Filename USA

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LIST OF QUESTIONS FO R PARTIES ON THE SOILS CUN ’ s : 20 10 ROUND

Received from MBTOC March 2, 2010

UNITED STATES



### General

1. MBTOC acknowledges the substantial reductions made in many sectors, however several sectors have MB quantities which may be classified as either QPS MB or CUN MB depending on the use of the material grown in fumigated soil. Despite questions in previous years, MBTOC is still unclear of the technical (or regulatory) difference for this classification and how it affects the current requests for CUNs.

Is it possible to provide a list of sectors where preplant soil use for CUNs has been reclassified as QPS use and how the technical or regulatory reason differs for the portion treated under CUN and QPS?

USG Response The classification of quar antine versus critical use is considered when the U.S. prepares the nomination package. The U.S. asks applicants for information on their CUE and QPS uses for

their relevant areas. Based on this information the amount needed for critical uses is calculat ed

and forwarded to the Parties.

The only sector where the U.S. has information on a shift from CUE uses to QPS uses of MeBr is forest seedling nurseries. As part of the U.S. nomination preparation process the U.S. has

reduced the Southern Forest Nurse ry nomination based on the transition to alternatives and a transition of CUE uses to QPS uses in Alabama and Mississippi, which have added methyl bromide to their list of approved quarantine treatments. The U.S. does not have any additional

information a bout other sectors that have transitioned from CUE uses to QPS uses.

2. Specifically, has any of the methyl bromide sought under the CUN requests last year for 2011 been reclassified to QPS MB under this year’s requests? If so, in which sectors and what is

the reason?

USG Response The U.S. does not know of any other applicants that between 2011 and 2012 have reclassified their uses to QPS.

3. Could you please show the historic change in relevant sectors since 2003 of MB applied for under the CUN process and that now considered QPS MB?

USG Response

The U.S. does not track information on changes from CUE uses to QPS uses. It appears from the question that MBTOC has evidence to show that some uses are transitioning from CUE to QPS

uses. Without a clear in dication from MBTOC on the specific sectors involved and the source of the information it is very difficult to provide additional information.Filename USA

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### US Peppers

1. According to table 5 and 6, the yields obtained with the 3 ways system (except for fall applicati on in Georgia) and with Iodomethane are equivalent to MB. Therefore, the two alternatives can be used in all the nominated region except in Georgia. How important is the fall application in this region compared to the spring application?

USG Response

Inf ormation provided to t he USG indicates that 35% of the pepper areas are fumigated and planted in the fall.



### US Eggplant

4. Until 1999, the chemical formulation primarily used was 98:2. Since then, growers have shifted to formulations with lower concentrati ons of methyl bromide and higher amounts of chloropicrin due to the phase

- out schedule of methyl bromide. At present, the standard formulation is 50:50 in Florida. What MB formulation is used in Georgia?

USG Response

The 50:50 MeBr formulation is used in Georgia.

5. When Iodomethane is expected to be registered on eggplant?

USG Response The manufacturer of iodomethane has not submitted a request to add eggplant to its registered

uses and the EP A h as no additional information when that might happen

.



### USA Forest Nursery

1. The Party states that the Midas label states use for conifers, but appears to be silent on deciduous forest nursery trees. Is it likely that the label will be expanded to include deciduous trees by 2012? If not, could the Party indicate w hat portion of the nomination is for deciduous forest nursery trees?

USG Response

The iodomethane manufacturer has not submitted a request to add deciduous forest nursery trees

to its labelled uses and the EP A has no additional information when that migh t occur.

2. The Party states that the forest nursery industry has not been able to contract with commercial fumigant applicators for fumigation with iodomethane. Is there any information from the registrant or the fumigation companies that would indicate this will change by

2012?

USG ResponseFilename USA

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The U.S. has contacted the registrant of iodomethane and representatives of the forest nursery industry. Industry comments (see below) indicate that soil fumigation with iodomethane is unlikely for at least the near future for forest seedling nurseries. A representative of Arysta LifeScience Corp. said they fumigated “large scale demonstration blocks” in forest nurseries “as recently as 2009 and as far back as 2004.” However, Dr. Ronald Overton of the U.S. Forest

S ervice, who represents the Northeast Forest Conservation Nursery Association (with member nurseries in 10 states) and Dr. Scott Enebak of Auburn University, who represents the Southern Forest Nursery Management Cooperative (with member nurseries in 13 stat es) had different impressions.

Dr. Overton responded:

No Midas trials have been conducted in nurseries in the Northeast Forest and Conservation Nursery Association consortium. Also, to my knowledge, there are no certified contract applicators of Midas i n the Northeast for the broadcast tarped applicatio ns used in forest

nurseries. As a consequence, the lack of availability of IM to Northeast nurseries, the lack of information on application rates, efficacy, effect on beneficial soil microorganisms, and crop phytotoxicity, as well as the other issues has not changed in the Northeast US.
[ Ronald P. Overton

, Area Regeneration Specialist

, Northeastern Area, State & Private Forestry

, USDA

Forest Service ; 4 March 2010]

Dr. Enebak responded:

1) Try as we mig ht we cannot get Arysta Life Science to do tests in forest tree nurseries. This is not "free" stuff we are asking for. Nurseries will pay for the materials as part of their normal fumigation costs, but we can't seem to get a response from their reps.

2) As far as wide

- scale testing in the broadcast system, we (Nursery Cooperative) had a small (0.5 acre) study in 2005 in GA tested straight iodomethane (prior to Midas' registration) and just this past spring (April 2009) we had 1.2 acres of Midas (2 rate s, 4 replications) applied in a nursery in Alabama. We are currently processing the first year ’ s seedling data from those trials and will have a report in April 2010.

We have two more cropping/growing seasons on those plots, so MI's effectiveness as a MBr replacement will start to show this year. I would not consider these wide

- scale studies.

I would agree with Ron Overton's assessment, "The lack of availability of Midas in southern US nurseries, the lack of information on application rates, efficacy , effect on beneficial soil microorganisms, and crop phytotoxicity, has not changed in the Southern US".
[Scott Enebak

, Professor & Director, Forest Health Dynamics Laboratory, Southern Forest Nursery Management Cooperative, Auburn University ; 4 March 20 10 ]



### USA Strawberry fruit

1. The CUN states that the lowest formulation of methyl bromide that is likely to be allowed in California is 57:43 (methyl bromide:chloropicrin) due to severe restrictions on the use of chloropicrin. High rates of chloropicrin (g reater than 225 kg/ha) are restricted by regulation and lower rates may not be optimally effective against plant pathogens.Filename USA

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Which strawberry hectareage of the main strawberry producing districts (Oxnard, Watsonville/Salinas, Santa Maria) will in 2012 be constrained in terms of regulatory caps on rates of chloropicrin? What is the lowest possible rate of chloropicrin application considered effective under barrier films?

USG Response See Appendix NN.10 Summary of VIF and rate research by Ajwa and Browne 2 010 CUE regarding the effect of reduced rates of fumigants and VIF on control of soil borne diseases. See Appendix JJ.12 Regulatory barriers that limit the use of alternative s CUE 2010 for fumigants by California strawberry fruit growers.

2. The CUN states that in Florida, rates that are 25

- 50% lower than historical methyl bromide rates are being used as the use of VIF

- type films has increased.

Looking at successful adoption of VIF in Florida and its favourable impact on dosage rates, will California poli cymakers review the regulation that bans use of VIF in MB application?

USG Response The EPA believes that high barrier films can reduce emissions and improve bystander safety when used according to label directions . But the EPA has no information regardi ng a decision by Cal DPR to allow the use of these films. See Appendix NN.10 Summary of VIF and rate research by Ajwa and Browne 2010 CUE for a s ummary of research regarding the effect of reduced rates of fumigants and VIF on control of soil borne disease s.

3. The CUN states that in California, township caps currently restrict the use of 1,3

- D on approximately 40

- 62% of total strawberry land (California Strawberry Commission, 2008).

Which strawberry hectareage of the main strawberry producing districts (O xnard, Watsonville/Salinas, Santa Maria) will in 2012 be constrained in terms of township caps
on 1,3

- D?

USG Response See Appendix JJ.12 Regulatory barriers that limit the use of alternative fumigants by California strawberry fruit growers.

4. The CUN stat es that the California Strawberry Commission has funded Farming Without Fumigants Initiative whose goal is to develop strawberry fruit production methods that can avoid the complexities of highly regulated fumigants.

o Please provide a summary of research results to date?

USG Response

See Wang et al 2009. MBAO. S trawberry Production in soilless Substrate Troughs

– Water ManagementFilename USA

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5. Tables 3, 4 and 5 provide economic impacts of MB alternatives, but do not state over which years, on what hectareage (how man y farms) or over which seasons these data have been

collected.

Please provide more in

- depth background information on the economic data provided in the CUN, and/or please provide a more up

- to

- date analysis?

USG Response The economic data provided in the report is from the 2008 assessment year. See Appendix U.07

E conomic impacts of alternative s.



### USA Sweet Potato Transplants

1. MBTOC acknowledges that the nominated area of sweet potato is reduced to 58ha from 81ha

between CUN08 to CUN11. What alternati ves are being used in the areas that have phased out MB.? What is the reason that those alternatives could not be used in the area of 58ha in CUN for 2012.

USG Response Scott Stoddard responded: Increased organic production. The number of producers has doubled since 2007, and much of the acreage growth can be attributed to increased organic acres

.

Alternatives: more metam sodium is being used (sprinkler applied). It is very likely that alternatives like metam and Telone + Pic will show as viable

alte rnatives by 2012. Currently, we are beginning the 3rd year of a 3 year project to

document this. In 2011, verification of the results from the replicated trial wil l be done in

6 to 8 locations. One of the big impediments to metam use is that it requires a change in production practices to utilizing a "cold bed", where the organic matter "layering" that is currently the standard method is eliminated in order to preserve the integrity of the

metam in the soil and therefore the weed control. (the cold bed system is also requ ired for solarization to work) Growers are hesitant to switch to a cold bed system for several reasons, including the belief tha t it reduces plant production.

[ C. Scott Stoddard, Assoc. Farm Advisor, Merced & Madera Counties, Universi ty of California ; 11 March

2010 ]

2. Pic is found very effective to treat nematodes. Devrinol and Valor in the tank mix were found to be effective for weed control. What is the reason that those alternatives could not be replaced methyl bromide in 2012?

USG Response Scott Stoddard responded: Research is showing that weeds are the main pest in the hotbed area, not nematodes or

disease. If verified, as is planned in 2011, there would be little need for tarped applications of this fumig ant (pic). Valor applica tion rates still need to be determinedFilename USA

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that will provide weed control with improved crop safety. Devrinol should be used more than it is for sweetpotatoes. Regardless, I believe that there is good potential for herbicides to help alleviate the impact fro m fumigant loss. I will wait until after the third year of the trial and the verification trials in 2011 before stating that herbicides can be used as effective alternatives to fumigation.

[ C. Scott Stoddard, Assoc. Farm Advisor, Merced & Madera Counties, University of California; 11 March

2010 ]

3. According to the table 7, Pic. gave yield increases of 11% with a gain of $1,410/hectare although it is in the list of the substances that are a VOC. What restrictions does this place on Pic used in sweet potato production?

USG Response Scott Stoddard responded In 2008 the best yielding fumigation treatment was Telone + Vapam, in 2009 it was Pic Chlor 60. Basically this tells me there is no consistent and significant impact of the hotbed fumigation treatments on root yield. But I tend to think of yield for the hotbeds as yield of plants. In either year Pic did not really have an advantage over the other treatments, so again, I'm unclear what this is referencing. I do not consider Pic only to be

an alter nativ e to pursue beyond 2010: It is mostly a disease control product and disease is not an issue, it is expensive to apply, it doesn't give weed control, and it has VOC

issues.

[ C. Scott Stoddard, Assoc. Farm Advisor, Merced & Madera Counties, University of C alifornia; 11 March

2010 ]



### USA Tomatoes

– FIELD

1. The nomination is for methyl bromide use in the production of tomatoes in Florida, Georgia,

the Mid

- Atlantic (Maryland, and Virginia), and the Southeast. Table 15 reports only 3 regions: SE, Georgia, and Flo rida. Maryland and Virginia are missing. Is this correct? USG Response MBTOC is correct the list of sites should include Maryland and Virginia. We have inserted the

corrected Table 15 below.

2. The University of Georgia reported that the price of iodomet hane went up so dramatically that they did not advise growers to use the product. Please give a reference to this statement? USG Response This information was provide d by Dr. Stanley Culpepper, University of Georgia.

3. Is the quantity required for 2011 or 2012? Please update the nomination (Table 15) USG Response

MBTOC is correct that the numbers should be for 2012 (see corrected table below).Filename USA

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### LIST OF ATTACHED FILES

Appendix JJ.12 Regulatory barriers that limit the use of alternative s CUE . Appen dix NN.10 Summary of VIF and rate research by Ajwa and Browne 2010 CUE

. Wang et al 2009. MBAO. S trawberry Production in soilless Substrate Troughs

– Water Management Appendix U.07 E conomic impacts of alternative s.