our strawberry patch is about 300' from the school building. Would these schools be state run, or any school. What about fumigating on the weekends when the child ren aren't at school?

Will eliminate some acreage.

We have an occupied house within the buffer of 100 ft of a 4

- acre field. I do like VIF film and maybe the buffer could be reduced if VIF is used .

Not a problem at current site, but will make it difficult to rotate to other sites.

Will make almost impossible to fumigate.

Submitted by:Appendix

USG Preplant Replies Spring 2009 Page 45 The North Carolina Strawberry Association

1138 Rock Rest Rd. Pittsboro, NC 27312 www.ncstrawberry.com info@ncstrawberry .comAppendix

USG Preplant Replies Spring 2009 Page 46 A PPENDIX D (References)

See attachment