USA CUE15 Strawberry Replies to MBTOC March Page 1

NOMINATING PARTY : The United States of America

DATE: MARCH 2 7 , 2013

FILE NAME: USA CUE15 Strawberry Rep lies Final

BRIEF DESCRIPTIVE TI TLE : Response to MBTOC March 7 , 2013 Questions on Strawberry Fruit

SITE NAME (OPEN FIEL D): Strawberry Fruit

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy U.S. Department of State
2201 C Street, N.W. Room 2 726 Washington, D.C. 20520 U.S.A. Telephone: (202) 647

- 3819

Fax: (202) 647

- 1052

E

- mail: SanMartiniFM@state.gov

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:
Contact/Expert Person: Mark Hartman

Title: Acting Director

Address: Biological and Economi c 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

- 0734

Fax: (703) 308

- 7042

E

- mail: Hartman.Mark@epa.gov

MBTOC Question 1. In the CUN on page 15 it states that “Methyl bromide is not used on the majority of strawber ry production fields (Table 2). Alternatives are effective and currently used in most of the growing area s (86.5%)”. Also in a paper of Mayfield & Norman (2012) it stated that “Alarming numbers in the CUNs sent to the Parties to the Montreal Protocol are not consistent with the success of California strawberry growers in aggregate as use of MeBr has been red uced. Nor are they consistent with basic economics. The ‘economic disruption’ standard of the CUE process was not intended to require the Parties to permit application of MeBr on new acreage to allow limitless expansion of a given industry using MeBr, and it is difficult to justify ongoing exemptions to support expansion rather than protect existing growers and growing regions. If all the new acres in production since 2005 are being managed profitably without MeBr, and existing acres are using less

MeBr le ss often while overall and per acre yields and revenues rise steadily, it seems we have reached a point where alternatives are demonstrating successes for field strawberries in

California”.USA CUE15 Strawberry Replies to MBTOC March Page 2

Based on the above information, please, explain why the conclusio n of the paper by Mayfield and Norman (2012) is not in agreement with the new CUN? U.S. Reply

W hile Mayfield and Norman (2012) pointed out that overall U.S. strawberry production has increased each year since 2004, our CUN noted (p 9) that the increase, at least in part, is due to the success of pest management and breeding programs that are a result of extensive research efforts to identify methyl bromide alternatives. The annual overall reduction in the methyl bromide nomination for California strawber ries since 2004, suggests that the strategy of progressive reduction in methyl bromide allocation has been successful in enabling growers to reduce the aggregate use of methyl bromide in conjunction with other pest management methods for most strawberry pr oduction.

S uccess of the methyl bromide phase

- out for strawberry production depends on developing technically and economically feasible alternatives.

The USG would like to emphasize that contrary to the statement by Mayfield and Norman, the USG does no t, and never has, nominated “new” hectares of production. As MBTOC will note by reviewing historical nominations, nominated hectares have been calculated after accounting for ineligible “new” production land.

MBTOC highlighted a Mayfield and Norman state ment: “ If all the new acres in production since 2005 are being managed profitably without MeBr, and existing acres are using less MeBr less often while overall and per acre yields and revenues rise steadily, it seems we have reached a point where alternati ves are demonstrating successes for field strawberries in California ”.

Alternatives are “demonstrating successes” in some, or even many, situations, as can be

seen in the reduction of methyl bromide use in California. However, for the nominated

critical land where alternatives either cannot be used or have not acceptably managed Macrophomina and Fusarium , growers are at a distinct disadvantage that may not be

obvious in state

- wide or even county

- wide production figures. While state

- wide revenue may have increased over the years, for critical production land, overall costs to produce the crop have increased for all growers in general.

It appears that the number of strawberry growers (based on dues paid to the California strawberry growers association) has declined from 470 in 2008, to 370 in 2012, indicating

that small

- scale growers may be disproportionately affected by the changing market

conditions.

The Mayfield and Norman conclusion may lead a r eader to the misperception that since some land can produce fruit without methyl bromide , all land can do so. The CUN is specific to land (not “new” land) 1) where Macrophomina and Fusarium have not been acceptably controlled with alternative fumigant met hods , 2) where a transition period is necessary to implement use of straight chloropicrin where it has not been used extensively, but where it might be a feasible alternative, and 3) where township caps on
1,3

- D adversely impact its use as an alternative.

MBTOC Question 2

. On page 3 of the CUN application for 2015 it states that the critical need for methyl bromide is because of township caps on 1,3

- D, a transition period forUSA CUE15 Strawberry Replies to MBTOC March Page 3

broadcast 100% chloropicrin or where Macrophomina and Fusarium have not been acceptably controlled with alternative fumigants.

Could you please provide a breakdown of the relative proportion that each factor above contributes to the critical need for methyl bromide?

Could you please explain what transition period and technical expertise will be required for application of 100% chloropicrin and why a long period of transition is required? This product is applied effectively in other regions of the world and this and similar formulations have been applied in strawberry production in California already? U.S. Reply The CUN is based on a calculation of aggregate critical need for methyl bromide . The USG does not have precise figures associated with each category.

A transition period was determined to be critical to strawb erry production based on the historical lack of use of 100% chloropicrin in California . Furthermore, t he reregistration effort by the state of California is separate from the overall federal (EPA) label for chloropicrin. As discussed in the CUN (p 7), t h e California Department of Pesticide Regulation (Cal DPR) is currently reviewing the registration of chloropicrin and 1,3

- D and should announce its recommendations in early 2013. Based on the Cal DPR review the use conditions for chloropicrin and 1,3

- D (e .g. buffers, reentry intervals, tarps, use rate, etc.) could change before 2015. In addition, the 1,3

- D review could lead to changes in how the 1,3

- D township caps are calculated. The unknown timing and extent of any changes may affect the biological and economic transition to chloropicrin and may include such use changes as buffer zones, types of tarps, use rates, etc. A potential new set of regulations for California will require a period of transition to growers who would like to use straight chloropi crin.

Several incidences of exposure to chloropicrin are being investigated . It is unclear the extent of the problem, but the occurrences highlight the need for a transition period for

some growers and applicators who have never fumigated with 100% chlor opicrin . I n addition, growers may experience overlapping restrictions on the use of alternatives (such as township caps on 1,3

- D)

.

A transition to 100% chloropicrin will involve many hectares

, many of which are located adjacent to residential areas . A t ransition period is necessary to accommodate both technical and regulatory requirements to insure worker and bystander safety and effective pest control

.

MBTOC Question 3. MBTOC is aware of other formulations and mixtures which are performing well in research trials and which no discussion is made in the nomination. This

includes Pic

- Clor 80, Pic

- Clor60 and metham sodium and Paladin and the use with or without

barrier films . Could you please explain why no discussion is provided on these alternatives

in the nomination? U.S. Reply The CUN discussed all registered and potential alternatives in Section 2 (pp 3

- 6). The CUN has generally discussed alternatives in terms of act ive ingredients, rather than products, thus, we discuss the alternative 1,3

- D/chloropicrin primarily without regard to

formulation.USA CUE15 Strawberry Replies to MBTOC March Page 4

The USG is aware that efficacy may vary depending on formulation, but as formulations and products change with some frequency, it would be difficult to describe all formulations. Consequently, the CUN discussions are generally limited to active ingredients.

Specifically, the CUN did describe the economic situation with the use of Pic

- Clor 60 (see Table 4, p 10).

The re are no registration s for Pic

- Clor 80 by national (EPA) or California (Cal DPR) regulatory authorities. Dimethyl disulfide (DMDS, Paladin®) is currently not registered for use in California, except with special experimental use labels for research field trials

. I ts potential date of registration is unknown

.

MBTOC Question 4. On page 3, specialists estimate that losses to Macrophomina and Fusarium may be 5% but no data is provided. Could you please provide further evidence of

this information? U.S. Rep ly The 5% loss was an estimate based on grower information provided by the California Strawberry Commission. Two real

- world examples of losses are provided below.

A grower ( E

. Terry ) had severe Macrophomina and Fusarium in 2009

, on a 14 acre block

on his Ventura ranch (Table 1, below) . He estimated that his net loss was $9,250 per acre for that block which had been treated for several years with drip applications of Inline TM (61% 1,3

- dichloropropene plus 33% chloropicrin) with a total loss of $166,500.

A grower ( B

. Reiman ) had severe Fusarium at a summer plant field of strawberries in

Ventura in 2012 (Table 1, below) . He treated the 37 acre field with 200 lbs/a cre chloropicrin by drip. Losses to Fusarium were so severe in tha t field that he disked up 14

acres before harvest and los t an average of $9,318 per acre with a total loss of $344,758.USA CUE15 Strawberry Replies to MBTOC March Page 5

Table 1. Estimated losses due to soilborne diseases in methyl bromide

- alternative treated ground, CSC

March 2013

Summer Planting 2012 Fall planting 2009

Fusarium Fusarium and Macrophomina

Grower Bill Reiman/Ventura Edgar Terry/ Ventura

Acres Planted 37 18

Varieties 3352 & 4053 ?

Fumigation Method Drip applied Chloropicrin Inline

Growing Costs incl. Admin/acre $ 21,277.00 $22,000.00

Harvest costs per box $4.25 $3.25

Box/cooling/marketing cost/box $3.00

Total Boxes harvested 61,457 54

, 000

Total acres harvested 23 18

Acres disked under due to Fusarium 14 0

Average return to ranch per box $11.45 $10.50

Total Revenue $703,682.65 $567,000.00

Total Grow and Admin costs $787,249.00 $396,000.00

Total Harvest Costs $261,192.25 $337,500.00

Total Net Profit/Loss $(344,758.60) $(166,500.00)

loss per acre with soilborne disease $ (9,317.80) $(9,250.00)

MBTOC Question 5. On page 3 of the nomination it describes that Koike reports that plant collapse due to Macrophomina and Fusarium has occurred in virtually all fields that have switched from methyl bromide and chloropicrin to alternative fumigant products and bed fumigation practices. Could you please provide data and any further evidence of the surveys conducted by Koike and the h istory of fumigation (including the method of fumigation that was used in the 3 years prior to the disease development? Please clearly specify the dosage rates of the fumigant/s, if the treatment was drip or shank applied and the treatment broadcast

or st rip treated.

Could you please provide a copy of the publication by Koike et al. 2011? U.S. Reply The description was based on numerous diseased plant samples processed by the University of California Cooperative Extension Plant Diagnostic L aboratory in Salinas,

California. After further investigation, it appears that this statement in the Koike study is

based on observations and discussions with a number of local growers who reported the problem rather than on research or a statistical survey

. The rese archers , in cooperation with the California Strawberry Commission, are gathering data to help determine if this observation is correlated with the use of alternative fumigants.

A copy of Koike et al., 2011 will be provided.USA CUE15 Strawberry Replies to MBTOC March Page 6

MBTOC Question 6. Noling and Cody (2012 a and b) report that a number of fumigants which when shank applied perform equally as well as methyl bromide when strip applied. No further discussion is provided on this information and its relevance to California. Could you please expl ain? U.S. Reply As noted in the CUN (p 4), the possible difference in efficacy between broadcast versus strip applications of 1,3

- D are unclear for California production conditions. Different

soil

- type , season of production and soilborne problems in Cali fornia compared to Florida make bed treatment less likely to succeed

. M o reo ver, broadcast 1,3

- D will likely change the calculation of township cap allowances due to an increased per hectare use of 1,3

- D.

While t he example of studies from Florida (Noling and Cody [2012 a and b]) indicate s that in some situations application methods might affect efficacy , the Florida case may or may not be relevant to California conditions. California researchers are planning further evaluation of application methods.

MBTOC Question 7. On page 7 the CUN states that ‘Currently all of the county agricultural commissions...now have a process in place to allow the use of chloropicrin at rates up to 392 kg/ha (350 lbs/acre)’. Has the adoption of this rate been considered in t he calculation of the critical need for the nominated amount of methyl bromide and if so how? U.S. Reply
Yes, the adoption of the higher rate was considered in the calculation of the nominated amount of methyl bromide. Hectares that could effectively use the higher rate of chloropicrin as an alternative were subtracted from the critical area. Please also see the reply to question 2.

MBTOC Question 8. On page 7, the text explains that Cal DPR is currently reviewing the registration of chloropicrin and 1,3

- D. When is the outcome of this review anticipated? U.S. Reply The final action on chloropicrin by Cal DPR will not take place for several months (December, 2013 at the earliest for chloropicrin) and not until a public comment period has occurred, whi ch has yet to be announced.

MBTOC Question 9. Table 4 on page 10 shows that 3 alternatives provide net revenues greater than methyl bromide, yet little discussion is provided on these products (steam, Pic at

300lbs/acre and Pic

- Clor 60). Could you please explain or provide further details. U.S. Reply The CUN (pp 3

- 6) discussed 1,3

- D/chloropicrin, chloropicrin, metam

- sodium, steam, anaerobic soil disinfestations, resistant cultivars, and substrate systems. The CUN did not

make an economic argument for the critical need for methyl bromide ; rather, the economic assessment was included as part of a comprehensive evaluation that was

conducted to evaluate the overall claim of a critical need for methyl bromide for a portion

of the straw berry fruit industry. The CUN describes technical aspects in strawberry production that have a critical need for methyl bromide

.

a. Where Macrophomina and Fusarium have not been acceptably controlled with alternative fumigant method s
,USA CUE15 Strawberry Replies to MBTOC March Page 7

b. Where a transition pe riod is necessary to implement use of straight chloropicrin where it has not been used extensively, but where it might be a feasible alternative, and

c. Where township caps on 1,3

- D adversely impact its use as an alternative.

MBTOC Question 10. Has an e conomic study been conducted using the maximum rate of chloropicrin at 392kg/ha? U.S. Reply An updated assessment for the 392 kg/ha rate of chloropicrin has been conducted. Table 4 of the CUN (p 10) presented information with 300 lb/acre (336 kg/ha). The additional 56 kg/ha of the higher rate of chloropicrin (392 kg

- 336 kg) reduced profit margins from 6% to 5%, due to the additional cost of material. The CUN considered that 336 kg/ha would be effective where the material could be used, thus, 392 kg/ha is also considered

effective where it can be used. As noted, the CUN is for the portion of production land where 100% chloropicrin is not used and where it might be used after a transition period.

MBTOC Question 11. Is it possible to provide an expect ed timeline for MeBr phase out for this particular crop? U.S. Reply A definitive timeline will be difficult since, as noted previously, Cal DPR is reevaluating fumigants that the USG has considered feasible alternatives. The USG notes, however, that due to extensive work by California growers, extension specialists, and researchers

the critical amount of methyl bromide has decreased annually.

MBTOC Question 12. As several references are difficult to obtain, is it possib le to provide

a full list of references on a disk or USB? U.S. Reply References will be provided in an acceptable format.