USA CUN13 SOIL Nursery Stock Field Page 1 of 13

NOMINATING PARTY : The United States of America FILE NAME: USA CUN1 3 SOIL NURSERY STOCK
— FRUIT, NUT, AND ROSE Open Field BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methyl Bromide Critical Use Nomination for Preplant Soil Use for Nursery Stock

—Fruit, Nut, And Rose in Open Fields (Submitted in 20 1 1 for 201 3 Use Season) CROP NAME (OPEN FIEL D OR PROTECTED): Nursery Stock

—Fruit, Nut, And Rose Open Field QUANTITY OF METHYL B ROMIDE NOMINATED : T ABLE 1 : Q UANTITY OF M ETHYL B ROMIDE N OMINATED

Year N OMINATION A MOUNT 2 01 3 541 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 N omination is critical because the lack of availability of methyl bromide for this use would result in a significant market disruption. 

### ■ Yes  No Signature Nam e 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 CUN13 SOIL Nursery Stock Field Page 2 of 13

CONTACT OR EXPERT(S ) FOR FURTHER TECHNICAL DETAILS: Contact/Expert Person: Jack Housenger Title: Director Address: Biological and Economic Analy sis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503 P 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

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 CUN1 3 SOIL NURSERY STOCK Field * Identical to paper documentsUSA CUN13 SOIL Nursery Stock Field Page 3 of 13



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

NURSERY STOCK

— FRUIT, NUT, AND ROSE 1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE Nursery producers provide pest
- free stock plants that are used for the establishment of orchards and gardens. Nurseries in this sector provide plants to comme rcial growers of rose bushes , and such divers e fruit crops as apricots, peaches, prunes, nectarines, cherries, plums, apples, pears, Asian pears, and ornamental pears. Nut trees produced b y these nurseries include almonds, walnuts, pistachios, pecans, and chestnuts. Approximately 95% of the trees are fruit and nut varieties sold to commercial producers; the other 5% are ornamental types used for landscaping. Deciduous trees are primarily produced in the Sacramento and San Joaquin valley s of California. S tock plants must meet state - mandated certi fication requirements for plant material (CDFA, 200 9 ; Hanson et al., 2009 ). Compliance with federal regulations for movement of plant material may also be required (USDA
- APHIS, 2007; USDA - APHIS, 2004). To achieve pest
- free status, nurseries have relied o n methyl bromide to provide effective fumigation on soils in diverse locations with various soil ty pes and moisture conditions. In some situations the use of 1,3
- dichloropropene (1,3
- D) can provide an effective alternative to methyl bromide for nematode c ontrol to enable nurseries to attain certification for stock. However, use of 1,3
- D is restricted b y township cap regulations and requires a soil ty pe and moisture level that is compatible with the chemical activity

(e.g., CDFA, 2009; Hanson et al., 2008; Hanson et al., 2007). Moisture restrictions for 1,3
- D may be more limiting than township caps. Nurseries with heavy soils or moisture greater than 12% (especially common in clay

soils at depths of 1 to 1.5 meters) may not use 1,3 - D to reduce nematode po pulations. Currently , where pathogens and nematodes are key pests, as in most nurseries, methyl bromide is critical. Deciduous tree nurseries range in size from 15 to over 600 hectares in field beds. A ty pical operation ranges between 80 and 120 hectares. The climate and soil is ideal for fruit and nut tree nurseries (as well as for fruit and nut production). While some nurseries concentrate on specific tree crops, most nurseries grow and sell a variet y of different trees. Nursery stock is grown on a cropping s ys tem that includes crop rotation or cover cropping between tree production cycles; therefore, not all of the nursery area is in tree production in a given ye ar. The tree production cy cle can be any

where from a single ye ar to several y ears dep ending on the ty pe of tree crop being produced. Nursery production of trees takes from one to four ye ars in the ground depending on the t ype being produced. In order to prepare the ground for planting, the fields are disked, deep ripped, leveled, and the n fumigated to meet certification standards set by the California Department of Food and Agriculture (CDFA, 200 9 ). Methyl bromide is applied by shank and treated area is usually covered with a tarp. The fumigation is carried out around August and Septemb er, and planting begins in October, and may continue through January
. Nursery roses are grown in open field plots. Production includes 1
- year and 2
- ye ar rose bushes, rose trees, climbing roses, miniature roses, rose ground cover, rose shrubs, and heirlo om roses.USA CUN13 SOIL Nursery Stock Field Page 4 of 13

A ty pical crop rotation for a two
- ye ar rose crop includes one ye ar fallow, followed by one or two ye ars of rotational crops, and then a two
- ye ar rose crop. The two
- year rose crop cycle begins with land preparation (removing the cover crop, deep cultivation, and fumigation with methyl bromide), followed b y planting the rootstock and T
- bud grafting. In late winter of the first ye ar, the rootstock tops are removed. The rose crop matures b y the second autumn and is then harvested. This cy cle vari es depending on the t yp e of rose crop being produced (e.g., two
- ye ar roses, one - ye ar minis and patio trees, or 18
- month mini bushes). Where soil conditions and regulations allow, 1, 3
- D may be used as an alternative to methyl bromide, but it appears to have a relativel y limited use due to regulatory restrictions and soil moisture requirements (Hanson et al., 2007). The USG has reviewed all factors affecting transition rates in this sector. Based on this assessment the transition rate has been greatl y 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 technicall y valid. The USG has nominated amounts of meth yl bromide based onl y on those sub
- sectors that cannot transition away from methyl bromide at the accelerated rate. 2 . SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE Reasons for critical use of methyl bromide include: 1) 1,3
- D is not an approved treatment for fine
- textured soils; 2) greater inputs are required for soil preparation and moisture management; 3) township caps and buffer zone requirements; 4) weed management efficacy ; 5) air quality standards related to volatile organic compounds and 6) iodomethane has not been proven effective at the use rates registered in California
. Methyl bromide , iodomethane and 1,3
- D are the only soil treatments cited in regulation s for open field nursery

stock in California (CDFA, 200 9 ). However, these regulations specify that 1,3 - D is only acceptable i n certain soil ty pe s with specified soil moisture at less than 12% (e.g., McKenry , 2000; Schneider et al., 2004 ; CDFA, 2009 ). Moisture restrictions for 1,3
- D may be more limiting than township cap restrictions . Nurseries with heav y soils or moisture greater than 12% (especially

common in clay

soils at depths of 1 to 1.5 meters) do not receive certification of nursery stock
. The rates specified in these regulations are substantially higher than those registered in California. In these situations methyl b romide is critical. The requested amount of methyl bromide in the U.S. nomination includes those areas where 1,3
- D would not meet the certification requirements or would be limited by township caps. Under California regulations , nursery crops must be “fr ee of especiall y injurious pests and disease sy mptoms” in order to qualify for a CDFA Nursery

Stock Certificate for Interstate and Intrastate Shipments (CDFA, 200 9 ). If an approved fumigation is not used in the nursery , a nematode sampling procedure is imposed by CDFA, and if nematodes are found all nursery stock in an area are destro yed resulting in a complete loss. Methyl bromide meets the certification guidelines . Under certain soil conditions 1,3
- D may also meet guidelines for nematode infestations
. Control of p athogens and weeds, which are also important pests of nurseries and part of the pest
- free certification requirements , requires rigorous multi
- ye ar testing ofUSA CUN13 SOIL Nursery Stock Field Page 5 of 13

alternatives . This nomination is for the critical use of methyl bromide where altern atives cannot be used or are not effective. 3 . I S THE USE COVERED BY A CERTIFIC ATION STANDARD? Nurseries in this sector are covered b y certification requirements as described in state (e.g., CDFA, 200 9 ) and federal (e.g., USDA
- APHI S, 2007; USDA - APHI S, 2 004) regulations. For example, “Section 3640, CCR, makes it mandatory that nursery stock for farm planting be commerciall y clean with respect to economicall y important nematodes” (CDFA, 200 9 ). The regulations specify methyl bromide /chloropicrin and 1,3
- D /chloropicrin as acceptable fumigants for control of nematodes. Specific requirements for soil texture and soil moisture (less than 12% at 1 meter) may

limit the use of 1,3
- D in some nurseries. In addition, pests other than nematodes may require addition al pest control measures
. If nematodes are found and the nursery stock is not “free of especiall y injurious pests and disease sy mptoms”, then a total loss is likely because the nursery

stock: 1) would not qualify for a CDFA Nursery

Stock Certificate fo r Interstate and Intrastate Shipments, 2) would likely not be marketable since resale for planting is severel y restricted by the CDFA, and 3) should be destroy ed to prevent further infestation. CALIFORNIA (CDFA, 200 9 ) California regulations (e.g., CDFA, 200 9

— NI PM #3) for nursery

standards (reg. 3060.2
- a) include: “All nursery

stock shall be kept ‘commerciall y’ clean with respect to established pests of general distribution. Commercially clean shall mean that pests are under effective control, are prese nt onl y to a light degree, and that onl y a few of the plants in an y 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 an y insect, animal or weed pests, or more than a f ew individual infestations of any plant disease.” 4 . IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE THE REASON WHY METHYL BROMIDE I S NOT USED IN THE OT HER AREA, AND IDENTIFY W HAT ALTERNATIVE STRA TEGIES ARE USED TO CONTROL THE TARGET P ATHOGENS AND WEEDS W ITHOUT METHYL BROMIDE THERE. Methyl bromide is used on nurser y soils where effective pest management and regulatory constrains preclude the use of 1,3
- D. Regulatory restrictions on 1,3
- D, can limit the use for a portion of nurseries of this sector. For example, depending on the season, the deciduous fruit and nut tree growers may use 1,3
- D as an alternative on approximately 35% of nursery

land. These areas are able to achieve less than 12% moisture (up to 1.5 m) on light soils. Sit es on which 1,3
- D is used are not included in the nomination.USA CUN13 SOIL Nursery Stock Field Page 6 of 13

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 NEC ESSARY TO ENABLE THIS? Accordi ng to the requesting consortium and researchers (e.g., Hanson et al., 20 10; Hanson et al., 2009 ) advances using alternatives are being made. Some deciduous tree nurseries use a double application of 1,3
- D where moisture of less than 12% can be achieved on light soils, although weeding costs may

be higher. This is allowed by California certification regulations, except where township restrictions apply or where plantback restrictions prevent the planting of a rotational crop. The USG has reviewed all fact ors affecting transition rates in this sector. Based on this assessment the transition rate has been greatl y increased for most portions of this sector. For the area covered in this nomination, the USG believes that the narrative discussion included in th is document is technicall y valid. The USG has nominated amounts of meth yl bromide based onl y on those sub
- sectors that cannot transition away from methyl bromide at the accelerated rate. 6. SUMMARY OF RECENT RESEARCH Fumigant options are limited for per ennial nurseries due to nematode certification requirements, but other pests also require managing (Hanson et al., 2010). Even with methyl bromide, fumigation alone does not generall y provide an acceptable level of weed control during the growing of nurse ry

stock (Hanson et al., 2010) . This requires additional inputs such as tilling, hand
- labor and/or herbicides. Herbicides are frequently of limited value because of the challenge of not damaging the stock plants (Shrestha et al., 2008) . In the long
- term , California researchers are continuing to develop and integrate various approaches of pest management for perennial nurseries (Hanson et al., 2010; Hanson et al., 2009; Hanson et al., 2008; Hanson et al., 2007). Zasada et al. (2010) conducted trials at two raspberry nurseries in Washington and one in California , treatments included 1) Telone C35; 2) Iodomethane 50:50, 225 lb w/VIF, 350 lb w/HDPE, or 300 lb w/HDPE; 3) PicClor 60 38:60, 366 lb w/VIF or 427 lb w/HDPE; 4) Methyl bromide , 67:33, 350 lb or 400 lb w/HDPE. Results indicated that all treatments eliminated quackgrass and nutsedge. Volunteer potatoes were controlled b y all treatments compared to the unfumigated, but Telone C35 and PicClor were not as effective as meth yl bromide or iodomethane, whic h were comparable. Pratylenchus nematodes were controlled by all treatments, but some nematodes were found at one location with iodomethane. Agrobacterium tumefasciens populations were greatest with methyl bromide. All treatments, including methyl bromi de, reduced Phytophthora rubi comparably. Shrestha et al. (2008) found that 1) the alternative fumigants (iodomethane:chloropicrin, 1,3
- D, 1,3 - D:chloropicrin (61:35) with HDPE or VIF), and drip 1,3
- D/chloropicrin (InL ine) generally provided similar weed control to soils treated with methyl bromide:chloropicrin (98:2) ; 2) there were differences in weed species and weed densities at four locations; however, the efficacy ofUSA CUN13 SOIL Nursery Stock Field Page 7 of 13

alternatives, with regard to weed seed germination and weed control, were generall y comparable to methyl bromide treatments ; 3) a lternative fumigants and methyl bromide, in general, resulted in similar hand
- weeding efforts; 4) In general, there did not appear to be a difference between VI F or HDPE film in we ed control or hand
- weeding time
. Gao et al. (2010) conducted studies to 1) examine the potential of TIF film to reduce emissions and enhance efficacy

of altern ative fumigants, 2) examine the efficacy of lower use rates with TI F, and 3) evaluate the persistence of fumigants under TIF an d the effect of time to reduce exposure upon tarp - cutting. Results showed that 1,3
- D concentrations under TIF were at least three times greater than under standard film and half
- rates of 1,3
- D concentrations under TIF were at least as high as full
- rates under standard film. However, emissions upon tarp
- cutting were far greater than emissions after cutting standard film. This was the case even cutting two weeks after fumigation. Nematode and weed control efficacy was improved with TIF such that lower rat es were comparable to full
- rates with standard film. Surges of emissions must be addressed by

further research for worker protection. Fumigant trials previously reported (Hanson et al., 2007) in rose nurseries have continued to identify possible alternat ives (Hanson et al., 2008). Recent results of rose nursery trials at two locations indicated that 1,3
- D (373 kg/ha) used with standard or VIF films resulted in similar Pythium , Fusarium , and citrus nematode control compared to methyl bromide:chloropicrin (392 kg/ha of 98:2) used with standard HDPE film. Total weed populations in plots fumigated with alternatives were similar to plots treated with methyl bromide. 7. ECONOMIC FEASIBILITY OF ALTERNATIVES T his study calculated net revenue as gross revenu e minus operating costs. This is a good measure of the direct losses of income that may be suffered by

the users. N et revenue does not represent net income to the users. Net income, which indicates profitability of an operation for an enterprise, is gro ss 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 anal ys is of the nursery stock application 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 alternative identified as technicall y feasible

- in cases of low pest infestation 1

– was 1,3 - D /c hloropicrin. The economic factors that drive the feasibility analy sis 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) qualit y losses, which generall y affect the quantity and price received for the goods, 1 The USG does not request methyl bromide for use in areas of low to moderate pest pressure. Only cases wher e key

pests are present at moderate to high levels require methyl bromide for pest pressure.USA CUN13 SOIL Nursery Stock Field Page 8 of 13

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 anal yz ed crop budgets for pre
- plant sectors to determine the lik el y 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. Itis relatively eas y 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 usual ly

eas y 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 hav e 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 good indicator of the direct losses of income that may be suffere d 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 anal ys is. These measures represent different way s to assess the economic feasibility of methyl bromide alternatives for meth yl bromide users, who are nursery stock producers in this case. Because producers (suppliers) represent an integral part of any definition o f a market, we interpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using meth yl bromide. The economic measures provide the basis for making that determination. Certification requireme nts . The U.S. nomination includes those areas where 1,3
- D would not meet the regulatory requirements or would be limited by township caps. Under California regulations , nursery

crops must be “free of especially injurious pests and disease s ymptoms” in or der to qualify

for a CDFA Nursery

Stock Certificate for Interstate and Intrastate Shipments (CDFA, 200 9 ). If an approved fumigation is not used in the nursery , a nematode sampling procedure is imposed by

CDFA, and if nematodes are found all nursery stock in an area should be destro yed resulting in a complete loss. Meth yl bromide meets the certification guidelines. Also, in certain soil conditions, 1,3
- D meets certification guidelines; California township caps may limit the use of 1,3
- D.USA CUN13 SOIL Nursery Stock Field Page 9 of 13

If nematodes are found and the nursery stock is not “free of especiall y injurious pests and disease sy mptoms”, then a total loss is likely because the nursery

stock:  Would not qualify

for a CDFA Nursery

Stock Certificate for Interstate and Intrastate Shipments,  Would prob ably

not be marketable, since resale for planting is severel y restricted by the CDFA.  Should be destroy ed to prevent further infestation. Yield loss . It is likely

that yield losses would also occur where soil conditions are not ideal, but little data are available. The yield loss could be 100% if the nursery stock cannot be certified as pest - free. Reduced pesticide use . An effective fumigation results in a growth response that allows an initial growth spurt. This growth response helps maintain a healt hy plant, which is able to better handle the stress induced by pathogens and pests. A healthier plant consequently requires a fewer number of pesticide spray s during the season. Beyond the nursery . Healthier plants and trees provide benefits bey ond the nursery in terms of higher yi elds of fruit and nuts and reduced infestations. One hectare of nursery stock provides these benefits to many

hect ares producing fruits and nuts. California Rose Growers Currently , 1,3 - D /c hloropicrin is the likely alternati ve to methyl bromide for use in California r ose p roduction in locations where 1,3 - D use restrictions do not apply
. 1,3 - D appears to have similar yields as meth yl bromide , yet is a cheaper alternative, thus, growers may prefer to use 1,3 - D . However, towns hip restrictions and certification restrictions requiring specific soil conditions hinder growers from using 1,3 - D .USA CUN13 SOIL Nursery Stock Field Page 10 of 13

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

CALIFORNIA ROSE GROW ERS M ETHYL B ROMIDE 1,3 - D ICHLOROPRO PENE + C HLOROPICRIN P RODUCTION L OSS (%) 0% 0 % P RODUCTION PER H ECTARE ( CWT ) 38,112 38,112 * P RICE PER U NIT ( US $) $ 2 $2

= G ROSS REVENUE PER H ECTARE ( US $) $ 87,182 $ 87,182

- O PERATING C OSTS PER H ECTARE ( US $)* $ 72,511 $ 71,973

= N ET REVENUE PER H EC TARE ( US $) $ 14,671 $ 15,209 1. L OSS PER H ECTARE ( US $) $ - $ (537) 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ (2) 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% - 1% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% - 4% 5. O PERATING P ROF IT M ARGIN (%) 17% 17% * T he measures must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. California Deciduous Fruit and Nut Nursery Tree Growers Currently , 1,3 - D/chlorop icrin is the likely alternative to methyl bromide for use in California Deciduous Fruit and Nut Nursery Trees where 1,3
- D use restrictions do not apply
. 1,3 - D appears to have similar yields as methyl bromide yet is a cheaper alternative, thus, growers may prefer to use 1,3 - D. However, township restrictions and certification restrictions requiring specific soil conditions hinder growers from using 1,3
- D.USA CUN13 SOIL Nursery Stock Field Page 11 of 13

T ABLE 3. C ALIFORNIA D ECIDUOUS F RUIT AND N UT N URSERY T REE G ROWERS : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES CALIFORNIA DECIDUOUS FRUIT AND NUT NURSERY TREE GROWERS M ETHYL B ROMIDE 1,3 - D ICHLOROPROPENE + C HLOROPICRIN P RODUCTION L OSS (%) 0% 0 % P RODUCTION PER H ECTARE (BOX 25 LBS ) 45,898 45,898 * P RICE PER U NIT ( US $) $ 5 $5

= G ROSS REVENUE PER H E CTARE ( US $) $ 228,801 $ 228,801

- O PERATING C OSTS PER H ECTARE ( US $)* $ 97,490 $ 96,214

= N ET REVENUE PER H ECTARE ( US $) $ 131,311 $ 132,587 1. L OSS PER H ECTARE ( US $) $ - $ (1,276) 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ (4) 3. L OSS AS A P ERC ENTAGE OF G ROSS REVENUE (%) 0% - 1% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% - 1% 5. O PERATING P ROFIT M ARGIN (%) 57% 58% * T he measures must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross r evenue minus operating costs.USA CUN13 SOIL Nursery Stock Field Page 12 of 13

8 . RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES T ABLE 4. N OMINATION A MOUNT

SECTOR 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 Qua ntity Approved by Parties for 2012: Amount (kgs) 191 1,400 1,591 Ar ea (ha) 5 35 40 Rate 38 40 40 Transition from 2012 Baseline Adjusted Value Percentage (%) - 66% - 66% - 66% Quantity Required for 2013 Nomination: Amount (kgs) 

### 65 476 541 Ar ea (ha) 0 2 3 Rate 1 91 210 208 CITATIONS CDFA (California Department of Food and Agriculture). 200 9 . http://www.cdfa.ca.gov/phpps/PE/Nursery /NI PM.html ; Regulation for nursery and seed inspection (NIPM #3), http://www.cdfa.ca.gov//phpps/PE/Nursery /pdfs/nipm_3_regs_ns y_sees_insp.pdf ; Approved treatment and handling procedures to ensure against nematode pest infestation of nursery stock (NI PM #7), http://www.cdfa.ca.gov/phpps/PE/Nursery /pdfs/NIPM_7.pdf Gao, S., Qin, R., Cabrera, A., Hanson, B., Gerik, J., Wang, D., and Browne, G. 2010. Demonstration of low permeabili ty tarp technology

in soil fumigation for perennials. Annual International Research Conference on Methyl Bromide Alternatives (20 10 ). http://mbao.org/2010/Proceedings/026GaoSPerenni alTIFPAW.pdf Hanson, B. D., Gao, S., Gerik, J., Wang, D. , Qin, R., Cabrera, J. A., and Jhala, A. 20 10. Pacific area - wide program: Current status of the California perennial nursery sector. Annual International Research Conference on Meth yl Bromide Altern atives (20 10 ). http://mbao.org/2010/Proceedings/027HansonBPAW.pdf Hanson, B. D., Gao, S., Gerik, J., Qin, R., and Wang, D. 200 9. Perennial crop nursery sector progress —Pacific area
- wide pr ogram for MB alternatives. Annual International ResearchUSA CUN13 SOIL Nursery Stock Field Page 13 of 13

Conference on Meth yl Bromide Alternatives (200 9 ). http://www.mbao.org/2009/Proceedings/032HansonBMBAO2009PAWS ummary text.pdf Hanson, B. D., Gao, S., Gerik, J., Wang, D., and Qin, R. 2008. Pest control with California approved nursery

stock certification 1,3
- D treatments. Annual International Research Conference on Meth yl Bromide Alternatives (2008). http://www.mbao.org/2008/Proceedings/025HansonBMBAO2008PAWprojectsummary .pdf Hanson, B. D., Gao, S., McKenry , M., Gerik, J., Wang, D., Klonsky , K., Cox, D., Correiar, B., and Yates, S. 2007. Efficacy and 1,3
- D emissions with approved nursery stock certification treatments applied with two shank designs. Annual International Research Conference on Methyl Bromide Alternatives ( 2007 )
. http://www.mbao.org/2007/Proceedings/013HansonBMBAO2007PAWproject.pdf McKenry , M. V. 2000. Evaluation of alternatives to methyl bromide for soil fumigation at commercial fruit and nut tree nurseries. Contra ctor for California Association of Nursery man. Prepared for California Department of Pesticide Regulation. http://www.cdpr.ca.gov/docs/pestmgt/grants/98
- 99/finlrpts/98
- 0 281.pdf Schneider, S., T. Trout, J. Gerik, and H. Ajwa. 2004. Perennial crop nurseries

— performance of methyl bromide alternatives in the field. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2004). http://www.mbao.org/2004/Proceedings04/029%20SchneiderS%20Nursery %20paper%20M BAO%202004.pdf Shrestha, A., Browne, G. T., Lampinen, B. D., Schneider, S. M., Simon, L . and Trout, T. J. 2008. Perennial crop nurseries treated with methyl bromide and alternative fumigants: effects on weed seed viability , weed densities, and time required for hand weeding. Weed Technology

22:267 - 274. USDA - APHIS (Animal and Plant Health Inspection Service), Plant Protection and Quarantine. 2007. Official regulatory

protocol for wholesale and production nurseries containing plants infected with Phytophthora ramorum
. http://www.aphis.usda.gov/plant_health/plant_pest_info/pram/downloads/pdf_files/CNPv8. 0 - 7 - 20 - 07.pdf USDA - APHIS (Animal and Plant Health Inspection Service), Plant Protection and Quarantine. 2004. Sudden Oak Death. Amended order restricting movement of nursery stock from California nurseries, April, 2004. http://www.aphis.usda.gov/new sroom/hot_issues/sod/content/printable_version/SOD_Order _4 - 22 - 04.pdf Zasada, I., Pinkerton, J. N., Walters, T., and Particka, M. 2010. Meth yl bromide alternatives trials in raspberry

nurseries. Annual International Research Conference on Methyl Bromide A lternatives (20 10 ). http://mbao.org/2010/Proceedings/030WaltersTRBnurs.pdf