USA CUN13 SOIL Nursery Stock Field Page 1 of 13

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN13 SOIL NURSERY STOCK—FRUIT, NUT, AND ROSE Open 

Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Nursery Stock—Fruit, Nut, 

And Rose in Open Fields (Submitted in 2011 for 2013 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Nursery Stock—Fruit, Nut, And Rose

Open Field

QUANTITY OF METHYL BROMIDE NOMINATED:

TABLE 1: QUANTITY OF METHYL BROMIDE NOMINATED

Year NOMINATION AMOUNT

2013 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 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 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 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

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 CUN13 SOIL NURSERY STOCK Field 

* Identical to paper documents
USA 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 commercial growers of rose bushes, and 

such diverse fruit crops as apricots, peaches, prunes, nectarines, cherries, plums, apples, pears, 

Asian pears, and ornamental pears. Nut trees produced by 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 valleys of California. 

Stock plants must meet state-mandated certification requirements for plant material (CDFA, 

2009; 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 on methyl bromide to provide effective fumigation on soils in diverse 

locations with various soil types 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 

control to enable nurseries to attain certification for stock. However, use of 1,3-D is restricted by 

township cap regulations and requires a soil type 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 populations. 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 typical 

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 variety of different trees. Nursery stock is grown on a 

cropping system 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 year. The tree production 

cycle can be anywhere from a single year to several years depending on the type of tree crop 

being produced. Nursery production of trees takes from one to four years in the ground 

depending on the type being produced. In order to prepare the ground for planting, the fields are 

disked, deep ripped, leveled, and then fumigated to meet certification standards set by the 

California Department of Food and Agriculture (CDFA, 2009). Methyl bromide is applied by

shank and treated area is usually covered with a tarp. The fumigation is carried out around 

August and September, and planting begins in October, and may continue through January. 

Nursery roses are grown in open field plots. Production includes 1-year and 2-year rose bushes, 

rose trees, climbing roses, miniature roses, rose ground cover, rose shrubs, and heirloom roses. 
USA CUN13 SOIL Nursery Stock Field Page 4 of 13

A typical crop rotation for a two-year rose crop includes one year fallow, followed by one or two 

years of rotational crops, and then a two-year rose crop. The two-year rose crop cycle begins 

with land preparation (removing the cover crop, deep cultivation, and fumigation with methyl 

bromide), followed by planting the rootstock and T-bud grafting. In late winter of the first year, 

the rootstock tops are removed. The rose crop matures by the second autumn and is then 

harvested. This cycle varies depending on the type of rose crop being produced (e.g., two-year 

roses, one-year 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 relatively 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 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.

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 regulations for open 

field nursery stock in California (CDFA, 2009). However, these regulations specify that 1,3-D is 

only acceptable in certain soil types 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 heavy 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 bromide 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 “free of especially injurious pests and disease 

symptoms” in order to qualify for a CDFA Nursery Stock Certificate for Interstate and Intrastate 

Shipments (CDFA, 2009). 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 destroyed 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 pathogens and weeds, which are also important pests of nurseries and 

part of the pest-free certification requirements, requires rigorous multi-year testing of 
USA CUN13 SOIL Nursery Stock Field Page 5 of 13

alternatives. This nomination is for the critical use of methyl bromide where alternatives cannot 

be used or are not effective.

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Nurseries in this sector are covered by certification requirements as described in state (e.g., 

CDFA, 2009) and federal (e.g., USDA-APHIS, 2007; USDA-APHIS, 2004) regulations. For 

example, “Section 3640, CCR, makes it mandatory that nursery stock for farm planting be 

commercially clean with respect to economically important nematodes” (CDFA, 2009). 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 additional pest control measures. 

If nematodes are found and the nursery stock is not “free of especially injurious pests and disease 

symptoms”, then a total loss is likely because the nursery stock: 1) would not qualify for a 

CDFA Nursery Stock Certificate for Interstate and Intrastate Shipments, 2) would likely not be 

marketable since resale for planting is severely restricted by the CDFA, and 3) should be 

destroyed to prevent further infestation.

CALIFORNIA (CDFA, 2009)

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.

Methyl bromide is used on nursery 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. Sites 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 NECESSARY TO ENABLE 

THIS?

According to the requesting consortium and researchers (e.g., Hanson et al., 2010; 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 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 

Fumigant options are limited for perennial nurseries due to nematode certification requirements, 

but other pests also require managing (Hanson et al., 2010). Even with methyl bromide, 

fumigation alone does not generally provide an acceptable level of weed control during the 

growing of nursery 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 by all treatments compared to the 

unfumigated, but Telone C35 and PicClor were not as effective as methyl bromide or 

iodomethane, which 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 

bromide, 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 (InLine) 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 of 
USA CUN13 SOIL Nursery Stock Field Page 7 of 13

alternatives, with regard to weed seed germination and weed control, were generally comparable 

to methyl bromide treatments; 3) alternative fumigants and methyl bromide, in general, resulted 

in similar hand-weeding efforts; 4) In general, there did not appear to be a difference between 

VIF or HDPE film in weed 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 alternative fumigants, 2) examine the efficacy of lower use rates with 

TIF, and 3) evaluate the persistence of fumigants under TIF and 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 rates 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 alternatives (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 

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. 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 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 technically feasible 

- in cases of low pest infestation1– was 1,3-D/chloropicrin.

The economic factors that drive 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, 

 

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.
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 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 good indicator of the direct losses of income 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 nursery stock 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.

Certification requirements. 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 symptoms” in 

order to qualify for a CDFA Nursery Stock Certificate for Interstate and Intrastate Shipments 

(CDFA, 2009). 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 destroyed resulting in a complete loss. Methyl 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 especially injurious pests and disease 

symptoms”, 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 probably not be marketable, since resale for planting is severely restricted by the 

CDFA.

 Should be destroyed 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 healthy plant, which is able to better 

handle the stress induced by pathogens and pests. A healthier plant consequently requires a 

fewer number of pesticide sprays during the season.

Beyond the nursery. Healthier plants and trees provide benefits beyond the nursery in terms of 

higher yields of fruit and nuts and reduced infestations. One hectare of nursery stock provides 

these benefits to many hectares producing fruits and nuts.

California Rose Growers

Currently, 1,3-D/chloropicrin is the likely alternative to methyl bromide for use in California 

rose production in locations 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 10 of 13

TABLE 2. CALIFORNIA ROSE GROWERS: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

CALIFORNIA ROSE GROWERS METHYL BROMIDE

1,3-DICHLOROPROPENE 

+ CHLOROPICRIN

PRODUCTION LOSS (%) 0% 0%

 PRODUCTION PER HECTARE (CWT) 38,112 38,112

* PRICE PER UNIT (US$) $ 2 $2

= GROSS REVENUE PER HECTARE (US$) $87,182 $ 87,182

- OPERATING COSTS PER HECTARE (US$)* $72,511 $ 71,973

= NET REVENUE PER HECTARE (US$) $ 14,671 $ 15,209

1. LOSS PER HECTARE (US$) $ - $ (537)

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $ - $ (2)

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -1%

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0% -4%

5. OPERATING PROFIT MARGIN (%) 17% 17%

*The 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/chloropicrin 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

TABLE 3. CALIFORNIA DECIDUOUS FRUIT AND NUT NURSERY TREE GROWERS: ECONOMIC IMPACTS OF 

METHYL BROMIDE ALTERNATIVES

CALIFORNIA DECIDUOUS FRUIT AND NUT 

NURSERY TREE GROWERS METHYL BROMIDE

1,3-DICHLOROPROPENE 

+ CHLOROPICRIN

PRODUCTION LOSS (%) 0% 0%

 PRODUCTION PER HECTARE (BOX 25LBS) 45,898 45,898

* PRICE PER UNIT (US$) $ 5 $5

= GROSS REVENUE PER HECTARE (US$) $ 228,801 $ 228,801

- OPERATING COSTS PER HECTARE (US$)* $ 97,490 $ 96,214

= NET REVENUE PER HECTARE (US$) $ 131,311 $ 132,587

1. LOSS PER HECTARE (US$) $ - $ (1,276)

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $ - $ (4)

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -1%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE 

(%) 0% -1%

5. OPERATING PROFIT MARGIN (%) 57% 58%

*The measures must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals 

gross revenue minus operating costs.
USA CUN13 SOIL Nursery Stock Field Page 12 of 13

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

TABLE 4. NOMINATION AMOUNT 

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 

Quantity Approved by 

Parties for 2012:

Amount 

(kgs)

 

191 

 

1,400 

 

1,591 

Area (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

Area (ha) 0 2 3

Rate 191 210 208

CITATIONS

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

Gao, S., Qin, R., Cabrera, A., Hanson, B., Gerik, J., Wang, D., and Browne, G. 2010. 

Demonstration of low permeability tarp technology in soil fumigation for perennials. 

Annual International Research Conference on Methyl Bromide Alternatives (2010).

http://mbao.org/2010/Proceedings/026GaoSPerennialTIFPAW.pdf

Hanson, B. D., Gao, S., Gerik, J., Wang, D., Qin, R., Cabrera, J. A., and Jhala, A. 2010. Pacific 

area-wide program: Current status of the California perennial nursery sector. Annual 

International Research Conference on Methyl Bromide Alternatives (2010).

http://mbao.org/2010/Proceedings/027HansonBPAW.pdf

Hanson, B. D., Gao, S., Gerik, J., Qin, R., and Wang, D. 2009.Perennial crop nursery sector 

progress—Pacific area-wide program for MB alternatives. Annual International Research 
USA CUN13 SOIL Nursery Stock Field Page 13 of 13

Conference on Methyl Bromide Alternatives (2009).

http://www.mbao.org/2009/Proceedings/032HansonBMBAO2009PAWSummarytext.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 Methyl 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. Contractor for California Association of 

Nurseryman. Prepared for California Department of Pesticide Regulation. 

http://www.cdpr.ca.gov/docs/pestmgt/grants/98-99/finlrpts/98-0281.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/newsroom/hot_issues/sod/content/printable_version/SOD_Order

_4-22-04.pdf

Zasada, I., Pinkerton, J. N., Walters, T., and Particka, M. 2010. Methyl bromide alternatives 

trials in raspberry nurseries. Annual International Research Conference on Methyl Bromide 

Alternatives (2010). http://mbao.org/2010/Proceedings/030WaltersTRBnurs.pdf