NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 SOIL STRAWBERRY NURSERY Open Field

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Strawberry Nursery in Open Fields (Submitted in 2010 for the 2012 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Strawberry Nursery Open Field

QUANTITY OF METHYL BROMIDE NOMINATED:

T ABLE 1. Q UANTITY OF M ETHYL B ROMIDE N OMINATED

Year N OMINATION A MOUNT

2012 3,752 kg

NOMINATING PARTY CONTACT DETAILS: Contact Person: John Thompson

Title: Division Director Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2658 Washington, D.C. 20520

U.S.A. Telephone: (202) 647-9799 Fax: (202) 647-5947

E-mail: thompsonje2@state.gov

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

this use would result in a significant market disruption. 

### ■ Yes  No

Signature Name Date

Title:

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

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on which the Party’s first-year exemption was approved, as well as any supplementary information provided by the Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not re-submit that earlier information.

USA CUN12 SOIL Strawberry Nursery Open Field Page 1 of 9CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:
Contact/Expert Person: Jack Housenger

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

U.S.A. Telephone: (703) 308-8200 Fax: (703) 308-7042

E-mail: Housenger.Jack@epa.gov

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

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

Secretariat

USA CUN12 SOIL STRAWBERRY NURSERY Open Field

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

Secretariat

USA CUN12 SOIL STRAWBERRY NURSERY Open Field

* Identical to paper documents

USA CUN12 SOIL Strawberry Nursery Open Field Page 2 of 9

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

STRAWBERRY NURSERY

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

Methyl bromide has been the long-time standard in nurseries for the treatment of soils to achieve pest-free certification of nursery stock. Currently in California, only methyl bromide and 1,3-D are specified treatments for nursery stoc k certification (e.g., CDFA, 2009—NIPM #7). By regulation, the use of 1,3-D is limited to soils wher e soil moisture and texture are amenable to nematicidal activity.

The USG has reviewed all factor s affecting transition rates in this sector. Based on this assessment the transition rate has been greatly incr eased for most portions of this sector. For the area covered in this nomination, the USG believes that the narrative discussion included in this document is technically valid. The USG has no minated amounts of methyl bromide based only on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate.

Research trials have indicated that iodomethane/chloropicri n, 1,3-D/chloropicrin followed by dazomet, and chloropicrin followed by dazomet provi ded similar pest control in runner nurseries when compared to methyl bromide/chloropicrin, however, additional trials were necessary to verify results (e.g., Fennimore et al. , 2008a; Kabir et al. , 2005). In addition, use of low permeable films has improved efficacy of alternatives. However, to attain certification of transplants, commercially feasible protocols mu st be developed and te sted and sanctioned by state regulators. These alternatives will require further study to show their consistency in providing control of yello w and purple nutsedge ( Cyperus esculentus

, C. rotundus ) and a number of other critical weed pests in California. In ad dition, regulatory restrict ions in California on the use of 1,3-D and chloropicrin make their use as alternatives uncertain. Therefore, until commercial trials support resear ch study findings, the nursery indus try has a critical need for methyl bromide.

California runner nurseries produce the largest number of strawbe rry plants in the world (CSC, 2008). Transplants produced in California are di stributed widely throughout the U.S. and other countries. Transplants are grown over a five-year cycle. Screenhouses ar e used during the first two years and open field plantings are used during the last three y ears. Methyl bromide is used on soils in production Year-2 though Year-5. Individual planting si tes are planted to strawberries once every three y ears. The fourth and fifth pr oduction years account for 22% and 77%, respectively, of the current methyl bromide nur sery usage in California. Several pathogens cause significant disease problem s for nursery plants in Cali fornia including, Phytophthora crown and root rots ( Phytophthora spp.), red stele ( Phytophthora fragariae ), Verticillium wilt ( Verticillium dahliae ), and anthracnose ( Colletotrechum acutatum ). In addition, numerous nematode and weed species can cause severe problems.

USA CUN12 SOIL Strawberry Nursery Open Field Page 3 of 92. SUMMARIZE WHY KEY ALTER NATIVES ARE NOT FEASIBLE

Nurseries currently use methyl bromide on all of their land for transplants designated as quarantine pre-shipment (QPS), which makes up 99% of methyl bromide use by nurseries. For the 2012 season, methyl bromide continues to be cr itical for California st rawberry nurseries to produce pest-free plants to meet state and fo reign certification standards, as well as the expectations of strawberry fruit producers. In California, the regulatory restrictions on 1,3-D and chloropicrin make their reliabil ity as alternatives uncertain.

Protocols for the commercial use of effective alte rnatives have not been sufficiently developed to provide confidence for effective control of the ke y pests that would ensure certification. There are no markets for plants that do not meet the ce rtification standards, which mean that losses up to 100% are possible when inadequate pest control occurs. Failure to adequately manage pests in transplants will jeopardi ze certification process and adversely affect fruit production industries in the U.S., as well as the in countries purchas ing U.S. plants (e.g., Canada, Mexico, Spain, countries in South America, and others).

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

The certification requirements for strawberry nur series (e.g., CDFA, 2009) located in California are strict (zero tolerance for any damaging diseas es and plant-parasitic ne matodes) in order to minimize the prospect of spreading these pests to California production fi elds, and other states and countries where these plants are shipped. Me thyl bromide has been the long-time standard

for these nurseries to attain cer tification. State authorities may determine appropriate measures to achieve pest-free designation. California describes methods to pr epare field soils using methyl bromide or 1,3-D (CDFA, 2009—NIPM #7). Calif ornia regulations (e.g., CDFA, 2009—NIPM #3) for nursery standards (reg. 3060.2-a) include:

“All nursery stock shall be kept ‘commercially’ cle an with respect to estab lished pests of general distribution. Commercially clean shall mean that pests are under effectiv e control, are present only to a light degree, and that onl y a few of the plants in any lot or block of nursery stock or on the premises show any infestation or infect ion, and of these none show more than a few individuals of any insect, animal or weed pests, or more than a fe w individual infestations of any plant disease.”

4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE,

INDICATE THE REASON WH Y METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTER NATIVE STRATEGIES ARE USED TO

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL

BROMIDE THERE.

All nurseries currently treat soils with methyl br omide. This nomination is only for a portion of nursery soils that produce r unners requiring methyl bromid e, but not designated QPS.

USA CUN12 SOIL Strawberry Nursery Open Field Page 4 of 95. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO

COVER AT LEAST PART OF THE CRO P THAT HAS REQUESTED USE OF

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE

THIS?

As previously stated, until commercial use of al ternatives has been proven to provide acceptable pest-free status, methyl bromide is critical. Th e USG has reviewed all factors affecting transition

rates in this sector. Based on this assessment th e transition rate has been greatly increased for most portions of this sector. For the area cove red in this nomination, the USG believes that the

narrative discussion included in this document is technically valid. The USG has nominated amounts of methyl bromide based only on those s ub-sectors that cannot transition away from methyl bromide at the accelerated rate.

6. SUMMARY OF RECENT RESEARCH

Research for the strawberry runner nu rseries in California (e.g., Fennimore et al. , 2008a; Kabir et
al. , 2005) has indicated that in re search plots some alternativ es appear to provide pest management levels comparable to traditional met hyl bromide treatments. However, the time and expense necessary to transfer new technology from the research stage to commercial application while meeting certification standards continues to re sult in the critical need for methyl bromide

for California nurseries.

Previous research (e.g., Larson and Shaw, 2007) suggested that inconsistent efficacy of alternatives remains the greatest problem for transition to alternatives by this industry (this was also the case for nurseries in Spain; see, e.g., Garcia-Mendez et al. , 2007). Alternatives that have

been evaluated in research trials over the past several years are 1,3-D/chloropicrin, 1,3- D/chloropicrin + metam-sodium, 1,3-D and metam-sodium, and dazomet as a follow-up application to 1,3-D/chloropicrin or chloropicrin (Fennimore et al. , 2008b).

For the effective production of runner plants, weed s must be kept to a minimum. Recently a report on weed control was published (Fennimore et al. , 2008a). Results indicated that iodomethane/chloropicrin, 1,3-D/ch loropicrin followed by dazomet, chloropicrin followed by dazomet, and methyl bromide/chloropicrin all provided comparable weed control with similar hand-weeding costs. Costs of iodomethane for California nurseries were considered uncertain since it is not currently on the market for comm ercial use in California. Cost analyses for

alternatives for California and th e southeastern nurseries is pr esented in this document.

The industry continues to refine protocols for effective alterna tives, but this requires several seasons of data gathering. For example, the us e of 1,3-D/chloropicrin followed by dazomet or chloropicrin followed by dazomet appeared more e ffective in nursery trials in California (Kabir

et al. , 2005) than previous nursery trials where chloropicrin wa s applied alone (Larson and Shaw, 2000). Fennimore et al. (2008b) found variable effects and indicated that further research is necessary to optimize the treatment regime . By optimizing methods identified through research alternative strategi es are being identified.

USA CUN12 SOIL Strawberry Nursery Open Field Page 5 of 9USA CUN12 SOIL Strawberry Nursery Open Field Page 6 of 9 7. ECONOMIC FEASIBILITY OF ALTERNATIVES

This study calculated net revenue as gross re venue minus operating costs. This is a good measure of the direct losses of income that may be suffered by the users. It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitability of an operation for an enterprise, is gross reve nue minus the sum of operating and fixed costs.

Net income is smaller than the net revenue measur ed in this study, often s ubstantially so. We did not include fixed costs because they are difficult to measure and verify.

The economic analysis of the strawberry nursery applications compared data on yields, crop prices, revenues and costs using methyl bromide and using alternative pest control regimens in order to estimate the loss of methyl bromide av ailability. The alternatives identified as technically feasible - in cases of low pest infestation 1 – for California are 1,3-D + chloropicrin followed by metam sodium.

The economic factors that really drives the feasibility analysis for nursery stock production uses of methyl bromide are: (1) yield losses, refe rring to reductions in the quantity produced, (2) increased production costs, which may be due to the higher-cost of using an alternative, additional pest control requireme nts, and/or resulting shifts in other production or harvesting practices (3) quality losses, which generally a ffect the quantity and price received for the goods, and (4) missed market windows due to plant back tim e restrictions, which al so affect the quantity and price received for the goods.

The economic reviewers then analyzed crop budgets for pre-plant sectors to determine the likely economic impact if methyl bromide were unavailab le. Various measures were used to quantify the impacts, including the following:

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

(2) Loss per Kilogram of Methyl Bromide . This measure indicates the value of methyl bromide to crop production.

(3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usually easy to meas ure, at least over some unit, e.g. , a hectare of land or a storage operation. However, high value commodities or cr ops may provide high revenues but may also entail high costs. Losses of even a small per centage of gross revenues could have important impacts on the profitability of the activity.

(4) Loss as a Percentage of Net Operating Revenue . We define net cash revenues as gross revenues minus operating costs. This is a very good indicator as to the direct losses of income

1 The USG does not request methyl bromide for use in areas of low to moderate pest pressure. Only cases where key pests are present at modera te to high levels require methyl bromide for

pest pressure.that may be suffered by the owners or operators of an enterprise. However, operating costs can often be difficult to measure and verify.

(5) Operating Profit Margin . We define operating profit ma rgin to be net operating revenue divided by gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be

difficult to measure and fixed costs even more di fficult, therefore fixed costs were not included in the analysis.

These measures represent different ways to a ssess the economic feasibili ty of methyl bromide alternatives for methyl bromide users, who ar e strawberry nursery pr oducers in this case. Because producers (suppliers) represent an integr al part of any definition of a market, we interpret the threshold of significant market disrup tion to be met if there is a significant impact on commodity suppliers using methyl bromide. The economic measures provide the basis for making that determination.

California strawberry nursery grow ers are not expected to see any yield or quality impacts with 1,3-D/chloropicrin plus metam sodium (Table 2).

T ABLE 2. C ALIFORNIA S TRAWBERRY G ROWERS A SSOCIATION : E CONOMIC I MPACTS OF M ETHYL B ROMIDE
A LTERNATIVES

.

CALIFORNIA SGA M ETHYL B ROMIDE I ODOMETHANE ( UNREGISTERED ) 1,3 D + PIC

P RODUCTION L OSS (%) 0% 0% 10%

P RODUCTION PER H ECTARE 372 372 235

* P RICE PER U NIT ( US $) $ 110.23 $ 110.23 $ 110.23

= G ROSS R EVENUE PER H ECTARE ( US $) $ 41,019 $ 41,019 $ 36,918

- O PERATING C OSTS PER H ECTARE ( US $)** $ 28,585 $ 43,295 $ 44,788

= N ET R EVENUE PER H ECTARE ( US $) $ 12,434 $ (2,276) $ (7,870)

L OSS M EASURES *

1. L OSS PER H ECTARE ( US $) $ 0 $ 14,710 $ 20.305

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ 0 $ 55.85 $ 77.09

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 36% 50%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING
R EVENUE (%) 0% 118% 163%

5. O PERATING P ROFIT M ARGIN (%) 30% -6% -21%

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

USA CUN12 SOIL Strawberry Nursery Open Field Page 7 of 98. RESULTANT CHANGES TO RE QUESTED EXEMPTION QUANTITIES

T ABLE 3: N OMINATION A MOUNT

California Strawberry
Nursery Assoc. Sector Total / Average

Quantity Requested for 2011: Amount (kgs) 4,690 4,690

Quantity Recommended by

MBTOC/TEAP for 2011 : Amount (kgs) 4,690 4,690

Amount (kgs) 4,690 4,690

Area (ha) 23 23

Rate 200 200

Transition from 2011 Baseline Adjusted Value Percentage (%) -20% -20%

Amount (kgs) 

### 3,752 3,752

Area (ha) 19 19

Rate 200 200 SECTOR STRAWBERRY NURSERY

Quantity Approved by Parties

for 2011:

Quantity Required for

2012 Nomination:

USA CUN12 SOIL Strawberry Nursery Open Field Page 8 of 9USA CUN12 SOIL Strawberry Nursery Open Field Page 9 of 9 CITATIONS

CSC (California Strawberry Commission). 2008. Reque st for a critical use exemption the use of methyl bromide on strawbe rries (submission to EPA).

CDFA (California Department of Food and Agriculture). 2009. http://www.cdfa.ca.gov/phpps/PE/Nursery/NIPM.html Regulation for nursery and seed inspection (NIPM #3), http://www.cdfa.ca.gov//phpps/PE/Nurs ery/pdfs/nipm _3_regs_nsy_sees_insp.pdf ; Approved treatment and handling procedures to ensure against nematode pest infestation of nursery stock (NIPM #7), http://www.cdfa.ca.gov/phpps/PE/Nursery/pdfs/NIPM_7.pdf ; CDFA Strawberry Registrati on and Certification Program, http://fpms.ucdavis.edu/St rawberry /CDFAStrawRegs.html

Fennimore, S. A., Haar, M. J., Goodhue, R. E., a nd Winterbottom, C. Q. 2008a. Weed control in strawberry runner plant nurseries with methyl bromide alternative fumigants. HortScience 43(5):1495-1500.

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. 2008b. Methyl bromide alternatives evaluated for California strawberry nurser ies. California Agriculture 62(2):62-67. http://repositories.cdlib.org/cgi/viewcontent. cgi? article=3194&context= anrcs/californiaagric

ulture

Garcia-Mendez, E., De Cal, A., Melgarejo, P ., Salto, T., Martinez-Beringola, M. L., Redondo, C., Martinez-Treceno, A., Becerr il, M., Andrade, M. A., Medina, J. J., Soria, C., LopezAranda, J. M., and Garcia-Sinova s, D. 2007. Strawberry nurseries in Spain: alternatives to methyl bromide, 2006 results. Annual Inte rnational Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2007).http://www.mbao.org/2007/Proceedings/063LopezArandaJSpainExperimentsNursery2006.pdf

Kabir, Z., Fennimore, S. A., Duniway, J. M., Mar tin, F. N., Browne, G. T., Winterbottom, C. Q., Ajwa, H. A., Westerdahl, B. B ., Goodhue, R. E., and Haar, M. J. 2005. Alternatives to methyl bromide for strawberry runner plant production. Hort Science 40(6):1709-1715.

Larson, K. D., and Shaw, D.V. 2007. Strawberry nursery soil fumigation and runner transplant fruit production. 2007 Annual In ternational Research Conference on Methyl Bromide

Alternatives and Emissions Reductions. http://www.mbao.org/2007/Proceedings/072L arsonKStrawberrynurserysoilfum igation.pdf

Larson, K. D., and Shaw, D.V. 2000. Soil Fumiga tion and Runner Plant Pr oduction: A Synthesis of 4 Yrs of Strawberry Nursery Field Trials. HortSci 35(4):642-646.