DRAFT FOR INTERNAL DISCUSSION ONLY 2-18-15
1,3-Dichloropropene (1,3-D) Township Cap Bank Information for 2013
As part of the California Management Plan for 1,3-D, the Department of Pesticide Regulation (DPR)
requires Dow AgroSciences (DAS) to administer a township cap program that includes:
 Limitations within each township (6x6 mile area)
 Allocation of 90,250 pounds per year for each township, with unused amount “banked”
 Maximum use of 180,500 pounds per year for each township, if available in the bank
1,3-D cap allocations and use are “adjusted pounds” using Application Factors that vary from 0.3x to
2.3x of pounds applied depending on fumigation method, month, and region. Higher Application
Factors result in higher 1,3-D air concentrations.
The following summarizes the townships with use exceeding the 90,250 adjusted pounds allocation
for 2013, the most recent reporting year. (Data for 2014 has been requested from DAS.) Of the 341
townships with some 1,3-D use in 2013, DPR issued waivers allowing 12 townships with depleted
banks to exceed 90,250 adjusted pounds. DPR stopped issuing waivers, so these 12 townships did not
exceed 90,250 adjusted pounds in 2014. In 2013, an additional 47 townships with sufficient banks
exceeded 90,250 adjusted pounds (Table 1). The crops with the highest use in these 47 townships
were almonds, grapes (raisin, table, and wine combined), strawberries, carrots, and sweet potatoes
(Table 2). Most of the townships that exceeded 90,250 adjusted pounds were in the San Joaquin
Valley and Central Coast region (Figure 1).
Table 1. Number of townships (with an available bank) that exceeded the allocation cap in 2013.
Number of
Percent of 341 Townships With
1,3-D Adjusted Pounds Applied
Townships
1,3-D Use That Exceeded Cap
47
>90,250 (allocation cap)
13.8
Breakdown
16
>90,250 – 112,812 (>1.0-1.25x of cap)
4.7
12
>112,812 – 135,375 (>1.25-1.5x of cap)
3.5
8
>135,375 – 157,938 (>1.5-1.75x of cap)
2.3
7
>157,938 – 180,500 (>1.75-2x of cap)
2.1
4*
>180,500 (>2x of cap)
1.2
*DPR issued waivers allowing 4 townships to exceed the 180,500 adjusted pounds use cap in 2013.
DPR stopped issuing waivers in 2014.
Table 2. Crops fumigated (preplant) in the 47 townships that exceeded the allocation cap in 2013.
Number of the 47 Townships
Crop
With Highest Use for the Crop*
Almonds
10
Grapes
8
Strawberries
3
Carrots
2
Sweet potatoes
2
*These values are likely underestimates because the crop is reported as “preplant/soil fumigation” or
“uncultivated ag” for many 1,3-D applications.
1

 DRAFT FOR INTERNAL DISCUSSION ONLY 2-18-15
Figure 1. Locations of 341 townships with 1,3-D use in 2013.

2