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: 

TABLE 1. QUANTITY OF METHYL BROMIDE NOMINATED

Year NOMINATION AMOUNT 

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 critical because the lack of availability of methyl bromide for 

this use would result in a significant market disruption. ■ Yes  No 

 

Signature Name Date 

Title: 

(Details on this page are 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 9 
CONTACT 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 stock certification (e.g., CDFA, 2009—NIPM #7). By 

regulation, the use of 1,3-D is limited to soils where soil moisture and texture are amenable to 

nematicidal activity. 

The USG has reviewed all factors affecting transition rates in this sector. Based on this 

assessment the transition rate has been greatly increased 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 nominated 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/chloropicrin, 1,3-D/chloropicrin followed by 

dazomet, and chloropicrin followed by dazomet provided 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 must be developed and tested and sanctioned by 

state regulators. These alternatives will require further study to show their consistency in 

providing control of yellow and purple nutsedge (Cyperus esculentus, C. rotundus) and a number 

of other critical weed pests in California. In addition, regulatory restrictions in California on the 

use of 1,3-D and chloropicrin make their use as alternatives uncertain. Therefore, until 

commercial trials support research study findings, the nursery industry has a critical need for 

methyl bromide. 

California runner nurseries produce the largest number of strawberry plants in the world (CSC, 

2008). Transplants produced in California are distributed widely throughout the U.S. and other 

countries. Transplants are grown over a five-year cycle. Screenhouses are used during the first 

two years and open field plantings are used during the last three years. Methyl bromide is used 

on soils in production Year-2 though Year-5. Individual planting sites are planted to 

strawberries once every three years. The fourth and fifth production years account for 22% and 

77%, respectively, of the current methyl bromide nursery usage in California. Several pathogens 

cause significant disease problems for nursery plants in California 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 9 
2. SUMMARIZE WHY KEY ALTERNATIVES 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 critical for California strawberry nurseries to 

produce pest-free plants to meet state and foreign certification standards, as well as the 

expectations of strawberry fruit producers. In California, the regulatory restrictions on 1,3-D and 

chloropicrin make their reliability as alternatives uncertain. 

Protocols for the commercial use of effective alternatives have not been sufficiently developed to 

provide confidence for effective control of the key pests that would ensure certification. There 

are no markets for plants that do not meet the certification standards, which mean that losses up 

to 100% are possible when inadequate pest control occurs. Failure to adequately manage pests in 

transplants will jeopardize certification process and adversely affect fruit production industries in 

the U.S., as well as the in countries purchasing 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 nurseries (e.g., CDFA, 2009) located in California 

are strict (zero tolerance for any damaging diseases and plant-parasitic nematodes) in order to 

minimize the prospect of spreading these pests to California production fields, and other states 

and countries where these plants are shipped. Methyl bromide has been the long-time standard 

for these nurseries to attain certification. State authorities may determine appropriate measures 

to achieve pest-free designation. California describes methods to prepare field soils using methyl 

bromide or 1,3-D (CDFA, 2009—NIPM #7). California regulations (e.g., CDFA, 2009—NIPM 

#3) for nursery standards (reg. 3060.2-a) include: 

“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.” 

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

INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER 

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE. 

All nurseries currently treat soils with methyl bromide. This nomination is only for a portion of 

nursery soils that produce runners requiring methyl bromide, but not designated QPS. 

USA CUN12 SOIL Strawberry Nursery Open Field Page 4 of 9 
5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO 

COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF 

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE 

THIS? 

As previously stated, until commercial use of alternatives has been proven to provide acceptable 

pest-free status, methyl bromide is critical. The USG has reviewed all factors affecting transition 

rates in this sector. Based on this assessment the transition rate has been greatly increased 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 nominated 

amounts of methyl bromide based only on those sub-sectors that cannot transition away from 

methyl bromide at the accelerated rate. 

6. SUMMARY OF RECENT RESEARCH 

Research for the strawberry runner nurseries in California (e.g., Fennimore et al., 2008a; Kabir et 

al., 2005) has indicated that in research plots some alternatives appear to provide pest 

management levels comparable to traditional methyl 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 result 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, weeds 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/chloropicrin 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 commercial use in California. Cost analyses for 

alternatives for California and the southeastern nurseries is presented in this document. 

The industry continues to refine protocols for effective alternatives, but this requires several 

seasons of data gathering. For example, the use of 1,3-D/chloropicrin followed by dazomet or 

chloropicrin followed by dazomet appeared more effective in nursery trials in California (Kabir 

et al., 2005) than previous nursery trials where chloropicrin was 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 strategies are being identified. 

USA CUN12 SOIL Strawberry Nursery Open Field Page 5 of 9 
USA CUN12 SOIL Strawberry Nursery Open Field Page 6 of 9 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

This study calculated net revenue as gross revenue 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 revenue minus the sum of operating and fixed costs. 

Net income is smaller than the net revenue measured in this study, often substantially 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 availability. The alternatives identified as 

technically feasible - in cases of low pest infestation1

 – 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, referring 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 requirements, and/or resulting shifts in other production or harvesting 

practices (3) quality losses, which generally affect the quantity and price received for the goods, 

and (4) missed market windows due to plant back time restrictions, which also 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 unavailable. 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 measure, at least over some unit, e.g., a hectare of land or a storage 

operation. However, high value commodities or crops may provide high revenues but may also 

entail high costs. Losses of even a small percentage 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 moderate 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 margin 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 difficult, therefore fixed costs were not included 

in the analysis. 

These measures represent different ways to assess the economic feasibility of methyl bromide 

alternatives for methyl bromide users, who are strawberry nursery producers in this case. 

Because producers (suppliers) represent an integral part of any definition of a market, we 

interpret the threshold of significant market disruption 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 growers are not expected to see any yield or quality impacts with 

1,3-D/chloropicrin plus metam sodium (Table 2). 

TABLE 2. CALIFORNIA STRAWBERRY GROWERS ASSOCIATION : ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES.

CALIFORNIA SGA METHYL BROMIDE

IODOMETHANE 

(UNREGISTERED) 1,3 D + PIC

PRODUCTION LOSS (%) 0% 0% 10% 

 PRODUCTION PER HECTARE 372 372 235 

* PRICE PER UNIT (US$) $ 110.23 $ 110.23 $ 110.23 

= GROSS REVENUE PER HECTARE (US$) $ 41,019 $ 41,019 $ 36,918 

- OPERATING COSTS PER HECTARE (US$)** $ 28,585 $ 43,295 $ 44,788 

= NET REVENUE PER HECTARE (US$) $ 12,434 $ (2,276) $ (7,870) 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $ 0 $ 14,710 $ 20.305 

2. LOSS PER KILOGRAM OF METHYL BROMIDE 

(US$) $ 0 $ 55.85 $ 77.09 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE 

(%) 0% 36% 50% 

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0% 118% 163% 

5. OPERATING PROFIT MARGIN (%) 30% -6% -21% 

**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 CUN12 SOIL Strawberry Nursery Open Field Page 7 of 9 
8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

TABLE 3: NOMINATION AMOUNT

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

CITATIONS 

CSC (California Strawberry Commission). 2008. Request for a critical use exemption the use of 

methyl bromide on strawberries (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/Nursery/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 Registration and Certification Program, 

http://fpms.ucdavis.edu/Strawberry/CDFAStrawRegs.html

Fennimore, S. A., Haar, M. J., Goodhue, R. E., and 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 nurseries. 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., Becerril, M., Andrade, M. A., Medina, J. J., Soria, C., LopezAranda, J. M., and Garcia-Sinovas, D. 2007. Strawberry nurseries in Spain: alternatives to 

methyl bromide, 2006 results. Annual International 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., Martin, 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. HortScience 40(6):1709-1715. 

Larson, K. D., and Shaw, D.V. 2007. Strawberry nursery soil fumigation and runner transplant 

fruit production. 2007 Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions. 

http://www.mbao.org/2007/Proceedings/072LarsonKStrawberrynurserysoilfumigation.pdf

Larson, K. D., and Shaw, D.V. 2000. Soil Fumigation and Runner Plant Production: A Synthesis 

of 4 Yrs of Strawberry Nursery Field Trials. HortSci 35(4):642-646.