U.S. S trawberry Fruit

1. On page 4 of the CUN, the Party states “Methyl iodide is more expensive than methyl bromide when used to treat infested fields at a rate considered effective (300 lb, 67/33 formulation). However, many areas may not require such hig h rates. For those areas, the cost of methyl iodide at lower rates (200 lb, 67/33 formulation) appears to be comparable in both cost and efficacy to methyl bromide (used at higher rates) and other alternatives, including 1,3

- D/chloropicrin.” What are the label rates allowed in California for methyl iodide ? In combination with and without chloropicrin?

2. Tables 3 and 4 of the CUN show that there are no yield losses associated with use of any of the alternatives shown in the table. Is this the correct inter pretation? Are the rates of iodomethane shown in the table registered for use on California strawberries?

3. MBTOC gratefully acknowledges the completed transition to alternatives for all soil fumigation uses other than strawberry fruit production. What cha nges in the availability or adoption of alternatives for the other commodities (vegetables, ornamentals, nurseries) are projected for 2014 that resulted in the completed transition? Are these changes also applicable to strawberry production, and if so, wh en?

4. MBTOC has suggested that results with shank injection of 1,3

- D /Pic are more effective than drip applied 1,3D/Pic, but this is expected to impact t township caps and thus has not been adopted widely by growers. Could you please indicate what efforts are being made to 1) implement this application method in counties subject to the CUN;2) consider review of the emission studies and township cap factors in view of the reduced dosage rates now being used with barrier films (eg VIF, SIF and TIF)?

5. CUN201 4 says on page 3 “ 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.” For w hich strawberry fruit sub

- sectors /regions/counties is methyl bromide being sou ght in 2014?

6. Decision Ex1/4(3) of the Montreal Protocol requires Parties submitting critical use nominations to also provide a National Management Strategy. The NMS , which was last updated by the US in 2009, encourages MB

- users to use alternatives through the use of expedited procedures ; to develop, register and deploy technically and economically feasible alternatives; and to provide information on the potential market penetration of newly deployed alternatives and alternatives which may be used to bring forward the time when it is estimated that methyl bromide consumption for such uses can be reduced and/or ultimately eliminated. In the light of the US NMS, it would be useful if the US could update MBTOC on a transition plan for US phase out of MB for s trawberry fruit production in California.

7. MBTOC notes that Macrophomina phaseolina and Fusarium seems to have occurred in a number of regions in the US producing strawberries and on other crops, and although they appear to be a recent disease in some are as for strawberries it seems as though they can be adequately controlled.
Related to these diseases, MBTOC would like to know:

a. Are there any scientific publications proving that Macrophomina and Fusarium cannot be managed by treatment with 1,3D/Pic, Pic alone or any other chemical or cultural practice or combination?

b. Is there any official survey of the incidence and spread of these “new” diseases in relation to history of the fumigant use or other cultural practices?

8. In terms of further adoption of 1,3

- D/ Pic:

### a. Please provide the expected caps for 2014 on a county basis?
b. What is the lowest use rate of 1,3

- D/Pic that can be used (with film) and if and by how much does this translate to an increase in area that can use 1,3

- D, compared with the situation when these lowest rates of 1,3D were not used;

c. Why is 1,3

- D/Pic is not being shank applied for improved efficacy?

d. How many fumigator companies provide the service of 1,3

- D/Pic application in each strawberry fruit producing county of California?

9. Why does th e CUN2014 review of key alternatives not mention the use of PIC

- alone as a major chemical alternative? Could you please provide a table of the regulatory restrictions on Pic on a per county basis for 2014 for those counties where MB is nominated as part o f the CUN?

10. Future potential chemical alternative DMDS: What is the expected timeframe for registration of DMDS for strawberry in California? What transition to DMDS could be expected in the coming years, bearing in mind Dec ExI/4(3) (above) that requires users of MB to develop, register and deploy technically and economically feasible alternatives as expeditiously as possible?

11. In terms of adoption of Methyl Iodide:

a. How many fumigator companies provide the service of MI application in each strawberry fru it producing county of California? b. Please indicate the expected adoption rate for MI on strawberry fruit over the years since registration (in Dec 2010)? c. Will growers in California transition to use MI instead of 1,3

- D on non

- strawberry crops and i f so, how is this expected to affect the township caps on 1,3

- D for strawberry fruit in 2014? d. Will the federal buffer zones for MI be larger than the ones currently in place in California?

e. What is the expected area of MI use for strawberry fruit in 2014 ?

12. To what extent can farmers use non

- 1,3

- D & non

- MI alternatives on buffer zones, such as Pic

alone, Pic + metham (sequentially), steaming, ASD, substrates? Your answer may be best shown as a table so that MBTOC can understand the use of each alternative

. 13. In terms of steaming:



### a. Is there any commercial application of steam treatment yet? Are these on buffer zones? What field sizes can feasibly be treated using current technology?
b. Will research trials be done in California with different steam applicat ion methods being implemented and how will these be demonstrated to farmers in 2012?

14. Do the various campaign groups in California only monitor use of MI at the moment or also of MB, 1,3

- D and/or Pic? Why do they not target all fumigants equally?

15. Among the alternatives in CUN 2014, a naerobic soil disinfestation (ASD)
, biofumigation or biodisinfestation is not mentioned. These techniques are successfully applied in strawberry production in some other countries (eg Spain) . Have these technologies been researc hed for CA strawberry production? If yes, what were the results, if no, could you kindly provide a reason?