Nominating Party: The United States of America

FILE NAME: USA CUN13 Soil cucurbits Open Field 

Brief descriptive Title of Nomination:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Cucurbits Grown in Open Fields (Submitted in 2011 for 2013 Use Season)

Crop name: Cucurbits Open Field

Quantity of methyl bromide requested:

Table 1: Quantity of Methyl Bromide Requested in Each Year of Nomination

Year	Nomination Amount (Kilograms)

2013	11,899 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:	  HYPERLINK "mailto:thompsonje2@state.gov" 
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).) 

This form is to be used by holders of single-year exemptions to reapply
for a subsequent year’s exemption (for example, a Party holding a
single-year exemption for 2005 and/or 2006 seeking further exemptions
for 2007).  It does not replace the format for requesting a critical-use
exemption for the first time.

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.   

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person:	Jack E. 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:	jack.housenger@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 CUN13 Soil cucurbits Open Field 	23













	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 cucurbits Open Field 















* Identical to paper documents



METHYL BROMIDE CRITICAL USE RENOMINATION FOR Preplant Soil Use (OPEN
FIELD OR PROTECTED ENVIRONMENT)

CUCURBITS

SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE:

This renomination covers cucurbits of several types (squash, melons,
and/or cucumber) grown in the southeastern US (except Florida),
Maryland, and Delaware. These crops generally are grown in open fields
on plastic tarps, often followed by various other crops.  Harvest is
destined for the fresh market.

Only areas that cannot use alternative fumigants or non-fumigant
options, and that face moderate to severe infestations of key pests,
have been included in the calculation of nominated amounts and area to
be treated. The applicants’ requests have also been adjusted downward
to account for the lower methyl bromide dose rates (see BUNNIE in
Appendix A) for the southern regions of US cucurbit production, since
increased use of high barrier films in conjunction with lower rates has
been reported there. For the mid-Atlantic region, the low dose rates
requested by the applicants were incorporated into calculations. 

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.

In developing this renomination the USG examined several recent studies
to determine whether yield losses and market window losses associated
with the best available fumigant alternative could be altered from
previous nominations. Unfortunately none of the studies located by the
USG met the criteria that earlier cited studies did. These criteria
include: the use of fumigant alternatives registered for the crop
nominated, the presence of both a methyl bromide standard and an
untreated control as treatments as well as the monitoring of yields
under each treatment. Several recent studies included a methyl bromide
treatment or an untreated control but not both, or included both but did
not monitor yield, or included unregistered alternatives. However,
research conducted at the University of Georgia that examined use of a
three way combination of alternative fumigants (1,3 D followed by
chloropicrin followed by metam-sodium) did meet these criteria, 
Therefore, southern US areas were adjusted to reflect the technical
feasibility of this three way combination of alternative fumigants under
VIF or metallized films,  as a replacement for spring-time applications
of methyl bromide+chloropicrin, after accounting for areas in the south
that face prohibition of 1,3 D due to karst topographical features.

The U.S. nomination is only for those areas where the alternatives are
not suitable.  For example, continuing research indicates that the three
way combination mentioned above (the “UGA 3 way”) does not
adequately control key pests when used in place of methyl bromide in
“fall” (i.e. August or September) fumigations. In U.S. cucurbit
production there are several factors that make the potential
alternatives to methyl bromide unsuitable.  These include:

The efficacy of alternatives may be significantly less effective than
methyl bromide in some areas, making these alternatives technically
and/or economically infeasible for use in cucurbit production.

Some alternatives may be comparable to methyl bromide as long as key
pests occur at low pressure.  The U.S. is only nominating a critical use
exemption (CUE) for cucurbits where the key pest pressure is moderate to
high such as nutsedge in the Southeastern U.S.

Regulatory constraints prevent use of some chemicals, e.g.,
1,3-dichloropropene (1, 3-dichloropropene ) use is limited in Georgia
due to the presence of karst topographical features.

U.S. reliance on methyl bromide has dramatically and rapidly been
reduced over the last eight years.  Critical use exemption (CUE)
requests have decreased every year since the U.S. phase-out process
began.  The development, registration, and use of new pest control
products and production methods have been key to the progress and
reductions made to-date.  As alternatives have demonstrated their
suitability, as thorough reviews of research results and applicant
information have been conducted, and contacts have been made with
regional crop experts to assess the technical and economic feasibility
of alternatives, U.S. Government (USG) requests have reduced by 99%, for
the fruiting vegetables, over the last 9 years.  However, as the amount
of methyl bromide available for use decreases each year, substantial
challenges exist in the collection of needed data to substantiate
on-going critical needs through the CUE process.  

There are now several alternatives for soil fumigation, including
1,3-dichloropropene plus chloropicrin, the “UGA 3 Way” combination
(1,3-dichloropropene plus chloropicrin followed by metam sodium),
iodomethane plus chloropicrin, and dimethyl disulfide (DMDS) which have
demonstrated some technical and economic feasibility for pest control in
a number of vegetable crops in the U.S. Southeast.  However, CUE
applicants in this nominated sector have indicated that they are not
always suitable for all situations.  While DMDS has a Federal
registration and has demonstrated effectiveness, it is not currently
registered in all the relevant states.  Given the timing of state
registrations, lack of experience using this alternative, and
application methods still under development to minimize odor in
communities surrounding treated fields there is uncertainty in
predicting when this alternative can be reasonably expected to
adequately replace methyl bromide in specific application scenarios. 
While the DMDS registrant has been working with the product to reduce
the odor, and growers are gaining experience in its use, work is still
needed on application approaches for the alternative to be fully
available for use in U.S. southeast vegetable crops.  For example
individual operators and small farms, which account for up to eighty
percent of the growers in this nominated sector are especially
hard-pressed to make this transition, because one of the most promising
alternatives requires additional money to convert their fumigation
equipment and custom fumigation applicators are not available in all
areas.  In addition to the expense to convert to the alternatives, there
have been reports that the alternatives do not perform as well as the
MeBr:pic combination.   

These concerns about the alternatives have only recently been brought to
the USG attention and insufficient supporting information was provided. 
Because of the uncertainties and challenges associated with the use of
the available alternatives, the USG believes it most prudent and the
best public policy to collect additional information so that the
technical and economic impacts of these reported problems can be
evaluated.  The USG will request the applicants provide additional
information to us no later than June 1, 2011 so that the information can
be analyzed and provided to MBTOC by July 15, prior to the Open Ended
Work Group (OEWG) meeting in early August.  The quality of any
additional information received will first be evaluated in terms of
whether or not it supports a compelling case and confirms problems with
the feasibility of alternatives. Then, on that basis, the USG will
either support or withdraw this nominated sector at that meeting.  

The nomination attached specifies the correct year (2013) and amount of
methyl bromide that is being requested for the individual crops within
this sector.  However, there has been no attempt to update the
information in this document regarding the new research, availability of
alternatives, etc.  Since the USG learned of the issues facing the
growers within this sector, after speaking directly with researchers
familiar with the specific problems only very recently, this information
was not available at the time the USG recommendation was developed.    

2.	Summarize why key alternatives are not feasible:

Our review of available research on other methyl bromide alternatives
discussed by MBTOC for cucurbits suggests that, of registered (i.e.,
legally available) chemistries only metam sodium and 1,3 D +
chloropicrin have shown potential as commercially viable replacement to
methyl bromide.  Non-chemical alternatives are either unviable for US
cucurbits or require more research and commercial development before
they can be technically and economically feasible. For some areas in the
southeastern US, a 3 way combination of 1,3 D followed by chloropicrin
alone, followed by metam-sodium, has shown promise against key cucurbit
pests in spring season fumigation. The transition rate included in the
BUNNIE incorporates an estimate of projected use of this strategy. In
this nomination, the Southeastern U.S. includes the following states:
Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina,
South Carolina, Tennessee, and Virginia.

The recent Federal registration of iodomethane has not been used to
adjust the amount of methyl bromide requested in this CUE, because this
material has not been registered on cucurbits. Other reasons for
considering an alternative technically infeasible for cucurbits include:

There are significant restrictions on which crops can be rotated through
after use of a given alternative (e.g., halosulfuron has rotational
restrictions that prevent its use in southeastern US tomatoes).

Resistance management prevents use of the alternative (e.g., glyphosate
resistant weeds, such as Amaranth, in the southern US, prevent use of
this alternative as a post-emergent weed control in those regions).  

The following is the procedure followed for the 2009 allocation year: 

For Southeastern U.S. and Georgia, metam-sodium and 1, 3 D +
chloropicrin are the most promising alternatives for nutsedges and
nematodes, respectively, which are the key target pests in these
regions. However, where nutsedges are severe, metam-sodium, used alone,
is technically and economically infeasible due to planting delays, yield
losses and inconsistent efficacy, while 1,3 D + chloropicrin is
infeasible in some areas due to (1) its use being prohibited on Karst
topographic features, which are widespread in these regions, (2) a 21
day planting delay, and (3) yield losses.  

There is also evidence that the pesticidal efficacy of both 1,3 D and
metam-sodium declines in areas where it is repeatedly applied, due to
enhanced degradation of methyl isothiocyanate by soil microbes (Ou et
al., 1995; Verhagen et al., 1996; Dungan and Yates, 2003; Gamliel et
al., 2003). 

While one study in 2006 showed good efficacy of a combination of 1,3 D +
chloropicrin and the herbicides napropamide + halosulfuron or
metolachlor + trifloxysulfuron in small plots of Florida tomatoes
(Santos et al. 2006), these results are not applicable to cucurbits
because neither metolachlor or trifloxysulfuron are registered in the US
for cucurbits, and halosulfuron can have  phytotoxic effects on
cucurbits.

All other potential or available methyl bromide alternatives are also
technically infeasible for U.S. cucurbits.

3.	is the use covered by A certification STANDARD?

Methyl bromide is not used to meet a certification standard for cucurbit
vegetable production.

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. 

In Southeastern U.S. Georgia, and Maryland, areas not treated do not
have nutsedges or pathogens naturally present in cucurbit fields. 
Simple absence of all pests is the only reason these areas are not
presently treated with methyl bromide.

In Delaware and Maryland areas without the existence of several races of
Fusarium oxysporum niveum, one of which is highly aggressive, or without
high concentration of the pathogen could use some alternatives such as
1,3-D. 

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?

The primary reason that some cucurbits may be grown without methyl
bromide in these regions is the absence of both key target pests and
constraints to use of alternatives (e.g., absence of nutsedge,
nematodes, and fungal pathogens in the Southeast, and Georgia, several
races of Fusarium and nutsedges in Delaware and Maryland, and karst
topographic features in Georgia).

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:

Narrative description of studies relevant to key pathogens

This section focuses on research relevant to effectiveness of methyl
bromide alternatives against Fusarium wilt, since that is the main key
pest cited by CUE applicants from the Maryland/Delaware regions. In
studies with vegetable crops in the southeastern US, 1, 3 D +
chloropicrin has generally shown better control of fungi than
metam-sodium formulations (though still not as good as control with
methyl bromide).  For example, in a study using a bell pepper/squash
rotation in small plots, Webster et al. (2001) found significantly lower
fungal populations with 1,3 D + 35 % chloropicrin (drip applied, 146
kg/ha of 1,3 D), as compared to the untreated control.  However, methyl
bromide (440 kg/ha, shank-injected) reduced fungal populations even
more.  Iodomethane had no significant suppressive effect, as compared to
the untreated control.  However, neither of these methyl bromide
alternatives increased squash fruit weight significantly over the
untreated control.  Indeed, as compared to the methyl bromide standard
treatment plots, squash fruit weight was 63 % lower in the 1,3 D plots,
and 41 % lower in the iodomethane plots.  The proportion of unmarketable
squash fruit (defined only as those fruit so bad as to have to be
discarded) in the 1,3 D plots was 30 % worse than that in the methyl
bromide  plots, though in the iodomethane plots it was equivalent to
methyl bromide . 

In another study conducted on tomatoes, Gilreath et al. (1994) found
that metam-sodium treatments did not match methyl bromide in terms of
plant vigor at the end of the season; again, Fusarium was one of several
pests present. 

In another study, by Hausbeck and Cortright (2007), cucurbit plant vigor
was measured to determine fumigant/mulch performance under either LPDE
or VIF plastic mulch for the control of Fusarium oxysporum.  Of the
fumigants used in the study, the methyl bromide and iodomethane
treatments resulted in cantaloupe plants with the highest vigor (Table
7.1).  In general, treatments under LPDE had higher plant vigor when
compared with plants grown under VIF.  It is noteworthy that in this
study VIF tarps were prone to wind removal, which reduces their
reliability under some growing conditions. 

Table 2:  Evaluation of Fumigants and Plastic Mulches for Managing
Fusarium in Cucurbit Crops 2007    TC "Table C 3 Michigan Region :
Evaluation pf Fumigants for managing Phytophthora " \f F \l "1"  

Treatment (time after treatment to planting)	Rate of formulated product
Vigor*

Untreated control under LDPE (5 days)	

1.0-1.3	a**

Iodomethane+chloropicrin 50:50 under LDPE (10 days)		196 kg/ha	1.0	a

Iodomethane+chloropicrin 50:50 under VIF (10 days)		196 kg/ha	3.0	c

Methyl bromide+chloropicrin 67:33 under LDPE (10 days)		 280 kg/ha	1.0	a

Methyl bromide+chloropicrin 67:33 under VIF (10 days)		 280 kg/ha	2.7	bc

1,3 D + chloropicrin 65:35 under LDPE (21 days)		187 liters/ha	2.3	bc

1,3 D + chloropicrin 65:35 under VIF (21 days)		187 liters/ha	4.7	d

Chloropicrin under LDPE (14 days)		187 liters/ha	2.7	c

Chloropicrin under VIF (14 days)		187 liters/ha	3.3	cd

*Vigor rating of plant health; 1=healthy plants with no stunting, 5=
moderated plant stunting with variable stand, 10=complete plant death.

**Column means with a letter in common are not significantly different
(Fisher LSD Method; P=0.05).

From Hausbeck and Cortright 2007.

In addition to the limitations of VIF discussed above, the USG notes
that the plant vigor in 1,3 D treatments in these new trials is lower
than that seen in methyl bromide treatments. This is similar to what was
seen in previous years’ tests (Hausbeck and Cortright 2004; see also
discussions in earlier cucurbit nominations). 

As far as the USG has been able to determine, no other studies have been
conducted since 2007 to evaluate the technical and commercial
feasibility of fumigant alternatives to methyl bromide for controlling
F. oxysporum subtypes under production conditions relevant to the
Maryland/Delaware regions. 

Research continues to also be conducted to identify Fusarium resistant
watermelon stock that can be grafted on a commercially feasible basis.
While rootstocks protective under conditions of low to moderate pathogen
infestation have been identified and tested, this work will require
several more years before it produces methyl bromide alternatives that
are both technically and economically feasible, and that functions under
severe infestations. Such work is being planned in the southeastern US
(Roberts et al. 2007, Taylor et al. 2007, Bruton, personal
communication).  Results of cucurbit rootstock resistant to root knot
nematode (Meloidogyne incognita) were presented at the MBAO conference
in November 2008 (Kokalis Burrell et al. 2008, Kubota et al. 2008).
Results with muskmelon showed that the evaluated rootstocks have
potential as an option in an integrated multi-tactic approach to replace
methyl bromide. However, this work is in its initial stages and further
evaluation is needed to assess feasibility of control of other soil
pests. Furthermore, these trials did not evaluate resistance or
commercial feasibility of rootstocks against the Fusarium pests that are
key targets for the Maryland/Delaware region. In general, grafting of
resistant rootstocks is still in an early stage of evaluation and
commercial implementation for US east coast cucurbit production, and so
the USG does not consider them viable alternatives to methyl bromide for
the purposes of this nomination.

In conclusion, the USG continues to use the best case yield loss
estimates from the previous years’ nominations for the
Maryland/Delaware region, since these need methyl bromide mainly for F.
oxysporum control.  To paraphrase these loss estimates: 1,3-D
+chloropicrin is the likely best available alternative for areas in this
region that can use (i.e. areas not close to the water table). Even with
this alternative, a yield loss of about 6 % is likely (based on Hausbeck
and Cortright, 2004, and discussions in the 2004-2007 cucurbit
nominations). The economic impact of this loss is further examined in
other sections of this document, below. 

Narrative description of studies relevant to key weeds and nematodes

For nutsedge pests, which are widespread in all requesting regions,
cucurbit growers do not currently have technically feasible alternatives
to methyl bromide use at planting.  Metam-sodium and 1,3 D +
chloropicrin have shown some efficacy in small-plot trials in other
vegetable crops (e.g, tomato).  However, at best, metam sodium may allow
at least 44 % yield loss, while 1,3 D may allow at least 29 % loss. 
Both often show less control than methyl bromide (in terms of population
suppression) of nutsedges.  These factors suggest that even this
alternative will not be economically feasible even in the best-case
technical scenario.  It should be noted also that there is evidence that
both 1,3 D and methyl isothiocyanate levels decline more rapidly, thus
further compromising efficacy, in areas where these are repeatedly
applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al., 2003). 
This is probably due to enhanced degradation of these chemicals by soil
microbes (Dungan and Yates, 2003). 

Other chemical alternatives to methyl bromide that have shown promise
against nutsedges and nematodes (e.g., pebulate and dimethyl disulfide)
are currently unregistered for cucurbits,

In one recent study, Culpepper and Langston (2004) conducted studies at
2 sites in spring 2003 and one site in the fall season of 2004.  Plot
sizes were 20 feet X 32 inches (4.94 m2).  Treatments were: Methyl
bromide standard (67:33 formulation), untreated control, 2 formulations
of Telone (1,3 D + chloropicrin) at various doses, followed by an
additional application of either chloropicrin or metam-sodium, a third
formulation of 1,3 D + chloropicrin (“Inline”), and iodomethane.  An
additional set of plots received the same fumigant treatments but also
received an herbicide treatment (clomazone + halosulfuron) later in the
season. 

Watermelon – the only cucurbit crop addressed in these experiments –
showed no significant (final) yield differences across any fumigant
treatment.  The same lack of difference was observed when herbicides
were added.  In fact, there was no difference in yield even when
pesticide treatments were compared to the untreated control.  However,
nutsedge populations in the study appeared to be relatively low (e.g.,
667 plants per plot or 135/m2, in the untreated control, at the end of
the study).

Furthermore, a number of important caveats must be mentioned when
considering these results:

Plots used were quite small, and it is not at all clear if the promising
results will hold reliably in larger commercial fields.  This is
particularly worrisome given the highly variable results reported by
other researchers for the same methyl bromide alternatives.

The nutsedge populations in this study were dominated by yellow nutsedge
(90 % of the total number).  It is not clear if populations where purple
nutsedge is dominant will be controlled as effectively.  A number of
other studies have indicated that purple nutsedge is a hardier species,
and even in Culpepper and Langston’s study, it appeared more resistant
to the methyl bromide alternatives.  For example, iodomethane gave “77
% control” of yellow nutsedge, but only “37 % control” of purple
nutsedge.  Control in this case was apparently defined as the reduction
in nutsedge populations as compared to populations in the untreated
control. 

This study was done only with watermelons, and it is not clear if other
cucurbits will respond so favorably in terms of yield, or lack of
phytotoxic response.  Also, a custom-built applicator had to be used for
the metam-sodium applications to eliminate worker exposure risks,
according to the authors.  It is not yet clear if such an applicator can
be mass-produced and/or used reliably in a commercial setting.

Another recent study of methyl bromide alternatives involving key weed
pests was done by Gilreath et al. 2005 (Crop Prot (24): 903-908). One of
3 trials in that study showed an average of 30 % lower bell pepper
yields with nutsedge and nematodes as the key pests present.  In the
other 2 trials yields were not significantly different across different
fumigant treatments, but nutsedge pressure was lower in those trials as
compared to the third. Other important caveats to these results are -
this was a small-plot study and was done in Florida. Thus it is not
clear how applicable the results are to the more northern regions
requesting methyl bromide for vegetable crops (e.g., Delaware, Maryland,
and Virginia). 

In addition to the studies described above, several other recent studies
conducted in the production circumstances of the southeastern US have
examined several fumigant alternatives to methyl bromide, most done in
crops other than cucurbits/peppers (e.g., Santos et al. 2006, Candole et
al. 2007, Santos and Gilreath 2007, Gilreath and Santos 2005, 2007).
These studies either focused solely on nutsedge weeds or a combination
of nutsedges, diseases, and nematodes. However, USG has examined these
papers and concludes that for cucurbits, these studies do not meet all
the criteria that allowed the use of earlier studies in estimating yield
and quality losses that may occur if such methyl bromide alternatives
are used as direct replacements for methyl bromide. 

These criteria are: the use of fumigant alternatives registered for the
crop nominated, the presence of both a methyl bromide standard and an
untreated control as treatments as well as the monitoring of yields
under each treatment. Several such studies included a methyl bromide
treatment or an untreated control but not both (Santos and Gilreath
2007, Johnson and Mullinix 2007), or included both but did not monitor
yield (Candole et al. 2007), or included unregistered alternatives
(e.g., Gilreath and Santos 2005, 2007, Santos et al. 2006). While these
studies (the majority of which were small-plot trials) indicate
continued promise of methyl bromide alternatives such as 1,3-D,
metam-sodium, chloropicrin, herbicides, or combinations thereof, they
cannot yet be used to alter yield estimates. 

Therefore,  for this nomination, the USG concludes that, for cucurbit
growers who can only use either 1,3-D + chloropicrin or
metam-sodium+chloropicrin in fall-season fumigations to control nutsedge
and nematode pests, the yield loss estimates used in last year’s
nomination continue to be applicable. These loss estimates are
illustrated in Table 7.2 below, and are used as the basis of part of the
economic assessment in the following section.

Table 3:  data on yield losses with likely methyl bromide alternatives
and nutsedge present as a crop pest.

Chemicals	Rate (kg/ha)	Average Nutsedge Density

(#/m2)	Average Marketable Yield

(ton/ha)	% Yield Loss (compared to MB)

Untreated (control)	-	300 ab	20.1 a	59.1

Methyl Bromide + Pic (67-33), chisel-injected	390 kg	 90 c	49.1 b	---

1,3 D + Pic (83-17), chisel-injected	327 l	340 a	34.6 c	29.5

Metam Sodium, Flat Fumigation	300 l	320 a	22.6 a	54.0

Metam Sodium, drip irrigated	300 l	220 b	32.3 c	34.2

Locascio et al. 1997. 

Recent studies that are useful (within the context of this nomination)
in assessing technical feasibility of a combination of methyl bromide
alternatives include the series of trials being conducted by Culpepper
et al. at the University of Georgia (e.g., Culpepper 2006, Culpepper et
al. 2007a,b, Culpepper 2008). These studies indicate that a 3-way,
sequential combination of several fumigant alternatives is technically
feasible for spring-time fumigation of most vegetable crops. The 3-way
combination consists of 1,3 D followed by chloropicrin at about 168
kg/ha, followed by metam-sodium, all under VIF or metallized (high
barrier) tarps, and will henceforth be referred to as the ‘UGA 3
way’, as Culpepper et al. have. An example of the results obtained in
spring fumigation with this combination in peppers is presented in the
table below. Results have been similar for cucurbit crops (Culpepper,
personal communication; also see several research reports available from
the University of Georgia at   HYPERLINK "http://www.gaweed.com" 
www.gaweed.com ).

Table 4:  Number of Pepper Fruit - Methyl Bromide: Chloropicrin Versus
Three Way Combination.  Spring 2006  TC "Table C 5.  Number of Fruit -
Methyl Bromide:Chloropicrin Versus Three Way Combination.  Spring 2006"
\f F \l "1"    

Fruit Size	Methyl Bromide : Chloropicrin

(# of Fruit)	UGA 3 way

1,3-D fb chloropicrin fb metam Na

Jumbo	30 b	125 a

X-Large	219 a	237 a

Large	153 a	143 a

Chopper	217 a	252 a

Cull	11 a	9 a

Jumbo + X-Large + Large	402 b	505 a

Footnote:  Culpepper 2006.   fb means followed by or a sequential
treatment. Plots were 3 rows by 100 feet long. 

Since Georgia is similar to other areas of the southeastern US, except
Maryland/Delaware cucurbits which face a different key pest (F.
oxysporum niveum), these results should be applicable to spring usage of
methyl bromide in these regions. However, other results thus far
indicate that summer/fall fumigation is not similarly effective with
this combination of alternatives (Culpepper, personal communication,
Culpepper 2006, 2008).  

Results of one of several experiments conducted by Culpepper et al. at
the University of Georgia illustrate the infeasibility of the use of the
‘UGA 3 way’ method in place of methyl bromide for fall-season
fumigations in vegetable production. In this experiment, fields were
fumigated during for fall-season crop production on July 17 2007.  Soil
temperature was 84 degrees at 8 inches. The experiment consisted of 4
fumigant treatments (Table 7.4) that were replicated three times. Even
under high-barrier film (“Blockade”), the ‘UGA 3 way’ gave less
control of purple nutsedge as compared to the methyl bromide standard
under the same type of film. Yields were consistently lower with the
‘UGA 3 way’ as well, with a roughly 50 % reduction in both number
and weight of harvested vegetables (Table 7.4). The economic
implications of this level of yield loss for Georgia cucurbit growers
are further described in Part E, below.

Table 5:  Comparing methyl bromide and the 3-Way for the control of
nutsedge and pepper yield.

Fumigant	Mulch	Late-season purple nutsedge control	Harvests 1-2

(Jumbo pepper)	Harvests 1-4

(Jumbo pepper)



%	# fruit/plot	lbs/plot	# fruit/plot	lbs/plot

UGA-3 Way	LDPE	48 d	34 c	16 c	44 c	19 c

UGA-3 Way	Blockade	60 c	50 b	24 b	71b	32 b

Methyl Bromide + chloropicrin	Blockade	85 b	106 a	48 a	136 a	61 a

None	LDPE	0 f	13 d	6 d	19 d	8 d

Notes: (1) The UGA 3 Way consisted of 1,3 D at approximately 192 kg/ha,
followed by chloropicrin at 168 kg/ha, followed by metam-sodium at
approximately 358 kg/ha. Methyl bromide + chloropicrin was applied in a
50:50 mix at approximately 160 kg/ha of each. Rates as shown are not
planting bed-strip adjusted.  (2) “Mulch” refers to the tarp type.
LDPE = traditional high permeability tarp; Blockade = low permeability
tarp manufactured by Pliant Corp.

It is important to note that caveats accompany even the technical
feasibility of the ‘UGA 3 way’ use in spring fumigations. Growers
must make several application modifications to properly use the
approach, and this may incur significant capital expenditure. Culpepper
et al. estimate their costs to do this for their research trials at
about $ 15,000 (Culpepper et al. 2007). Application costs will also
increase as more chemicals and runs of tractor equipment are required to
conduct the ‘UGA 3 way’, and the cost of VIF or metallized film is
between 1.75 and two times greater than standard LBPF (Culpepper,
personal communication).  

Time and further research and extension education will also be needed to
implement the ‘UGA 3-way’ method in areas outside Georgia where the
method has been less-studied, and where different problems may need to
be resolved. An example of this issue is illustrated in recent work by
Chellemi et al. (2008). These researchers evaluated the ‘UGA 3 way’
in on-farm tests in Florida peppers. Results of four trails were highly
variable, with two showing better yields than the methyl bromide
standard, and two showing worse results. All four trials showed a
reduction in larger (more profitable) peppers in the ‘UGA 3 way’ as
compared to the methyl bromide standard. The cause appeared to be an
overload of potassium in the soil, created by the combined use of the
metam-potassium in the ‘UGA 3 way’ and the growers’ standard
practice of applying a high-potassium fertilizer. 

7.  ECONOMIC FEASIBILITY OF ALTERNATIVES 

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

Readers please note that in this study net revenue is calculated as
gross revenue minus operating costs.  This is a good measure as to the
direct losses of income that may be suffered by the users.  It should be
noted that net revenue does not represent net income 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.  We did
not include fixed costs because it is often difficult to measure and
verify.

Summary of Economic Feasibility

The economic analysis of cucurbit applications compared data on the
yields, crop prices, revenues and costs of using methyl bromide or
alternative pest control regimens. This was done in order to estimate
impacts on cucurbit growers with the decreasing availability of methyl
bromide.  The Georgia 3-Way (1,3-Dichloropicrin with Chloropicrin
followed by metam sodium ) was identified as being a technically
feasible alternative (in cases of low pest infestation) to methyl
bromide in Georgia and the Southeastern United States. Due to
differences in climate and pests, it is uncertain whether or not the
same assumption holds for Maryland and Delaware cucurbit production. 
1,3-D + chloropicrin and metam sodium are also presented in this
analysis as recognized alternatives to methyl bromide; however, neither
are considered technically feasible as yield losses are expected. 

The economic reviewers 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 very good
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 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 cucurbit 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.

Maryland and Delaware

The U.S. concludes that, at present, no economically feasible
alternatives to methyl bromide exist for use in Maryland and Delaware
melon production.  Yield loss and missed market windows, which are
discussed individually below, have proven most important in reaching
this conclusion.

1. Yield Loss

Expected yield losses of 6% are anticipated throughout Maryland and
Delaware melon production.  

2. Missed Market Windows

USG agrees with Maryland and Delaware’s assertion that growers will
likely receive significantly lower prices for their produce if they
switch to 1,3-D + chloropicrin.  This is due to changes in the harvest
schedule caused by the above described soil temperature complications
and extended plant back intervals when using 1,3-D + chloropicrin.  

The analysis of this effect is based on the fact that prices farmers
receive for their cucurbits vary widely over the course of the growing
season.  Driving these fluctuations are the forces of supply and demand.
 Early in the growing season, when relatively few cucurbits are
harvested, the supply is at its lowest and the market price is at its
highest.  As harvested quantities increase, the price declines.  In
order to maximize their revenues, cucurbit growers manage their
production systems with the goal of harvesting the largest possible
quantity of cucurbits when the prices are at their highs.  The ability
to sell produce at these higher prices makes a significant contribution
toward the profitability of cucurbit operations.

To describe economic conditions in Maryland and Delaware melon
production, EPA used weekly and monthly cucurbit sales and production
data from the U.S. Department of Agriculture for the previous three
years to gauge the impact of early season price fluctuations on gross
revenues.  Though data availability was limiting, analysts assumed that
if cucurbit growers adjust the timing of their production system, as
required when using 1,3-D + Chloropicrin, gross revenues will decline by
approximately 5% over the course of the growing season, due solely to
price effects.  The season average price was reduced by 5% in the
analysis of the alternatives to reflect this effect.  Based on currently
available information, the U.S. believes this reduction in price serves
as a reasonable indicator of the typical effect of planting delays
resulting when methyl bromide alternatives are used in Maryland and
Delaware melon production.

Other Considerations: 

In Maryland and Delaware cucurbits, Fusarium oxypsorum niveum exists in
three separate races, and no one crop cultivar has resistance to all
races. Crop experts in Maryland report that methyl bromide alternatives
provided lower protection against the pathogen while also creating
obstacles to meeting premium market windows. USG believes that the best
alternatives (1,3 D + chloropicrin) may offer some defense against the
pathogen (with a yield loss similar to that likely in Michigan).
However, since the crop acreage involved is in low-lying coastal plain,
water-logged soils frequently occur in rainy periods and this could
delay fumigation with this and other alternatives (such as metam-sodium)
and cause additional losses by forcing growers to miss key mid-July
market windows.

The Southeastern USA and Georgia 

In the Southeastern U.S. and Georgia, using the Georgia 3-Way on spring
plantings is believed to be a technically (and thus economically)
feasible alternative to methyl bromide, although some limitations exist.
Referring to Tables 6 through 14, the loss of gross revenue using the
Georgia 3-Way is negligible for Georgia and the Southeastern U.S., while
in some cases gains in gross revenue are expected in Georgia. Unlike
spring plantings, however, yield losses are expected in fall plantings,
with studies in Georgia’s application show a 50% yield loss. The
Georgia 3-Way also cannot be used on cucurbits that are grown in karst
soils since it contains 1,3-D. Therefore, for fall plantings and areas
with karst soils, the use of methyl bromide is critical to Georgia’s
and the Southeastern United States’ cucurbit production. Note that
data describing Georgia cucurbit production is based on double cropping
production practices.  

Southeastern U.S. Analytical Notes 

The applicant provided no data on the operating costs of alternatives. 
Analysts assumed, however, that these costs were similar to those of
methyl bromide with slight upward adjustments for the costs of applying
the alternatives and a slight downward adjustment for the cost of the
alternative product.  In addition, the applicant did not provide data
for second crops (including revenues and operating costs).  Analysts
assumed that Southeastern cucurbits are grown in a single crop
production system.  However, if double cropping is practiced in the
actual production system, this assumption could make the critical need
for methyl bromide appear smaller than it actually is, because the value
the second crop derives from methyl bromide is not included in the
analysis

Georgia Analytical Notes 

Other potentially significant economic factors, such as price reductions
due to missed market windows, were not analyzed for this region as the
case for critical use of methyl bromide is sufficiently strong based
solely on Georgia 3-Way fall yield losses.

Economic analysis of Georgia growing conditions included cost and
production data representing a second cucurbits or peppers crop.

Table 6.  Maryland and Delaware Melon - Economic Impacts of Methyl
Bromide Alternatives

MARYLAND AND DELAWARE MELON	METHYL BROMIDE	1,3-D + CHLOROPICRIN

PRODUCTION LOSS (%)	0%	6%

    PRODUCTION PER HECTARE	2,347	2,207

* PRICE PER UNIT (US$)	$11	$11

= GROSS REVENUE PER HECTARE (US$)	$25,822	$24,273

- OPERATING COST PER HECTARE (US$)	$21,073	$20,366

= NET REVENUE PER HECTARE (US$)	$4,749	$3,907

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	$843

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	$11

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	18%

5. OPERATING PROFIT MARGIN (%)	18%	16%

* Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 7.  Southeastern USA (except Georgia) Cucumber -: Economic Impacts
of Methyl Bromide Alternatives

SOUTHEAST USA (EXCEPT GEORGIA) CUCUMBER	METHYL BROMIDE	GEORGIA 3-WAY
1,3-D + CHLOROPICRIN	METAM SODIUM 

PRODUCTION LOSS (%)	0%	0%	29%	44%

    PRODUCTION PER HECTARE	828	828	588	464

* PRICE PER UNIT (US$)	$16	$16	$16	$16

= GROSS REVENUE PER HECTARE (US$)	$13,245	$13,245	$9,404	$7,417

- OPERATING COST PER HECTARE (US$)	$10,556	$10,652	$9,691	$9,736

= NET REVENUE PER HECTARE (US$)	$2,689	$2,593	-$288	-$2,319

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0 	$96 	$2,976 	$5,007 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0 	$1 	$32 	$54 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	1%	22%	38%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	4%	111%	186%

5. OPERATING PROFIT MARGIN (%)	20%	20%	-3%	-31%

* Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 8.  Southeastern USA (except Georgia) Melons - Economic Impacts of
Methyl Bromide Alternatives

SOUTHEAST USA (EXCEPT GEORGIA) MELON	METHYL BROMIDE	GEORGIA 3-WAY	1,3-D
+ CHLOROPICRIN	METAM SODIUM 

PRODUCTION LOSS (%)	0%	0%	29%	44%

    PRODUCTION PER HECTARE	815 	815 	579 	457

* PRICE PER UNIT (US$)	$15 	$15 	$15 	$15

= GROSS REVENUE PER HECTARE (US$)	$12,232 	$12,232 	$8,685 	$6,850

- OPERATING COST PER HECTARE (US$)	$11,202 	$11,297 	$10,337 	$10,381

= NET REVENUE PER HECTARE (US$)	$1,030 	$934 	($1,652)	-$3,531

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0 	$96 	$2,682 	$4,562 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0 	$1 	$29 	$49 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	1%	22%	37%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	9%	260%	443%

5. OPERATING PROFIT MARGIN (%)	8%	8%	-19%	-52%

* Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 9.  Southeastern USA (except Georgia) Squash -: Economic Impacts
of Methyl Bromide Alternatives

SOUTHEAST USA (EXCEPT GEORGIA) SQUASH	METHYL BROMIDE	GEORGIA 3-WAY	1,3-D
+ CHLOROPICRIN	METAM SODIUM 

PRODUCTION LOSS (%)	0%	0%	29%	44%

    PRODUCTION PER HECTARE	311	311	221	174

* PRICE PER UNIT (US$)	$29	$29	$29	$29

= GROSS REVENUE PER HECTARE (US$)	$9,029	$9,029	$6,411	$5,056

- OPERATING COST PER HECTARE (US$)	$7,338	$7,433	$6,473	$6,517

= NET REVENUE PER HECTARE (US$)	$1,692	$1,596	-$62	-$1,461

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0 	$96 	$1,754 	$3,152 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0 	$1 	$19 	$34 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	1%	19%	35%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	6%	104%	186%

5. OPERATING PROFIT MARGIN (%)	19%	18%	-1%	-29%

* Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 10.  All Southeastern US (except Georgia) Cucurbits - Economic
Impacts of Methyl Bromide Alternatives

ALL SOUTHEAST US (EXCEPT GEORGIA) CUCURBITS	METHYL BROMIDE	GEORGIA 3-WAY
1,3-D + CHLOROPICRIN	METAM SODIUM 

PRODUCTION LOSS (%)	0%	0%	29%	44%

    PRODUCTION PER HECTARE	652	652	463	303

* PRICE PER UNIT (US$)	$18	$18	$18	$17

= GROSS REVENUE PER HECTARE (US$)	$11,502	$11,502	$8,166	$5,235

- OPERATING COST PER HECTARE (US$)	$9,802	$9,899	$8,939	$8,984

= NET REVENUE PER HECTARE (US$)	$1,700	$1,603	-$773	-$3,749

LOSS MEASURES *	 

1. LOSS PER HECTARE (US$)	$0	$97	$2,472	$5,449

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	$1	$27	$59

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	1%	21%	47%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	6%	145%	321%

5. OPERATING PROFIT MARGIN (%)	15%	14%	-9%	-72%

 * Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 11.  Georgia Cucumber - Economic Impacts of Methyl Bromide
Alternatives

GEORGIA CUCUMBERS	METHYL BROMIDE	GEORGIA 3-WAY: SPRING APPLICATION 
GEORGIA 3-WAY: FALL APPLICATION 

PRODUCTION LOSS (%)	0%	0%	50%

    PRODUCTION PER HECTARE	5,740	5,740	2,870

* PRICE PER UNIT (US$)	$12 	$12 	$12

= GROSS REVENUE PER HECTARE (US$)	$67,223 	$67,223 	$33,611

- OPERATING COST PER HECTARE (US$)	$54,251 	$40,226 	$40,226

= NET REVENUE PER HECTARE (US$)	$12,972 	$26,997 	-$6,615

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	-$14,024	$19,587

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	-$151	$211

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	-21%	29%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	-108%	151%

5. OPERATING PROFIT MARGIN (%)	19%	40%	-20%

* Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 12. Georgia Melon   Economic Impacts of Methyl Bromide
Alternatives

GEORGIA MELONS	METHYL BROMIDE	GEORGIA 3-WAY: SPRING APPLICATION 	GEORGIA
3-WAY: FALL APPLICATION 

PRODUCTION LOSS (%)	0%	0%	50%

    PRODUCTION PER HECTARE	                4,275 	                      
4,275 	2,137

* PRICE PER UNIT (US$)	$12	$12	$12

= GROSS REVENUE PER HECTARE (US$)	$49,696	$49,696	$24,848

- OPERATING COST PER HECTARE (US$)	$42,085	$43,288	$43,288

= NET REVENUE PER HECTARE (US$)	$7,610	$6,408	-$18,440

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	$1,202	$26,050

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	$13	$280

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	2%	52%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	16%	342%

5. OPERATING PROFIT MARGIN (%)	15%	13%	-74%

 * Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 13.  Georgia Squash - Economic Impacts of Methyl Bromide
Alternatives

GEORGIA SQUASH	METHYL BROMIDE	GEORGIA 3-WAY: SPRING APPLICATION 	GEORGIA
3-WAY: FALL APPLICATION 

PRODUCTION LOSS (%)	0%	0%	50%

    PRODUCTION PER HECTARE	                 5,251 	                     
  5,251 	2,625

* PRICE PER UNIT (US$)	$8	$8	$8

= GROSS REVENUE PER HECTARE (US$)	$40,556	$40,538	$20,269

- OPERATING COST PER HECTARE (US$)	$43,739	$31,348	$31,348

= NET REVENUE PER HECTARE (US$)	-$3.183	$9,188	-$11,079

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	-$12,372	$7,896

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	-$132	$85

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	-31%	19%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	-389%	248%

5. OPERATING PROFIT MARGIN (%)	-6%	21%	-58%

* Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

Table 14.  All Georgia Cucurbits - Economic Impacts of Methyl Bromide
Alternatives

GEORGIA CUCURBITS	METHYL BROMIDE	GEORGIA 3-WAY: SPRING APPLICATION 
GEORGIA 3-WAY: FALL APPLICATION 	1,3-D + CHLOROPICRIN

PRODUCTION LOSS (%)	0%	0%	50%	29%

    PRODUCTION PER HECTARE	4,741	4,741	2,370	3,404

* PRICE PER UNIT (US$)	$10	$10	$10	$10

= GROSS REVENUE PER HECTARE (US$)	$46,439	$46,435	$23,217	$33,325

- OPERATING COST PER HECTARE (US$)	$44,278	$40,213	$40,213	$43,999

= NET REVENUE PER HECTARE (US$)	$2,161	$6,222	-$16,995	-$10,675

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	-$4,062	$19,156	$12,835

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	-$44	$206	$138

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	-9%	41%	28%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	-188%	887%	594%

5. OPERATING PROFIT MARGIN (%)	5%	13%	-73%	-32%

 * Interpret the loss measures with caution. Negative numbers presented
in rows indicating a “loss” should be interpreted as a “gain”. 
Positive numbers can be interpreted as losses. 

8.  RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

The USG has applied an aggressive transition rate, which is reflected in
the nomination amount and detailed in Table 15. 

Table 15. Nomination Amount.

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Locascio, S.J., J.P. Gilreath, D.W. Dickson, T.A. Kucharek, J.P. Jones,
and J.W. Noling. 1997.

Fumigant alternatives to methyl bromide for polyethylene mulched tomato.
HortSci. 32: 1208-1211. 

Ou, L.-T., K.Y.Chung, J.E. Thomas, T.A. Obreza, and D.W. Dickson.1995.
Degradation of 1,3-

dichloropropene (1,3-D) in soils with different histories of field
applications of 1,3-D. J. Nematol. 25: 249–257.

Roberts W., B. Bruton, W. Fish, and M. Taylor. 2007. Using grafted
transplants in watermelon

production. From the 2007 Proceedings of the Southeast Regional
Vegetable Conference,

Georgia, USA. Available on the web at:  

  HYPERLINK "http://www.tifton.uga.edu/veg/publications.htm" 
http://www.tifton.uga.edu/veg/publications.htm 

Santos, B.M. and J.P. Gilreath. 2007. Effects of propylene oxide doses
on Cyperus and

Belonolaimus control and nutrient absorption in tomato. In press at:
Crop Prot. (2007), doi:10.1016/j.cropro.2007.03.021.

Santos, B.M., J.P. Gilreath, T.N. Motis, J.W. Noling, J.P. Jones, and
J.A. Norton. 2006. Comparing Methyl Bromide Alternatives for Soilborne
Disease, Nematode and Weed Management in Fresh Market Tomato. Crop Prot.
25:690-695.

Smelt, J.H., S.J.H. Crum, and W. Teinissen. 1989. Accelerated
transformation of the fumigant

methyl isocyanate in soil after repeated application of metam sodium. J.
Environ. Sci. Health B24: 437-455.

Taylor, M. B. Bruton, W. Fish, W. Roberts. 2007. Cost benefit analyses
of using grafted

watermelon transplants for Fusarium wilt disease control. Acta
Horticulturae 782: IV

International Symposium on Seed, Transplant and Stand Establishment of
Horticultural

Crops; Translating Seed and Seedling Physiology into Technology.

Verhagen, C., G. Lebbink, and J. Bloem. 1996. Enhanced biodegradation

of the nematicides 1,3-dichloropropene and methyl isothiocyanate in a
variety of soils. Soil Biol. Biochem. 28:1753–1756.

Webster, T. M., A. S. Csinos, A. W. Johnson, C. C. Dowler, D. R. Sumner,
and R. L. Fery. 2001.

Methyl bromide alternatives in a bell pepper – squash rotation. Crop
Prot. 20 (7): 605 – 614.

 It should be noted that 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.

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