DRAFT FOR INTERNAL DISCUSSION ONLY 3-24-15
1,3-Dichloropropene (1,3-D) Township Cap Bank Information for 2014
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 2014. Of the 332 townships with some 1,3-D use in 2014, 53 townships exceeded 90,250 adjusted
pounds (Table 1). No townships exceeded the 180,500 adjusted pounds use limit. Twelve townships
had depleted banks and were limited to 90,250 adjusted pounds. Eleven of the 12 townships did not
exceed 90,250 adjusted pounds. DPR approved an exception for the 12th township. This exception
was for a research study on fumigant alternatives, and that township exceeded the cap by 1,422
adjusted pounds. The crops with the highest use in these 53 townships were almonds, grapes (raisin,
table, and wine combined), strawberries, carrots, sweet potatoes and tangerines (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 2014.
Number of
Percent of 332 Townships With
1,3-D Adjusted Pounds Applied
Townships
1,3-D Use That Exceeded Cap
54
>90,250 (allocation cap)
16.2
Breakdown
17
>90,250 – 112,812 (>1.0-1.25x of cap)
5.1
14
>112,812 – 135,375 (>1.25-1.5x of cap)
4.2
11
>135,375 – 157,938 (>1.5-1.75x of cap)
3.3
12
>157,938 – 180,500 (>1.75-2x of cap)
3.6
Table 2. Crops fumigated (preplant) in the 53 townships that exceeded the allocation cap in 2014.
Number of the 54 Townships
Crop
With Highest Use for the Crop*
Almonds
4
Grapes
4
Strawberries
3
Carrots
2
Sweet potatoes
2
Tangerines
2
*These values are likely underestimates because the crop is reported as “preplant/soil fumigation” or
“uncultivated ag” for many 1,3-D applications.
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 DRAFT FOR INTERNAL DISCUSSION ONLY 3-24-15
Figure 1. Locations of 332 townships with 1,3-D use in 2014.

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