USA CUN11 SOIL Strawberry Fruit Open Field Page 1 of 14 

### NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 SOIL STRAWBERRY FRUIT Open Field

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Strawberry Fruit Grown in Open Fields (Submitted in 2009 for 2011 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Strawberry Fruit Open Field

QUANTITY OF METHYL BROMIDE REQUESTED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION



### Year N OMINATION 

### A MOUNT



### 2011 1,023,471 kilograms

NOMINATING PARTY CONTACT DETAILS: Contact Person: Hodayah Finman Title: Foreign Affairs Officer 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) 647-1123 Fax: (202) 647-5947

E-mail: finmanhh@state.gov

Following the requirements of Decision IX/6 paragra ph (a)(1) The United States of America has determin ed that the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for
this use would result in a significant market disru ption

. . 

### ■ Yes  No

Signature Name Date

Title:

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat we bsite under Decision Ex. I/4(8).)

This form is to be used by holders of single-year e xemptions to reapply for a subsequent year’s exempt ion (for example, a Party holding a single-year exemption fo r 2005 and/or 2006 seeking further exemptions for 2 007). It does not replace the format for requesting a critic al-use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation 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 Pa rty need not re-submit that earlier information.USA CUN11 SOIL Strawberry Fruit Open Field Page 2 of 14 CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger Title: Director (Acting) 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 CUN11 SOIL STRAWBERRY FRUIT Open Field 14

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat

USA CUN11 SOIL STRAWBERRY FRUIT Open Field

* Identical to paper documentsUSA CUN11 SOIL Strawberry Fruit Open Field Page 3 of 14 

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

STRAWBERRY FRUIT

1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICA L USE

This nomination is for methyl bromide for the produ ction of strawberries in California, Florida, and several other states in the eastern U.S. (Alaba ma, Arkansas, Georgia, Illinois, Kentucky, Louisiana, Maryland, Mississippi, Missouri, New Jer sey, North Carolina, Ohio, South Carolina, Tennessee, and Virginia). Strawberry growers have been replacing methyl bromide and reducing its use rates in all production areas.

California . California growers have a critical need for methy l bromide, for 2011, to treat fields where alternatives are not available due to regulat ions or to complete a fumigation program that includes a once per three year treatment with methy l bromide to manage two new diseases. Iodomethane is unlikely to be registered for use in California in the near future and, therefore, cannot reduce methyl bromide critical needs. Altho ugh use of methyl bromide has been reduced over the years (approximately one-third of strawber ry land was treated with methyl bromide in 2006 (NASS, 2007; Table 1) this trend is in danger of being slowed if the incidences of two new diseases continue to increase in strawberry fields. Macrophomina and Fusarium oxysporum have emerged in some fields that have been treated annually with alternatives (Legard, personal communication, 2008). These pathogens have not bee n found in any of the fields that have been treated annually with methyl bromide (Legard, perso nal communication, 2008).

The lowest formulation of methyl bromide that is li kely to be allowed in California is 57:43 (methyl bromide:chloropicrin) due to severe restric tions on the use of chloropicrin. High rates of chloropicrin (greater than 225 kg/ha) are restricte d by regulation and lower rates may not be optimally effective against plant pathogens. Towns hip caps restricting the use of 1,3-D may affect between 5,700 and 9,000 hectares by 2011 (Ca lifornia Strawberry Commission, 2008— Appendix JJ.11).

Florida . Iodomethane is now registered in Florida. Fumiga nt trials indicate comparable results to methyl bromide. A transition from methyl bromid e to iodomethane is likely to occur quickly if first-users of iodomethane report successes in t he 2008 and 2009 seasons. However, use rates, formulation and differences in application techniqu es require development of protocols for effective use of the new product. Until sufficient experience is gained with iodomethane, methyl bromide is considered critical for a portion of lan d for the 2011 use season.

Some production areas in Florida are located above karst geological formations. For these areas, there are restrictions on the use of 1,3-D to preve nt contamination of ground water. Fields with key disease problems have achieved good control wit h chloropicrin, but those with sting nematode problems require either methyl bromide or 1,3-D. Results of several years of research trials in Florida with high barrier films indicate that an effective rate of methyl bromide with these films may be as much as 50% less than the his torical use rate for some Florida strawberryUSA CUN11 SOIL Strawberry Fruit Open Field Page 4 of 14 

### production land (Noling and Botts, 2007a; Noling an d Botts, 2007b). Rates that are 25-50% lower than historical methyl bromide rates are bein g used in Florida as the use of VIF-type films

has increased. This has allowed a reduced rate of methyl bromide while maintaining efficacy.

Eastern Region . Growers in the eastern U.S. have reduced their us e of methyl bromide from previous years. Continuing research and extension (e.g., Welker et al., 2008) suggests that growers will transition to alternatives as rates an d application methodologies are optimized. For 2011, this consortium requested on average a rate o f 70 kg methyl bromide/ha to be used with a 50:50 (methyl bromide: chloropicrin) formulation. Diverse climatic areas even within a single state (e.g., coastal, mountain, piedmont) prevent a uniform description of an “eastern strawberry production” region. This strawberry industry is de -centralized and outside of North Carolina consists of small family farms that directly market strawberries through “U-pick”, “ready-pick”, roadside stands, and farmers markets (Sydorovych et al., 2006). In the eastern U.S, many of the farms contend with yellow and purple nutsedges, whi ch are significant problems in some areas

more than others. Farmers with a low incidence of nutsedge use other chemicals, such as chloropicrin, 1,3-D, and metam-sodium to manage dis eases such as black root rot, nematodes, and other weeds (Sydorovych et al., 2006). Iodomet hane will likely have increased use as growers gain experience with its application.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

Alternatives are considered not feasible where 1) t hey have not been sufficiently tested or protocols have not been sufficiently developed for their use, 2) costs are excessive, 3) application difficulties exist due to such factors as hilly ter rain or equipment requirements, 4) areas of environmental sensitivity or characteristics reduce their efficacy, 5) regulatory restrictions prevent their use, 6) pest pressure is to such an e xtent that alternatives are not effective.

Approximately two-thirds of strawberry land in Cali fornia use alternatives to methyl bromide (Table 2). In California, township caps currently restrict the use of 1,3-D on approximately 40- 62% of total strawberry land (California Strawberry Commission, 2008). High rates of chloropicrin (greater than 225 kg/ha) are restricte d by regulation and lower rates are not optimally effective against plant pathogens. One a lternative, iodomethane, is not registered for

use in California.

In Florida, based on the 2010 nomination, approxima tely one-third of strawberry production land has been considered critical for methyl bromide (Ta ble 1). In eastern U.S. production areas, based on the 2010 nomination, approximately 18% of strawberry production land has been considered critical for methyl bromide (Table 1). Iodomethane has recently been registered in all of the strawberry production states, except Califor nia. Its use will likely replace a significant portion of the critical use area for methyl bromide . However, because its registration is new it is not known how rapidly a transition to iodomethane w ill take place by commercial operations (Toth, 2008). High-percent iodomethane formulation s (98:2) have not been tested rigorously to support research findings. Identifying effective u se rates and effective formulation ratios are only beginning to be addressed after the 2008 regis tration. Equipment adaptation and product availability are concerns for growers who have no e xperience with the product. Consequently,USA CUN11 SOIL Strawberry Fruit Open Field Page 5 of 14 

### while iodomethane may be a promising soil treatment , there remains a critical need for methyl bromide until issues of concern are satisfactorily resolved for iodomethane.

As previously stated, some production areas in Flor ida are located above karst geological

formations and there are restrictions on the use of 1,3-D. Sting nematode problems require either methyl bromide or 1,3-D. Some fields with key dise ase problems have achieved good control with chloropicrin, although there may be regulatory restrictions on its use at high rates.

Alternative strategies for pest managment where wee d pressure is strong include additional herbicides to provide acceptable weed management. However, this may require a 30-day period prior to planting (Noling and Botts, 2007a). Addit ional technical problems may be encountered, such as proper distribution of low rates of methyl bromide, which relies on back pressure measured at the flow divider (Noling and Botts, 200 7a; Gilreath et al., 2005c). Noling and Botts (2007a) pointed out that taller and narrower beds r equired significantly more hand labor to lay VIF film due to slippage during the laying operatio n. Newer formulations of VIF films may help adjust for this problem.

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a certification standard for strawberry fruit production.

4. PROPORTION OF CROP USING METHYL BROMIDE

T ABLE 

### 2. P ROPORTION OF 

### C ROP 

### U SING 

### M ETHYL 

### B ROMIDE

R EGION WHERE METHYL

BROMIDE USE IS REQUESTED T OTAL CROP

AREA ( HA ) A REA NOMINATED

FOR METHYL

BROMIDE USE IN
2010 (H A ) P ROPORTION 1 OF TOTAL

CROP AREA TO BE TREATED

WITH METHYL BROMIDE (%)

California 14,500 2 4,856 33 Eastern U.S. (15 states) 2,600 3 474 18

Florida 3,000 2 1,022 34

1 Based on the amount of methyl bromide nominated fo r the 2010 use season for strawberry fruit producti on.

2 NASS, 2007. 2006-season data.

3 Based on estimates from various recent extension p ublications of states associated with the requestin g consortium.



### 5. 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 W HAT ALTERNATIVE STRATEGIES ARE USED TO

CONTROL THE TARGET PATHOGENS AND WEEDS W ITHOUT METHYL

BROMIDE THERE.

Pest problems vary, and therefore, no one strategy is appropriate for the variety of pests and growing conditions in strawberry production. Alter natives are used on two-thirds of strawberry production land in California. For example, “Methyl bromide is often being used in rotation with alternative fumigants. Many growers will use alternative fumigants for 2-3 years then rotate back to methyl bromide to clean up emerging weed and disease problems. While, in some locations, local permit conditions may not allow th e use of methyl bromide due to the proximity of sensitive sites such as schools or housing, thus alternative fumigants such a s Inline are used.USA CUN11 SOIL Strawberry Fruit Open Field Page 6 of 14 

### In these locations, growers may accept lower return s over time due to higher weeding costs and reduced yields or they will cease growing strawberr ies in those fields if soil borne disease losses and weed density gets too high” (California Strawberry Commission, 2008).

Furthermore, in California, the choice of fumigant “is influenced by a number of factors including the regulatory situation for a particular ranch, their financial situation—can they afford methyl bromide, the type of crop they are pr oducing (summer plantings typically do not use methyl bromide because they have a short produc tion season while growers in the northern district are more likely to use methyl bromide sinc e they have a very long season), the prevalence of disease or weed problems, etc...” (Legard, personal communication, 2008).

In the Florida and the eastern U.S., an area-wide r esearch program (Welker et al., 2008; Welker et al., 2007) has highlighted successes with altern atives (e.g., InLine ® 

### , chloropicrin) and reduced rates of methyl bromide (150 kg ai/ha). Based on t he 2010 U.S. nomination for methyl bromide, alternatives are used on two-thirds of strawberry l and in Florida and approximately 82% of strawberry land in the eastern U.S. (Table 2). Pre liminary research conducted on a commercial

farm in North Carolina where black root rot and win ter weeds were the key pests (with low nutsedge pressure) indicated that in some situation s the efficacy of alternative treatments with a high barrier films was similar to a treatment of 30 0 kg methyl bromide/ha with a standard film. The nomination for 2011 is for areas where pest pre ssure is moderate to high and alternatives have not been sufficiently adapted to the areas of concern.

6. 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?

In California, expansion of alternative methods to critical areas “does not appear to be likely due to the emergence of two new soil borne disease prob lems and the persistence of the yellow nutsedge weed problem. An alarming number of field s in Santa Maria, Oxnard and Orange County, that have not been fumigated with methyl br omide for more than two years, are experiencing increasing losses to charcoal rot ( Macrophominia phaseolina) and Fusarium wilt ( F. oxysporum )” (California Strawberry Commission, 2008). In ad dition restrictions on the use of 1,3-D in California and Florida limit its expans ion to other areas. If use rates, formulation, and availability issues are resolved iodomethane co uld expand in Florida and eastern U.S. strawberry growing areas where it is registered.

Nevertheless, the California Strawberry Commission has funded Farming Without Fumigants Initiative whose goal is to develop strawberry frui t production methods that can avoid the complexities of highly regulated fumigants. This r esearch includes collaboration with the University of California and USDA.

In Florida, iodomethane may be used in 2008 for the first time and could be a replacement for methyl bromide if use this season proves to be acce ptable. A transition period is likely to be necessary to allow protocols for iodomethane to be developed for commercial production ofUSA CUN11 SOIL Strawberry Fruit Open Field Page 7 of 14 

### strawberries in Florida. The adoption of VIF over the past two years has increased the efficacy of fumigants such that lower use rates are effectiv e.

In the eastern U.S. adoption of VIF-type films is a lso occurring and alternatives are being used. However, for some areas methyl bromide has allowed production on marginal land or in the case of the many small farms, land that is not able to b e rotated out of strawberries due to the

economic situation of the farmer. Iodomethane will likely present a feasible alternative with excellent efficacy (SE Regional Strawberry Integrat ed Management Guide, 2008), but as is the case in Florida, a transition period for adoption o f iodomethane is necessary for production areas in the eastern U.S. to allow protocols for iodometh ane to be developed for commercial strawberry production (Toth, 2008).

7. SUMMARY OF RECENT RESEARCH

California . According to Legard (personal communication, 2008 ) with regard to Macrophomina

and Fusarium oxysporum

, “...neither disease was a problem before growers star ted using alternative fumigants, although we have not seen th ese disease problems in fields that have been strip/bed fumigated with methyl bromide (this metho d is used about 20% of the time in Santa Maria). The key consideration may be the shift fro m broadcast fumigation to drip fumigation. We are conducting studies this fall to see if high rates of fumigants applied through the drip tape can control these diseases. We have seen Macrophom ina occur in fields that were drip fumigated with 100% Pic. However, growers are rest ricted from applying rates above 200 lbs/a, so we are testing higher rates to see if they are e fficacious. If so, we would then need to find a way to convince local regulators to allow drip appl ications at those rates. Another reason for the increase in disease problems on fields not trea ted with methyl bromide may be related to the fact that MB disperses better and has a longer half -life than Pic. Straight MB does have fungicidal properties. Broadcast applications of s traight Pic are strictly regulated and many counties either prohibit them or restrict their rat es (in Ventura County they will allow only 125 lbs/a) to levels that are not efficacious. ”



### In an attempt to address the problem, some growers have returned to using a methyl bromide treatment after two years treatment with alternativ es in order to “clean-up” the soil contaminated with both emerging pathogens and weeds. Norton (20 08) reported that excellent weed and disease control have been achieved with drip-applie d 1,3-D/chloropicrin (InLine) followed 5-8 days later by metam-sodium. However, weed control was highly dependent on optimal fumigant placement, which has not always been applied.

Fennimore et al. (2008) reported:

• High barrier tarps improve efficacy at reduced rate s of drip-applied 1,3-D, iodomethane, and methyl bromide. This effect did not appear to occur with chloropicrin used alone.

• Drip applied 1,3-D/chloropicrin (InLine), iodometha ne/chloropicrin, and methyl bromide/chloropicrin resulted in comparable yields in two locations.

• Totally impermeable films glued well and enhanced r etention of 1,3-D, iodomethane, and methyl bromide compared to standard films.

• Test plots that were treated with steam and Brassic a meal provided good yields in two

locations.USA CUN11 SOIL Strawberry Fruit Open Field Page 8 of 14 

### • Test plots treated with steam also provided good we ed control.

Florida and the Eastern Region . Iodomethane may offer an effective alternative to methyl bromide, although 2008 is the first year where it c an be used commercially. Consequently,

certain uncertainties must be resolved and necessit ate a critical need for methyl bromide for a portion of strawberry land until a transition can b e complete. According to the Florida request for the critical use of methyl bromide, " Iodomethane has been trialed extensively in replica ted small plot research across the crop needs and soil types currently treated with methyl bromide in Florida. We have been working with Arysta LifeScie nces in evaluating various cropping and efficacy components of iodomethane. Midas received a registration in the state of Florida on July 7, 2008. We anticipate additional grower use and trial work this fall with further acreage of Florida strawberries, tomatoes and peppers recei ving treatment. A major impediment to adoption of this alternative is the extensive risk mitigation and management requirements associated with its use. The expense of the produc t and complexity of implementing these requirements have significantly reduced the enthusi am of growers for this alternative ."

In Florida, trials were conducted that assessed iod omethane (either drip- or chisel-applied). Iodomethane (and various 1,3-D/chloropicrin treatme nts) resulted in yields that were comparable to methyl bromide treated plots (Noling, 2008). Ho wever, variability between test sites were said to be a result of application problems. These will have to be resolved prior to optimal

commercial use of these alternatives.

Iodomethane is also registered in the eastern straw berry-growing states comprising this consortium. North Carolina State University extens ion rated iodomethane:chloropicrin (50:50) as providing excellent control of diseases nematode s and good to excellent control of weeds, including nutsedge (Welker, 2008). A formulation o f 98:2 (iodomethane:chloropicrin) has been marketed but not well-studied. Poling and Schiavon e (2008) found that a 50:50 formulation of iodomethane resulted in the highest numerical total and marketable yield of any treatment, although not significantly different than methyl br omide. According to the researchers, “Total and marketable yields were significantly greater fo r fumigated soil than the untreated control

treatments. Midas 50:50 at the 180 lb/A broadcast rate with standard plastic, and Midas 50:50 at the 120 lb/A broadcast rate with VIF had the hig hest yields in the study, but were not significantly different from methyl bromide at 175 lb/A with VIF. It is very interesting that the lower rate of Midas 50:50 (120 lb/A with VIF) was s ignificantly higher in total and marketable yield than Midas 50:50 at the 140 and 160 rates wit h VIF. Also, the 180 lb/A rate (with VIF) was 7,272 lb/A lower in marketable yield than the 1 20 lb/A rate of Midas 50:50 (with VIF).”

Welker et al. (2008) found that in South Carolina t rials weed control was achieved under VIF with 1,3-D/chloropicrin (35 gal Telone C35), iodome thane/chloropicrin (168 kg/ha 50:50), and methyl bromide/chloropicrin (146 kg/ha, 50:50). Ho wever yield was significantly reduced with the 1,3-D/chloropicrin. Researchers suspected that under VIF, that rate was too high stunted plants. In North Carolina trials, drip applied 1,3 -D/chloropicrin (InLine) and PicClor 60 resulted in excellent annual weed control under VIF, where p revious data had indicated unacceptable

weed control. Extension conducted an on-farm field day, which provided information on methyl bromide alternatives to growers.USA CUN11 SOIL Strawberry Fruit Open Field Page 9 of 14 

### Norton (2008) reported that use of 1,3-D/chloropicr in followed by metam-sodium with appropriate water moisture could achieve excellent disease and weed control. A 21-d waiting period was required prior to transplanting. As wit h the situation in Florida, use experience, availability, and equipment and rate adjustments fo r the new product may require a period of transition for a portion of strawberry land making some methyl bromide critical for 2011.

8. ECONOMIC FEASIBILITY OF ALTERNATIVES

The following economic analysis is organized by met hyl bromide critical use application regions.

In this study net revenue is calculated as gross re venue minus operating costs. This is a good

measure to describe the direct losses of income tha t may be suffered by the users. It should be noted that net revenue does not represent net incom e to the users. Net income, which indicates profitability of an operation of an enterprise, is gross revenue minus the sum of operating and

fixed costs. Net income should be smaller than the net revenue measured in this study. Fixed

costs were not included because it is often difficu lt to measure and verify.

Summary of Economic Feasibility

The economic analysis of the strawberry fruit appli cation compared data on yields, crop prices, revenues and costs using methyl bromide and using a lternative pest control regimens in order to estimate the loss of methyl bromide availability. The alternatives identified as technically feasible in cases of low pest infestation for Flori da and the eastern U.S. states are: (a) Iodomethane and (b) 1,3-D/chloropicrin followed by metam sodium. For California, the primary alternative is 1,3-D/chloropicrin followed by metam sodium. Iodomethane is not registered for

use in California.

The economic factors that drive the feasibility ana lysis for fresh market strawberry fruit use of methyl bromide are 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 and yield losses.

Crop budgets were analyzed 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 isola tion.

(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 crop s may provide high revenues but may alsoUSA CUN11 SOIL Strawberry Fruit Open Field Page 10 of 14 

### entail high costs. Losses of even a small percenta ge 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 goo d indicator as to 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 oper ating 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 en terprise. Again, operating costs may be

difficult to measure and fixed costs even more diff icult, therefore fixed costs were not included in the analysis.

These measures represent different ways to assess t he economic feasibility of methyl bromide alternatives for strawberry fruit producers. Becau se producers (suppliers) represent an integral part of any definition of a market, the threshold o f significant market disruption is met if there is a significant impact on commodity suppliers using m ethyl bromide. The economic measures provide the basis for making that determination.

In the case of strawberry fruit production, for the eastern growers that have access to iodomethane, an impact of 1-4% in gross revenue is expected in the first year of use due to increased costs to retrofit application equipment ( hoses, nozzles, flow meters) that will allow the

use of iodomethane. This cost is estimated to be a pproximately $600-$700 per acre based on USG estimates. Southeastern and Florida strawberry growers that use iodomethane are expected to experience no change in yield or quality. See t ables 3 and 4 below.

For California strawberry producers, there is no ch ange in impacts from previous year estimates as iodomethane is under registration review but reg istration is not expected in the near future. The loss to gross revenue for growers using alterna tives to methyl bromide is estimated to remain about 14% as compared to the use of methyl b romide. Table 5 illustrates the 2008 economic impact assessment for California strawberr y fruit growers.USA CUN11 SOIL Strawberry Fruit Open Field Page 11 of 14 T ABLE 3. F LORIDA F RUIT AND V EGETABLE G ROWERS A SSOCIATION : E CONOMIC I MPACTS OF M ETHYL

B ROMIDE A LTERNATIVES

FLORIDA FVGA M ETHYL B ROMIDE I ODOMETHANE 1,3 D + PIC

P RODUCTION L OSS (%) 0% 0% 14%

P RODUCTION PER H ECTARE 2,989 2,989 2,559

* P RICE PER U NIT ( US $) $ 32.80 $ 32.80 $ 32.8

= G ROSS R EVENUE PER H ECTARE ( US $) $ 98,064 $ 98,064 $ 83,942

- O PERATING C OSTS PER H ECTARE ( US $)** $ 52,571 $ 56,525 $ 51,586

= N ET R EVENUE PER H ECTARE ( US $) $ 45,493 $ 41,538 $ 32,086

L OSS M EASURES *

1. L OSS PER H ECTARE ( US $) $ 0 $ 3,955 $ 13,407

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ 0 $ 16.8 $ 56.96

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 4% 14%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 9% 29%

5. O PERATING P ROFIT M ARGIN (%) 46% 42% 38%

**Note that the measures in the tables below must b e interpreted carefully. Operating costs do not in clude fixed costs and net revenue equals gross revenue minus op erating costs.

T ABLE 4. S OUTH E ASTERN S TRAWBERRY C OMMISSION : E CONOMIC I MPACTS OF M ETHYL B ROMIDE
A LTERNATIVES South Eastern Strawberry Commission M ETHYL B ROMIDE I ODOMETHANE 1,3 D + PIC

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE 14,011 14,011 12,044

* P RICE PER U NIT ( US $) $ 2.89 $ 2.89 $ 2.89

= G ROSS R EVENUE PER H ECTARE ( US $) 40,463 $ 40,463 $ 34,784

- O PERATING C OSTS PER H ECTARE ( US $)** $ 33,175 $ 33,611 $ 32,744

= N ET R EVENUE PER H ECTARE ( US $) $ 7,288 $ 6,853 $2,039

L OSS M EASURES *

1. L OSS PER H ECTARE ( US $) $ 0 $ 436 $ 5,249

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ 0 $ 2.88 $ 34.69

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 1% 13%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 6% 72%

5. O PERATING P ROFIT M ARGIN (%) 18% 17% 6%

**Note that the measures in the tables below must b e interpreted carefully. Operating costs do not in clude fixed costs and net revenue equals gross revenue minus op erating costs.USA CUN11 SOIL Strawberry Fruit Open Field Page 12 of 14 T ABLE 5. C ALIFORNIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

CALIFORNIA M ETHYL B ROMIDE PIC + MB 1,3 D + PIC

P RODUCTION L OSS (%) 0% 15% 14%

P RODUCTION PER H ECTARE 49,410 41,999 42,475

* P RICE PER U NIT ( US $) $ 1.37 $ 1.37 $ 1.37

= G ROSS R EVENUE PER H ECTARE ( US $) $ 67,537 $ 66,020 $ 58,057

- O PERATING C OSTS PER H ECTARE ( US $)** $ 66,849 $ 57,432 $ 66,100

= N ET R EVENUE PER H ECTARE ( US $) $ 688 ($ 8,614) ($ 8,042)

L OSS M EASURES *

1. L OSS PER H ECTARE ( US $) $ 0 $ 9,302 $ 8730

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ 0 $ 46.36 $ 43.51

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 14% 13%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% `1352% 1269%

5. O PERATING P ROFIT M ARGIN (%) 4% -15% -14%

**Note that the measures in the tables below must b e interpreted carefully. Operating costs do not in clude fixed costs and net revenue equals gross revenue minus op erating costs.



### 8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTI TIES

The USG has applied an aggressive transition rate w hich is reflected in the nomination amount

and detailed in Table 6.

TABLE 6. N OMINATION 

### A MOUNT 

### : 2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) – Transition Use Reduction Description Spreadsheet

.

California
Strawberry

Commission Eastern Strawberry Florida Strawberry Sector Total / Average

Quantity Requested for 2010: Amount (kgs) 952,543 47,862

103,017

1,103,422

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 856,598 47,862

103,017

1,007,477

Amount (kgs) 856,598

47,862

103,017

1,007,477

Area (ha) 4,370

299

644

5,313

Rate 196

160

160

190

Transition from 2010 Baseline Adjusted Value Percentage (%) 0% -52% -53% -7%

Amount (kgs) 

### 952,543

22,848

48,080

1,023,471

Area (ha) 

### 5443 143 300 5886

Rate 

### 175 160

160

174 SECTOR STRAWBERRY FRUIT

Quantity Approved by Parties

for 2010:



### Quantity Required for

2011 Nomination:USA CUN11 SOIL Strawberry Fruit Open Field Page 13 of 14 

### CITATIONS

California Strawberry Commission. 2008. Request for a critical use exemption for methyl

bromide on strawberries for the 2011 use season.

Fennimore, S., Ajwa, H., Subbarao, K., Martin, F., Browne, G., Klose, S. 2008. Facilitating adoption of alternatives to methyl bromide in Calif ornia strawberries. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008).

Gilreath, J., Santos, B., Mirusso, J., Noling, J., and Gilreath, P. 2005c. Application

considerations for successful use of VIF and metali zed mulches with reduced fumigant rates in tomato. U. Florida Extension publ. HS287. http://edis.ifas.ufl.edu/pdffiles/HS/HS27000.pdf

Legard, D. 2008. Personal communication, email 24 S eptember, 2008.

NASS (National Agriculture Statistics Service), 200 7. Agricultural Chemical Usage 2006 Vegetable Summary. http://usda.mannlib.cornell.edu/usda/current/AgriCh emUsVeg/AgriChemUsVeg-07-25- 2007_revision.pdf

)

Noling, J. W. 2008. Large scale demonstration tria ling of methyl bromide alternatives in Florida strawberry. Annual International Research Conferenc e on Methyl Bromide Alternatives and Emissions Reductions (2008).

Noling, J. W. and Botts, D. A. 2007a. The Vegetabl e Production Handbook for Florida, 2007. http://edis.ifas.ufl.edu/pdffiles/CV/CV29000.pdf

Noling, J. W. and Botts, D. A. 2007b. Grower field demonstration trials of methyl bromide alternatives in Florida strawberry. Annual Internat ional Research Conference on Methyl Bromide Alternatives and Emissions Reductions, 2007

. http://www.mbao.org/2007/Proceedings/052NolingMBAO2 007CSREES.pdf

Norton, J. A. 2008. Metam combinations as alternat ives to methyl bromide in US-grown strawberries and mulched vegetables. Annual Interna tional Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008 ). http://www.mbao.org/2008/046Norton.pdf

Poling, E. B. and Schiavone, R. 2008. Strawberry pl asticulture research with MIDAS 50:50 and MIDAS 98:2 in North Carolina, 2007-2008 (Central Cr ops Research Station, Clayton). [Provided by author]

SE Regional Strawberry Integrated Management Guide. 2008. http://www.smallfruits.org/SmallFruitsRegGuide/Guid es/2008/08StrawberryIntegMgmtGu ideDec10.pdfUSA CUN11 SOIL Strawberry Fruit Open Field Page 14 of 14 

### Sydorovych, O., Safley, C. D., Ferguson, L. M., Pol ing, E. B., Fernandez, G. E., Brannen, P. M., Monks, D. M., and Louws, F. J. 2006. Economic evalu ation of methyl bromide alternatives for the production of strawberries in the Southeast ern United States. http://www.ncsu.edu/project/berries/extension/FINAL %20strawberry%20MB%20budget.pdf

Toth, S. 2008. Personal communication, email to C. Augustyniak, November 4, 2008.

Welker, R. 2008. Choosing alternatives to methyl br omide for strawberries. North Carolina Pest News vol 23, number 12, June 27, 2008. Stephen Toth , ed. http://ipm.ncsu.edu/current_ipm/08PestNews/08News12 /pestnews.html

Welker, R. M., Driver, J. G., Smith, J. P., Schiema nn, C. A., and Louws, F. J. 2008. On-farm research and extension activities to implement MB a lteratives: an area wide initiative update. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008).

Welker, R. M., Driver, J. G., Smith, J. P., Brannen , P. M., Schiemann, C. A., and Louws, F. J. 2007. On-farm research to implement MB alternatives : an area wide initiative. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2007). http://www.mbao.org/2007/Proceedings/022LOUWSareaWi deMBAO07.pdf

.