Page 1 of 17

RESPONSES TO QUESTIONS FROM MBTOC S ON 2011 CUNS FOR 

USE IN 2013 – UNITED STATES

Received from MBTOC March 4, 2011

Last update March 10, 2010

MBTOC Question 

1..Please note that Ex.I/3(5); XVI/2(4); XVII/9(5)), XVIII/13(6), XIX/9(7), XX/5(7), XXI/11(6) 

and XXII/6(5) request Parties to submit by 1 Feb info on how criteria in IX/6(1) is met when 

licensing permitting or authorizing CUEs. Could you please provide clarification of your 

response to this Decision? 

USG Response

This information was transmitted to the Ozone Secretariat on March 9 by the EPA. The package 

included: 1) a table listing the updated registration status of methyl bromide alternatives, 2) a 

description of the methodology used in determining economic feasibility, 3) the 2010 allocation 

rule which contains a description of the USA application of IX/6 when licensing methyl bromide 

in 2010 and the manner in which inventories are managed, 4) a summary of the critical use 

nominations for calendar year 2013, and 5) the accounting framework for 2010 critical use 

methyl bromide. 

Vegetables General 

MBTOC Question 

1. In the previous nominations in past years, rates vary according to the crop: In the nominations 

for 2013, the rates are similar for all the vegetables (150 kg/ha). If these reported figures in 

the tables are correct, please explain why they are all now based on the same rate? 

USG Response

Starting in the 2010 nomination documents, for use of methyl bromide in 2012, the U.S. used 

similar rates for the vegetable crops. We have used 125 kg MeBr/ha for all of the vegetables 

(see Appendix A) for corrected nomination tables. There are some inconsistencies with the 

number presented in the chapters and we have recalculated the numbers for all of the nominated 

sectors. 

MBTOC Question 

2. The transition rate is similar for all vegetables even though the availability of some chemical 

and non chemical alternatives appear to be apparently different. How was the transition rate 

for all vegetable nominations (80%) calculated? 

USG Response

As part of the 2011 methyl bromide Critical Use Exemption (CUE) process, for use in 2013, the 

U.S. government was contacted by several applicants who asserted that some alternatives were 

not providing consistently effective control or that it was too expensive to convert their 

fumigation equipment to use the alternatives. This information was provided at the end of the 

process for preparing the CUE nomination packages and supporting technical and economic 
Page 2 of 17

information had not been collected by those applicants. Therefore, the USG cut all these sectors 

by 80% while waiting for them to provide information to substantiate these claims. The 

applicants are collecting the information and the USG will provide this information to MBTOC 

prior to the OEWG. 

MBTOC Question 

3. What is the registration status of DMDS on the different vegetables?

USG Response

Dimethyl disulfide (PaladinTM and Paladin ECTM) have federal registrations and are currently 

registered in 18 states (listed below). Registration is pending in three states that have requested 

Critical Use Exemptions in the past (CA, FL & NY). The registered use sites include: fruiting 

vegetables (eggplant, pepper, tomato), cucurbit crops (cucumbers, melons [all], squash [all]), 

small fruit crops (blueberry, caneberry, strawberry), field grown ornamentals, and forest nursery 

crops. Rates of the 98:2 formulation range from 310 to 455 pounds of Paladin formulation per 

treated acre. One concern about the adoption of DMDS is the odor issue. The registrant and 

distributor are currently working on techniques to reduce the odor. 

AR AZ GA IN

KY MD MI NC

NJ NM OH OR

PA SC TN TX

VA WA

US Cucurbits 

MBTOC Question 

1. Are there any research trials being conducted for this sector? 

USG Response

Several studies have been conducted in recent years and many continue to be. To illustrate recent 

research not captured in previous years’ nominations, provided below is a selected list of 

research reports from the Proceedings of the 2010 Methyl Bromide Alternatives Outreach 

(MBAO) Conference, which are available on the internet at 

http://mbao.org/2010/Proceedings/Methyl%20Bromide%20Phaseout%20--

%20Proceedings%20of%202010%20Alternatives%20Research%20Conference.htm.

Bausher, M. G. and D. O. Chellemi. 2010. Performance of Grafted Tomatoes in Open Field Trials at 

Two Locations in Florida.

Driver, J.G. and F. J. Louws. Evaluation of non-fumigant based and drip applied nematicides to 

manage root-knot nematode (Meloidogyne spp.) on yellow squash.

Freeman, J., M. Paret, T. McAvoy, S. Olson, and S. Rideout. 2010. Utilization of grafted tomato 

seedlings for bacterial wilt resistance in open field production.

Kokalis-Burelle, N., E. N. Rosskopf, and M. G. Bausher. 2010. Grafting for control of Meloidogyne 

incognita on bell pepper, tomato, and melons.

MacRae, A. W. , G.Vallad, and J. W. Noling. 2010. Evaluation of all Components of the 3-WAY 

Fumigant System for use in Central Florida Tomato. 
Page 3 of 17

Vallad. G., A. W. MacRae, T. Jacoby, and J. W. Noling. 2010. Sustainability of methyl bromide 

alternatives – tomato and pepper initial crop. 

Welker, R.M., J.G. Driver, C.L. Rivard and F. J. Louws.2010. Outreach and new approaches for 

methyl bromide alternatives through the USDA area-wide project. 

Studies done in southern U.S. tomato and pepper production systems are also included in the list 

above, because these systems are similar to southern U.S. cucurbit production in terms of soil 

environment, key pests, etc. Research done prior to 2010 was summarized in the USG 

nominations submitted in 2009 and earlier. Therefore, it is not reproduced here.

MBTOC Question 

2. What specific alternatives other efforts are there to adopt alternatives for the remaining 

nomination?

USG Response

As indicated by the partial list of studies described in the response to the previous question, there 

are ongoing efforts to evaluate and eventually adopt several alternatives in commercial U.S. 

cucurbit production. These include the use of alternative fumigants, alone and in combination. 

These approaches appear to be the most feasible, and include 1,3-D + chloropicrin, metamsodium, and the sequential application of these materials known as the “Georgia 3-way”. 

Iodomethane formulated with chloropicrin and DMDS are other newly available alternatives that 

the industry is working to adopt as methyl bromide alternatives. 

There is also ongoing work to explore the use of grafting resistant cultivars and drip-applied 

nematicides as methods to control specific pests in specific conditions. While these are not 

apparently ready for large-scale commercial utilization, they are part of the long-term effort to 

adopt a variety of methyl bromide alternatives.

US Peppers 

MBTOC Question 

1. The proposed rate for 2013 (150 kg/ha) is higher than the proposed rate for 2012 (125 kg/ha).

MBTOC wonders whether this rate increase result from spelling mistake or an actual 

increased rate. 

USG Response

MBTOC is correct the rate should be listed as 125 kg MeBr/ha for all of the vegetables (see 

Appendix A) for corrected nomination tables. There are some inconsistencies with the number 

presented in the chapters and we have recalculated the numbers for all of the nominated sectors. 
Page 4 of 17

US Eggplant 

MBTOC Question 

1. When is Iodomethane is expected to be registered on eggplant? 

USG Response

While early research has suggested that this may be a suitable use for this fumigant the 

EPA/Office of Pesticide Programs has not received a request to register iodomethane for this 

crop. 

MBTOC Question 

2. Are there any research trials being conducted for this sector? 

USG Response

Several studies in vegetable production systems similar to eggplant have been conducted in 

recent years and many continue to be. To illustrate recent research not captured in previous 

years’ nominations, provided below is a selected list of research reports from the Proceedings of 

the 2010 Methyl Bromide Alternatives Outreach (MBAO) Conference, which are available on 

the internet at http://mbao.org/2010/Proceedings/Methyl%20Bromide%20Phaseout%20--

%20Proceedings%20of%202010%20Alternatives%20Research%20Conference.htm. 

While these studies have not been done in eggplant specifically, the USG believes they are 

relevant to the portion of U.S. eggplant crops that are included in the nomination. This is because 

the growing conditions and the pest spectrum included in these studies appears to be similar to 

those in the eggplant sector under consideration here.

Bausher, M. G. and D. O. Chellemi. 2010. Performance of Grafted Tomatoes in Open Field Trials at 

Two Locations in Florida.

Driver, J.G. and F. J. Louws. Evaluation of non-fumigant based and drip applied nematicides to 

manage root-knot nematode (Meloidogyne spp.) on yellow squash.

Freeman, J., M. Paret, T. McAvoy, S. Olson, and S. Rideout. 2010. Utilization of grafted tomato 

seedlings for bacterial wilt resistance in open field production.

Kokalis-Burelle, N., E. N. Rosskopf, and M. G. Bausher. 2010. Grafting for control of Meloidogyne 

incognita on bell pepper, tomato, and melons.

MacRae, A. W. , G.Vallad, and J. W. Noling. 2010. Evaluation of all Components of the 3-WAY 

Fumigant System for use in Central Florida Tomato. 

Vallad. G., A. W. MacRae, T. Jacoby, and J. W. Noling. 2010. Sustainability of methyl bromide 

alternatives – tomato and pepper initial crop. 

Welker, R.M., J.G. Driver, C.L. Rivard and F. J. Louws.2010. Outreach and new approaches for 

methyl bromide alternatives through the USDA area-wide project. 

Research done prior to 2010 was summarized in the USG nominations submitted in 2009 and 

earlier. Therefore, it is not reproduced here.
Page 5 of 17

MBTOC Question 

3. What specific alternatives other efforts are there to adopt alternatives for the remaining

nomination?

USG Response

As indicated by the partial list of studies described in the response to the previous question, there 

are ongoing efforts to evaluate and eventually adopt several alternatives in commercial U.S. 

eggplant production. These include the use of alternative fumigants, alone and in combination. 

These approaches appear to be the most feasible, and include 1,3-D + chloropicrin, metamsodium, and the sequential application of these materials known as the “Georgia 3-way”. 

Work on drip-applied nematicides as methods to control specific pests in specific conditions 

conducted in other vegetable crops may also be applicable to U.S. eggplant production. While 

these are not apparently ready for large-scale commercial utilization, they are part of the longterm effort to adopt a variety of methyl bromide alternatives.

U.S. Fruit, Nut, and Flower Nurseries 

No questions

USA Orchard Replant 

MBTOC Question 

1 Iodomethane has been registered in California since December 2010. Can the USG give 

reasons why MI has not been considered as an alternative in the CUN for 2013? 

USG Response

Iodomethane, which may be an effective alternative, was registered in December 2010 in 

California but at lower use rates than the rest of the U.S. and with buffer distances up to 10 fold 

greater (e.g. Browne et al., 2010, Cabrere et al., 2010). We didn’t calculate, for use in 2013 what 

the effectiveness of lower rates might be or the impact of the buffers. 

Browne, G., Lampinen, B., Doll, D., Holtz, B., Updahyaya, S., Schmidt, L., Wang, D., Fennimore, S., 

Hanson, B., Gao, S., Klonsky, K., and Johnson, S. 2010. Integrated pre-plant alternatives to 

methyl bromide for almonds and other stone fruits. Annual International Research Conference 

on Methyl Bromide Alternatives (2010). Available online at 

http://mbao.org/2010/Proceedings/028BrowneG.pdf. 

Cabrera, J.A., Gan, J., Hanson, B.D., Wang, D. 2010 Factors affecting the nematicidal activity of 

dimethyl disulfide. Annual International Research Conference on Methyl Bromide Alternatives 

(2010). Available online at http://mbao.org/2010/Proceedings/005CabrereaA.pdf. 

MBTOC Question 

2 MBTOC acknowledges the substantial reduction in the use of methyl bromide for replant 

particularly for 2012 and 2013. Can the USG indicate what alternatives/methods will be 

employed to effect the final transition and can these not now be extended to eliminate or 

further reduce the dependence of MB for Replant?
Page 6 of 17

USG Response

Presumably the final transition will involve the incorporation of iodomethane and possibly (if 

registered) DMDS in addition to adoption of some non-fumigated methods (steam) that will 

require use of specialized equipment and extensive education. Ongoing research (e.g. steam, 

iodomethane, DMDS, tarp technologies, individual tree-hole applications) should support the 

future adoption by growers after 2013. 

USA Ornamentals 

MBTOC Question 

1. What is the justification for use of a 20 g/m2 for Florida when the growers are using "hot gas" 

and VIF? Why is there a need for this dose? Do you have data to support use of this dose? 

USG Response

The US rates are based on information from the applicants. This rate covers uses in a wide 

variety of sites (greenhouses, shade houses, open fields, etc.) and a wide range of uses from 

pathogen control, to removal of the previous crop. The researchers in Florida have been focused 

on testing the alternatives (e.g. iodomethane, DMDS, steam, biofumigation, etc.) and not on 

testing reduced rates. 

MBTOC Question 

2· The total treated area in the nomination was reduced from 322 ha to 241 ha, however the 

amount of MB required is the same. Is this correct? Is the information in table 4 

(Nomination amount) correct? 

USG Response

The nomination is for a total of 48, 164 kg and 241 ha which is the same request as for 2010 (for 

use in 2012). There are some inconsistencies with the number presented in the chapters and we 

have recalculated the numbers for all of the nominated sectors (see Appendix A). 

USA Strawberry fruit 

MBTOC Question 

1.· Is it possible for the USG to provide a possible transition plan for phase out for this 

nomination. 

USG Response

At this time the USG does not have sufficient information to make this type of assessment.

MBTOC Question 

2.· Rate for 2013 CUN is 120 kg/ha, not 170 kg/ha as mentioned in the table 4. Rate for 2012 is 

shown 152 kg/ha as well. How was a rate reduction from 152 kg/ha for 2012 to 120 kg/ha for 

2013 achieved? 
Page 7 of 17

USG Response

The USG intention is to request a use rate of 170 kg of MeBr/ha for strawberry fruit for 2011, for 

use in 2013. This is the same use rate of methyl bromide that was requested in 2010, for use in 

2012. Please see Appendix A for updated BUNNI information. 

MBTOC Question 

3.· Is it possible to provide a table of which alternatives have been adopted in past years to 

reduce the nominations? What kinds of alternatives do growers use in the area where methyl 

bromide of critical use nomination is not used? And can you also list for each region why the 

alternative cannot be used? 

USG Response

The USG does not have information on the rate of adoption of individual alternatives for 

strawberry fruit. The California Strawberry Commission plans on presenting updated 

information on the suitability of alternatives at the MBTOC meeting in Antalya.

Table 1. California Strawberry Commission Adoption of Alternatives, June 2010

MBTOC Question 

4.· The CUN mentions excellent results of research with DMDS. What is the expected time path 

for registration of DMDS for strawberry in California? What transition to DMDS could be 

expected in the coming years? 

USG Response

The USG does not have information on the registration timing in California for DMDS.

MBTOC Question 

5.· Please indicate the expected adoption rate for Methyl Iodide on strawberry fruit over the years 

since registration (in Dec 2010)? 
Page 8 of 17

USG Response

The USG estimated a 7% adoption rate for iodomethane per year for 2011 through 2013. The 

uncertain nature of iodomethane performance at lower rates, the price compared to alternatives, 

the concerns of county agricultural commissions, and the impacts of larger buffers in California 

make it very difficult to estimate a transition time for this chemical. 

MBTOC Question 

6.· Will growers in California transition to use Methyl Iodide instead of 1,3-D on non-strawberry 

crops and if so, how is this expected to affect the township caps on 1,3-D for strawberry 

fruit? 

USG Response

The USG has not estimated transition time for iodomethane use in non-CUE crops. Several 

factors would probably affect such a transition, including the performance of iodomethane 

compared to their current 1,3-D standard mixture(s), the price of iodomethane compared to 

alternatives, restrictions placed on iodomethane by county-level agricultural commissioners, and 

the impacts of larger buffers mandated by California regulators. These issues make it very 

difficult at this time to make an accurate, reliable estimate of the extent to which California 

growers will transition to iodomethane.

USA Strawberry RUNNERS 

MBTOC Question 

1. On Page 1 the CUN states that use is requested for 19 ha where 1,3-D is not an approved 

treatment, is not economically feasible or is limited by township caps. On page 5 it says 

because of soil type, and moisture? Could you please be more specific? Where is the 19 ha 

situated and what is the specific restriction on 1,3D/Pic use? (Page 1 also states use is for 22 

ha but we assume this is a typographical error) as it does not match the table.) 

USG Response

The constraint to 1,3-D use is based on label descriptions of conditions to make 1,3-D effective: 

soil moisture (<12% at 1 meter) and not heavy clay soils. Effective rates under those conditions 

would be greater than the label rate allowance. In addition, any regulatory restriction based on 

township caps would come into play. The 19 ha were considered to have at least one of these 

constraints. The exact acres fumigated change each year and the USG does not have information 

on which specific fields will be fumigated in 2013. 

MBTOC Question 

2. In the nomination on page 1 it states that ‘Based on this assessment the transition rate has 

been greatly increased for this sector’ yet the nominated amount has been the same for 

several years. Could you please clarify? 

USG Response

The nomination document should have stated that the nomination amount requested is 

unchanged.
Page 9 of 17

MBTOC Question 

3. The CUN states that certification covers zero tolerance for damaging diseases and plantparasitic nematodes in order to minimize the spread of these pests to production fields. If so, 

how are the 19 has surveyed for damaging diseases and nematode presence? What are the 

specific diseases referred to? 

USG Response

California regulations particularly apply to nematodes. California regulations specify that 

inspectors issue certification of successful nematode treatment according to the regulations 

(based on soil type and treatment type). This appears to be a quarantine questions and the USG 

wonders why it was submitted with CUE questions.

MBTOC Question 

4. Can you provide the trial data that specifically relates to the ineffectiveness of alternatives 

against the diseases and parasitic nematodes for which the request is made? 

USG Response

Again, 1,3-D is listed as an acceptable treatment for nurseries, within certain soil type 

specifications. The 19 ha were considered to have some constraint (soil type, moisture, cap) that 

precluded its effective use. The nomination has considered 1,3-D effective in areas that are not 

constrained by the above. This, again, is a land calculation issue--what acreage is affected by 

clay soils/high moisture, or regulatory caps.

MBTOC Question 

5. The specific certification text shown in the CUN states that ‘All nursery stock shall be kept 

‘commercially’ clean with respect to established pests of general distribution. Commercially 

clean shall mean that pests are under effective control, are present only to a light degree, and 

that only a few of the plants in any lot or block of nursery stock or on the premises show any 

infestation or infection, and of these none show more than a few individuals of any insect, 

animal or weed pests, or more than a few individual infestations of any plant disease.” 

USG Response

See # 4 above--i.e., the nomination is for the small area of nursery land that is constrained in its 

effective use of 1,3-D by one of the limits as described previously (soil type/moisture, regulatory 

caps). This appears to be a quarantine questions and the USG wonders why it was submitted 

with CUE questions.

MBTOC Question 

6. Can you please describe how this criteria is not met with the alternatives to methyl bromide? 

USG Response

See # 4 above--i.e., the nomination is for the small area of nursery land that is constrained in its 

effective use of 1,3-D by one of the limits as described previously (soil type/moisture, regulatory 
Page 10 of 17

caps). This appears to be a quarantine questions and the USG wonders why it was submitted 

with CUE questions.

MBTOC Question 

7. The CUN uses references up till 2008 to support the nomination. Could you please describe 

what efforts are being made to uptake alternatives, particularly MI which is considered a 

suitable alternative since 2008? Specifically what efforts are being made to test and conduct 

economic assessment of MI at lower rates? 

USG Response

The USG has been informed that trials are being developed to test iodomethane and the label 

rates allowed in California. We have no further information on those trials. Those tests are only 

in the design stage and it will take several years to demonstrate consistent pest control before this 

alternative will be recommended by researchers, crop consultants and then adopted by growers. 

MBTOC Question 

8. The CUN also states that lower rates of MI and large buffer zones restrict its use? Could you 

please provide the evidence to support this statement? 

USG Response

This information is based on an EPA, Office of Pesticide Programs assessment. In general the 

assessment indicated that smaller blocks would be treated, or lower rates needed, to avoid large

(untreated) buffer areas, provide growers more time to fumigate a field, as well as to account for 

increased difficulties controlling soil moisture, and increased management time to plan and 

conduct fumigations. 

Analysis of Soil Fumigant Risk Management Requirements using Geographic Information Systems: 

Case Studies based on a Forest Seedling Nursery (DP# 363546). Available online at: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2005-0123-0465. 

USA Tomatoes – FIELD 

No questions

USA Research Request 

MBTOC Question 

1. MBTOC finds difficulty in preliminary assessment of this nomination as there have been no 

details provided on the use (description of trials, research plans, treatments, etc.). Are these 

available?

USG Response

Research projects are ongoing as funded by grower groups, the USDA Agricultural Research 

Service, and the USDA National Institutes for Food & Agriculture (NIFA). NIFA grants are 
Page 11 of 17

provided via the Integrated Pest Management Crops at Risk (CAR), Risk Avoidance and 

Mitigation (RAMP), and Methyl Bromide Transitions (MBT) Competitive Grants Programs.

USG is providing a partial list of ongoing research projects which begin in the year 2010 and 

some continuing into 2013. Given the short timeframe, we were not able to provide a detailed 

description of trials, research plans, treatments, etc. We plan to provide the requested 

information upon our return to the states and forward the information for consideration before 

the Open-Ended Working Group. We expect that research details for 2012 and 2013 trials will 

be dependent upon the outcome of 2011 studies. Because of this the amounts of methyl bromide 

for research provided in our nomination request were only estimates from researchers and may or 

may not be the final amounts used. 

Table 2. Example of Individual Research Program: Dr. Joseph W Noling 2009, Florida

Project # Title Start Date End Date

FLA-LAL-04776 Grower field demonstration Trialing of Gas 

Impermeable plastic mulches, Reduced Rates of 

Soil Fumigants, and Optimized Irrigation and 

Cultural Practices

9/19/2009 9/31/2010

FLA-LAL-04553 Large Scale Field Demonstration Validation trials 

in Florida Strawberry

9/19/2007 9/31/2011

FLA-LAL-04575 Biology, Interaction, and Management of 

Nematodes and Weeds of Florida Vegetable Crops

8/1/2006 7/31/2011

FLA-LAL-04553 - Large Scale Field Demonstration Validation 

trials in Florida Strawberry

Table 3. Example of USDA Sponsored Research Programs

Project Cooperator Dates Grant 

Amount

ADVANCED DEVELOPMENT AND IMPLEMENTATION OF ANAEROBIC 

SOIL DISINFESTATION TECHNOLOGY AS AN ALTERNATIVE TO 

METHYL BROMIDE 

http://cris.nifa.usda.gov/cgibin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=41020&format=

WEBFMT6NT

UNIV. OF 

TENNESSEE

START: 01 

SEP 2010 

TERM: 31 

AUG 2013 

$643,177

MULTI-STATE EVALUATION OF CARBONATED FUMIGANTS 

AND LOW PERMEABLE TARPS TO REDUCE APPLICATION 

RATE, INCREASE EFFICACY, AND MINIMIZE EMISSIONS 

http://cris.nifa.usda.gov/cgibin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=40658&f

ormat=WEBFMT6NT

UNIV. OF 

FLORIDA 

START: 01 

SEP 2010 

TERM: 31 

AUG 2013 

GRANT 

YR: 2011

$ 0

ENERGY EFFICIENT STEAM SOIL DISINFESTATION SYSTEMS 

FOR FLOWER AND STRAWBERRY 

http://cris.nifa.usda.gov/cgibin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=40815&f

ormat=WEBLINK

UNIV OF 

CALIFORNIA

, DAVIS

START: 01 

SEP 2010 

TERM: 31 

AUG 2013 

GRANT 

YR: 2010 

$500,000

STRAWBERRY AND ORNAMENTAL PRODUCTION WITHOUT 

METHYL BROMIDE EMPLOYING GROWER-DIRECTED 

ALTERNATIVE PEST MANAGEMENT RESEARCH AND 

OUTREACH 

http://cris.nifa.usda.gov/cgibin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=270&for

UNIV OF 

CALIFORNIA

, DAVIS

START: 01 

SEP 2008 

TERM: 31 

AUG 2011 

FY: 2009 

GRANT 

$674,595
Page 12 of 17

mat=WEBFMT6NT YR: 2008 

South Atlantic Areawide Pest Management (Awpm) Project for Methyl 

Bromide Alternatives 

http://www.ars.usda.gov/research/projects/projects.htm?accn_no=411360

Subtropical 

Plant 

Pathology 

Research

Start Date: 

Oct 01, 

2006 

End Date: 

Sep 30, 

2011

not listed

Alternatives to Mebr for California Cropping Systems 

http://www.ars.usda.gov/research/projects/projects.htm?accn_no=412732

Water 

Management 

Research

Start Date: 

Dec 26, 

2007 

End Date: 

Dec 25, 

2012

not listed

MBTOC Question 

2. The details above would specifically need to show how the remaining challenges in each 

sector are being addressed under Decision IX/6 particularly attempts to reduce emissions and 

efforts made to adopt alternatives, including the number of trials from which data is required 

to support registration of alternatives etc. Are you able to provide such information?

USG Response

The USG is working to compile information to address this request and will submit this to 

MBTOC as soon as it is available. Can MBTOC provide the USG with the specific sectors 

they are interested in when they posed this question? Knowing this could help the USG 

provide the most relevant details.
Page 13 of 17

APPENDIX A. 2013 Methyl Bromide Usage Newer Numerical Index (BUNNI)

We have attached the tables for the nominated amounts because there were some inconsistencies 

in the rates presented in our nomination documents. These inconsistencies did not change 

the amount requested except in cucurbits which was increased by 1 kg (11,899 to 11,900 kg). 

NOMINATION AMOUNT – FOR COMMODITIES

 California 

Dried Plum 

Board 

 California 

Walnut 

Commission 

 California Date 

Commission 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 3,317 527 1,063 4,907

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 829 527 1,063 2,419

Amount (kgs) 829 527 1,063 2,419

Volume (1000 m3) 36 11 51 98

Rate 23 48 21 31

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -66% -66% -66% -66%

Amount (kgs) 282 179 361 822

Volume (1000 m3) 12 4 17 33

Rate 23 48 21 31

Quantity Required for 

2013 Nomination:

Quantity Approved by Parties for 

2012:

SECTOR

COMMODITIES

NOMINATION AMOUNT – FOR DRIED, CURED PORK PRODUCTS

 Gwaltney of 

Smithfield 

 National 

Country Ham 

Association 

 Nahunta Pork 

Center 

 American 

Assoc. of Meat 

Processors 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 726 709 91 2,204 3,730

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 726 709 91 2,204 3,730

Amount (kgs) 726 709 91 2,204 3,730

Volume (1000 m3) 56 42 5 110 213

Rate 13 17 18 20 17

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) 0% 0% 0% 0% 0%

Amount (kgs) 726 709 9 1 2,204 3,730

Volume (1000 m3) 56 42 5 110 213

Rate 13 17 18 20 17

SECTOR

HAM

Quantity Approved by Parties for 

2012:

Quantity Required for 

2013 Nomination:
Page 14 of 17

NOMINATION AMOUNT – FOR STRUCTURES – FOOD PROCESSORS

 Rice Millers Pet Food 

Institute 

 North American 

Millers 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 14,511 13,722 107,066 135,299

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 7,256 13,722 53,533 74,511

Amount (kgs) 7,256 13,722 53,533 74,511

Volume (1000 m3) 726 745 8,459 9,930

Rate 20 18 19 19

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -66% -66% -66% -66%

Amount (kgs) 2,467 4,665 18,201 25,334

Volume (1000 m3) 123 259 958 1340

Rate 20 18 19 19

SECTOR

Quantity Approved by Parties for 

2012:

STRUCTURES

Quantity Required for 

2013 Nomination:

NOMINATION AMOUNT – FOR CUCURBITS 

 Mardel Cucurbit Southeast Cucurbit Georgia - 

Squash 

 Georgia - 

Cucumber 

 Georgia - 

Melon 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 1,739 38,325 4,076 3,285 12,075 59,501

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 1,739 38,325 4,076 3,285 12,075 59,500

Amount (kgs) 1,739 38,325 4,076 3,285 12,075 59,500

Area (ha) 14 307 33 26 97 476

Rate 125 125 125 125 125 125

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -80% -80% -80% -80% -80% -80%

Amount (kgs) 348 7,665 815 657 2,415 11,900

Area (ha) 3 61 7 5 19 95

Rate 125 125 125 125 125 125

SECTOR

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

CUCURBITS

NOMINATION AMOUNT – FOR EGGPLANT 

 Florida Eggplant Georgia Eggplant 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 3,843 3,061 6,904

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 3,843 3,061 6,904

Amount (kgs) 3,843 3,061 6,904

Area (ha) 31 24 55

Rate 125 125 125

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -80% -80% -80%

Amount (kgs)

 769 612 1,381

Area (ha) 6 5 11.0

Rate 125 125 125

SECTOR

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

EGGPLANT
Page 15 of 17

NOMINATION AMOUNT – FOR PEPPER 

 Southeast Pepper Georgia Pepper Florida Pepper 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 341 947 27,077 28,366

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 341 947 27,077 28,365

Amount (kgs) 341 947 27,077 28,365

Area (ha) 3 8 217 227

Rate 125 125 125 125

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -80% -80% -80% -80%

Amount (kgs) 68 189 5,415 5,673

Area (ha) 0.5 2 43 45

Rate 125 125 125 125

SECTOR

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

PEPPER

NOMINATION AMOUNT – FOR STRAWBERRY FRUIT 

 California 

Strawberry 

Commission 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 751,596 751,596

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 673,085 673,085

Amount (kgs) 673,085 673,085

Area (ha) 3,959 3,959

Rate 170 170

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -21% -21%

Amount (kgs) 531,737 531,737

Area (ha) 4406 4406

Rate 170 170

STRAWBERRY FRUIT

SECTOR

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:
Page 16 of 17

NOMINATION AMOUNT – FOR TOMATO 

 Maryland 

Tomatoes Virginia Tomato 

 Southeast 

Tomato Total Georgia Tomato 

 Florida 

Tomato Total 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 73 646 8,164 3,882 41,657 54,423

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 73 646 8,164 3,882 41,657 54,422

Amount (kgs) 73 646 8,164 3,882 41,657 53,703

Area (ha) 1 5 65 31 333 435

Rate 125 125 125 125 125 125

Transition from 2012 Baseline 

Adjusted Value

Percentage (%) -80% -80% -80% -80% -80% -80%

Amount (kgs) 15 129 1,633 776 8,331 10,741

Area (ha) 0.1 1 13 6 67 86

Rate 125 125 125 125 125 125

SECTOR

TOMATOES

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

NOMINATION AMOUNT – FOR NURSERY STOCK 

 California 

Rose Growers 

 California 

Assoc of Nursery 

and Garden 

Centers 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 191 1,400 1,591

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 191 1,400 1,591

Amount (kgs) 191 1,400 1,591

Area (ha) 1 7 8

Rate 191 200 196

Transition from 2012 Baseline 

Adjusted Value

Percentage 

(%) -66% -66% -66%

Amount (kgs) 6 5 476 541

Area (ha) 0.34 2.4 2.7

Rate 191 200 196

SECTOR

NURSERY STOCK

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

NOMINATION AMOUNT – FOR ORCHARD REPLANT 

 CA G&TFL - 

Stone Fruit 

 CA G&TFL - 

Raisin Grape 

 CA Walnut 

Commission 

 Almond 

Hullers & 

Processors 

 CA Wine 

Grapes Replant 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 12,700 626 1,844 1,660 1,494 18,324

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 12,700 626 1,844 1,660 1,494 18,324

Amount (kgs) 12,700 626 1,844 1,660 1,494 18,324

Area (ha) 64 3 9 8 7 92

Rate 200 200 200 200 200 200

Transition from 2012 Baseline 

Adjusted Value

Percentage 

(%) -66% -66% -66% -66% -66% -66%

Amount (kgs) 4,318 213 627 564 508 6,230

Area (ha) 22 1 3 3 3 31

Rate 200 200 200 200 200 200

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

ORCHARD REPLANT

SECTOR
Page 17 of 17

NOMINATION AMOUNT – FOR ORNAMENTALS 

 California Cut 

Flower 

Commission 

 Florida Cut 

Flowers 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 46,950 1,214 48,164

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 46,950 1,214 48,164

Amount (kgs) 46,950 1,214 48,164

Area (ha) 235 6 241

Rate 200 200 200

Transition from 2012 Baseline 

Adjusted Value

Percentage 

(%) 0% 0% 0%

Amount (kgs) 46,950 1,214 48,164

Area (ha) 235 6 241

Rate 200 200 200

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination:

ORNAMENTALS

SECTOR

NOMINATION AMOUNT – FOR STRAWBERRY NURSERY

 California 

Strawberry 

Nursery Assoc. 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 4,690 4,690

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 3,752 3,752

Amount (kgs) 3,752 3,752

Area (ha) 19 19

Rate 200 200

Transition from 2012 Baseline 

Adjusted Value

Percentage 

(%) 0% 0%

Amount (kgs) 3,752 3,752

Area (ha) 19 19

Rate 200 200

STRAWBERRY NURSERY

SECTOR

Quantity Approved by Parties 

for 2012:

Quantity Required for 

2013 Nomination: