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 -FIELD........................................................................................ 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

USA GENERAL

I, In 2006 the Party stated that"... While many field research 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 that fumigant emissions can be substantially reduced with the use of 

LPBF's. However, the few large 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 high 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 its 
USG 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-Tov, 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 

Application of Metam Sodium and Metam Potassium. Available online at: 

http://www.mbao.org/

1. California)! DPR data showrs substantial increase in consumption of metham potassium 

for use in California. In 2006, approximately 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 Pesticide 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 metamsodium 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 867,911 405,960 905,309 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 

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

Note: Usage 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 Pesticide 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 2004 2005 2006 2007

CHLOROPICRIN 1,723,173 1,725,506 1,679,155 1,733,960 1,849,674 
USG 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: Usage 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

References for each individual Critical Use 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 Pesticide 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 economic 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 (ie the application rate per hectare, the 

product costs and other variable costs used to calculate these 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 

economic 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 101 kg/ha broadcast, 

metam sodium at 215 kg/ha broadcast and 1,3-D at 115 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 Application 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 Prices: $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 fumigants 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 that 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 parameters 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 constraints, if known. The complexity of the process 

makes it impossible to use the Party-determined amount as a starting point although the 
USG Preplant Replies Spring 2009 Page 5

incorporation of the transition amount always results in a request that is below the previous total 

US request reflecting the growing uptake of alternatives until the point where a technical or 

economic maximum is reached.

When a new alternative becomes available, or when new information from full-scale commercial 

trials become available, a new Delphi process is conducted 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 affecting 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 following 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), 

Tylenchorhynchus 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 hapla, 

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 (Meloidogyne 

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 nematodes 

(Meloidogyne spp)

Pepper Root knot nematodes 

(Meloidogyne spp)

Tomato Root knot nematodes 
USG 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.

USA CUCURBITS – FIELD

 a. In the 2007 round of MBTOC questions, the Party stated that "... the USG has been 

Informed by The Florida Fruit and Vegetable Association that individual vegetable 

growers are trying metalized films, sometimes in combination with 50/50 methyl bromide 

mixtures. Many cucurbit growers in Georgia have also reported using 53 % methyl 

bromide: 47 % chloropicrin mixtures recently. However, they have apparently not yet 

begun testing metalized films. Mr. Terrey Keliey, of the University of Georgia, provided, 

this information. He also reported that "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 metalized 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."

USG 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 are 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 

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

However, 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 applicants 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 successful 

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 cucurbit 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 rootstock. 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, grafting 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 species 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.

USA EGGPLANT - FIELD

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

In Georgia and Florida, using the 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 not 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 incorrect 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 

exist‖. 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. Please 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 statements 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 table 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 to 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 eggplants 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 production is based on double cropping production practices. 

USA 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 is 

easier and a much higher number of plants can be produced per unit area. Are there any 
USG Preplant Replies Spring 2009 Page 9

studies or trials being conducted in this respect? MBTOC 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

Experts 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 constantly 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 shortened" 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 

production. 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 

that 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 with 

USDA/ARS researchers.

USA FOREST 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 disaggregate 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 nurseries. 

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 ―mandated‖, 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 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.

3. Could the Party' please indicate the area to be treated on the basis of mandatory use of 

MB and those requiring the crop to be "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 MBTOC 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 limitations. 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 CUN states the Midas 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 uncertainty. Can 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 conifer 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 

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

―we 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 Fall.‖ 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 one 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 keeps 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 technology 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 including 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 2005-2006. 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 at 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 forest 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, see 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 USDA/ARS Oregon State University 

Nursery Coop study evaluating a range of treatments including MI-Pic (VIF and HDPE), MetamSodium-Pic (HDPE), DMDS-Pic (HDPE) in comparison to MB-Pic (HDPE) in three bare-root 

nurseries. Results from this trial are still awaiting 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-fumigation 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 resolved, 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 ORCHARD 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-Dichloropropene 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 township 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 township 
USG Preplant Replies Spring 2009 Page 13

per year. Between 2002 and 2005 there were eight counties (Fresno, 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 track 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 replant 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 regulatory 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 

completing 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 fruit replant problems without 

MB; 2) Provide comprehensive economic assessments of alternative replant management 

strategies; 3) Educational 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 provide full cites to studies referenced in the CUN 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 Response
USG Preplant Replies Spring 2009 Page 14

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, 

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, Gianessi 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. Contractor 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., Katayama, 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/hectare) 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 the 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 Table 

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 Establishment -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 61,331 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. (2002), 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. 

2

In addition to operating costs, non-bearing costs include replanting trees.

3

Initial production is 10% of full production. 

4

Production in the 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 tables 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 orchards 

under four treatment options. However, table 5 shows only 2 treatment options. Please 

report the data for the other two options.

USG Response
USG Preplant Replies Spring 2009 Page 17

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

were lower. Therefore, 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), and 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 62 -82 -164 -1,208

7 Full production 61,028 904 779 -310

8-40 Full production 71,028 904 779 562

NPV (7% discount rate) -874 -1,529 -4,399 -5,489

IRR 6.3% 5.7% 3.7% 2.0%

Source: Buchner et al. (2001), 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

Production is 67% of full production with 1,3-D alone.

7

Production ceases one year earlier with 1,3-D alone.

8. Page 15 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 value 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 page 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 adopted 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 from 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 operating revenue. 

Table 3: New York Anemones - 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.$) 892,050 810,863 718,199 625,534

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 estimates. 

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 Operating 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

TABLE 4: FLORIDA CUT FLOWERS - LILIES - ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES

Florida Cut Flowers - Lilies METHYL 

BROMIDE

IODOMETHAN

E + PIC (98:2)

YIELD LOSS (%) 0 0 

 YIELD PER HECTARE 31,135 31,135

* PRICE PER UNIT (U.S.$) 10 10

= GROSS REVENUE PER HECTARE (U.S.$) 311,353 311,353

- OPERATING COSTS PER HECTARE (U.S.$) 262,715 264,445

= NET OPERATING REVENUE PER HECTARE (U.S.$) 48,638 46,908

1. LOSS PER HECTARE (U.S.$) 0 1,730

2. LOSS PER KILOGRAM OF METHYL BROMIDE (U.S.$) 0 4

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0 1

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 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 some 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 agricultural 

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 would be required to obtain permission to conduct a 

survey from the Office of Management and Budget, a process that could take a year. 

2. In Eastern region, what has been the transition, rate to iodomethane 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 distributers 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 CUN 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 support 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 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.‖ 

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 Response

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 costs and gross 
USG Preplant Replies Spring 2009 Page 22

revenue were transposed in that column so that although 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 email 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/Pic 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 inadvertently 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 comparing 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 critical use. 

Yield loss estimates were calculated based on pest pressure, location differences, cultivar 

differences, and, especially for 1,3-D, soil moisture and texture characteristics. Consequently, 

while there are alternatives in some trials that may provide 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 in 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 2011. 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 MetaAnalysis of Strawberry Yield Response to Preplant Soil Fumigation with Combinations of 

Methyl Bromide-chloropicrin and Four Alternative 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 clarify?
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+PIC?

USG Response

This column should have been deleted from the analysis. This is not a viable alternative in 

California given the large buffers that are currently required by the State of California when Pic 

is used. The corrected table is below:

TABLE 5. CALIFORNIA : ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

CALIFORNIA METHYL 

BROMIDE

1,3 D + PIC

PRODUCTION LOSS (%) 0% 14%

 PRODUCTION PER HECTARE 49,410 42,475

* PRICE PER UNIT (US$) $ 1.37 $ 1.37

= GROSS REVENUE PER HECTARE (US$) $ 67,537 $ 58,057

- OPERATING COSTS PER HECTARE 

(US$)** $ 66,849 $ 66,100

= NET REVENUE PER HECTARE (US$) $ 688 ($ 8,042)

1. LOSS PER HECTARE (US$) $ 0 $ 8730

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $ 0 $ 43.51

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 13%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 1269%

5. OPERATING PROFIT MARGIN (%) 4% -14%

**Note that the measures in the tables below must be interpreted carefully. Operating costs do 

not include fixed costs and net revenue equals gross revenue minus operating costs.

USA STRAWBERRY 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) in order to minimize the prospect of spreading 
USG Preplant Replies Spring 2009 Page 24

these pests to other 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 insect 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 language. All nursery 

regulations, however, attempt to provide growers with healthy stock plants that ensure growerconfidence that unfit starting material will not end their season before it begins. 

Progress is being made by researchers. However, until 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., GarcíaMéndez 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://nationalplantboard.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 various 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 pest 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 recordkeeping 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 the 
USG Preplant Replies Spring 2009 Page 25

requirements 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

García-Méndez, E., García-Sinovas, D., Becerril, M., De Cal, A., Melgarejo, Pl, Martínez-Treceño, A., Fennimore, 

S. A., Soria, C., Medina, J. J., and López-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. What 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 according 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 Agriculture‟.

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 individual 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 North Carolina it claims that 'A plant inspection certificate shall 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 

inspection 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%20Certification%20Standards.pdf; 

http://www.ncagr.gov/plantindustry/plant/nursery/lictbl.htm; 

http://nationalplantboard.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 government. 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 satisfies 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 portion of nursery soils that 

produce transplant requiring methyl bromide, but not designated QPS'.

Could the Party please explain the difference between the MB use amount requested 

under the 'critical use' process and those designated QPS.

USG Response

Under 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, therefore, 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 critical 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 experience 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 overall, 

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?

USG 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 disease 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 determine 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", but 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 substantial 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. Unlike 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) could 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, were 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 Vapam (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 February 28, 2008 and Devrinol & Valor 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 

treatments 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 hand 
USG Preplant Replies Spring 2009 Page 29

weeding times, which clearly shows the solar and untreated plots needing 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 and 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, iodomethane 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, 

suggest 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 

considered 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 determine 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 percent 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 each 
USG 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 measures 

were reached, an overall assessment was made which included the individual measures.

2. A transition for 2010 is given by the BUNI‟s. Please explain how these transition rates 

were obtained.

USG Response

Please see transition discussion (above).
Appendix

USG Preplant Replies Spring 2009 Page 31

APPENDIX 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, Department of Horticultural Science, 

North Carolina State University

Steve Toth, IPM Coordinator and Extension Entomologist, Department of 

Entomology, North Carolina State University

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

production members for reasons stated in this 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 the 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, this document helps to further explain our 

reasons for wishing to 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 registered 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 total 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 some 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 control. 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 to 
Appendix

USG Preplant Replies Spring 2009 Page 32

gain consistent control of nutsedge, and this could significantly add to the cost of Midas usage. 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) did 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 trying 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 application 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 bromide 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 applications 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 November 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 Association, 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 Fruit 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 management. 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 handle 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 next year as Packagers 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 these 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. It is simply too early to tell for sure.
Appendix

USG Preplant Replies Spring 2009 Page 33

APPENDIX 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 Poling

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. 35o7‘ N, long. 

78o5‘ 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 the 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

Treatment 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 + Standard 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 Midas 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 volume of Midas 
Appendix

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 provided 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 existing 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 designs 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 collection 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 relatively 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 minimal.

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 with 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 120 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 higher 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 is 
Appendix

USG Preplant Replies Spring 2009 Page 35

standard and the plastic mulch covered beds occupy 50% of an acre. The total cost for Midas 

fumigation 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 plastic 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 pick-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 

likely 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 Norfolk 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 formulations 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. Vigorw Discolor

11. M50:50@180lb Std. 31,409 a x29,584 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.z22,374 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. Control VIF no nutgrass 17,017 h 15,877 h 17.8 3.2 2.2 68.5 ab

z

broadcast rate/acrey

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 different (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

APPENDIX C (Strawberry Fruit)

Email from S. Toth, 11-4-2008

Responses to Information Request from EPA Regarding Iodomethane as a Replacement 

for Methyl Bromide 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 conditions/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 circumstances 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

 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

 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 bromide.

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 fumigant 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 Office

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

 approximately 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 quality, 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 yield 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 some 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 actually 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 

strawberries & 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 

Frank 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 methyl 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 problem 

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, Horticulture, 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 Research Lab
Appendix

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 (because 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, some 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 results. 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 grower 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 and 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 comparable 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 not 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 Straw
Appendix

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 respond 

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 of 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.ncstrawberry.com 
Appendix

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 

Strawberry Association. Growers were contacted primarily via email, with queries going not 

only to NCSA members but non-member growers for whom the association had email addresses. 

Additional 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 

September 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 Association by 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 

Florida farm was discarded as being outside our area of concern. These responses represent 

fumigation 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 to be 

representative of the totality of producers within the NC Strawberry Association‘s network.

Summary

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

Median acreage is 3 (i.e., half were smaller, half were larger). 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 

largest growers, whose acreage totals 175 acres, the average acreage is a little over 4 acres.

Methyl bromide is still the predominant fumigant. The vast majority – 63 respondents or 83 

percent – are still using methyl bromide/chloropricrin. Four are also experimenting on part of 

their acreage with Telone C-35 and two with Midas. Five growers have switched entirely to 

Midas. One is raising part of his acreage organically.

Of the others, five are using no fumigation. Some indicated that they are raising their fruit 

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

and one is using Telone C-17. Several growers, who hire out fumigation, didn‘t know what was 

being used.

Growers are changing to VIF plastic. Using VIF (very impermeable film) reduces the amount 

of chemical that is needed because it escapes so much more slowly. 45 growers (59%) are using 

VIF plastic mulch this year in strawberries. Suppliers have reported that for most growers, this 

will be their first experience using VIF.

Most growers do their own fumigation. Of those who fumigate, almost three-quarters (73%) 

do their 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 

fumigation: 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 

already 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 

commented on respirators in their responses. 

One grower wrote, ―Respirators would make effective and efficient communication between the 

fumigation operator (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 necessary for routine 

fumigation procedures.‖ Another grower wrote, ―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 approximately 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, nursing 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 during 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 respond or didn‘t know how they would affect them. About half reported some negative 

effect of buffers ranging from ―will cut some acreage‖ to ―will put us out of the strawberry 

business.‖ Several growers have fields within the quarter-mile buffer required for schools, 

nursing homes, and similar institutions. The specific comments from growers reporting adverse 

affects 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 of other items with less PYO traffic.

If all these new buffers go into effect we will have to relocate our strawberry operation to 

another 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 the 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 to 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 

buildings, 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 opening 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 

business. The court ruled that the dairy was there first and it was protected by a federal law since 
Appendix

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 plant 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 

subdivision. It will hamper my rotation, and will cause me to plant 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 restraints 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 

driveway? 

50% of fields 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 

regulators 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 

fumigant" 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 children 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.com
Appendix

USG Preplant Replies Spring 2009 Page 46

APPENDIX D (References)

See attachment