Nominating Party: 	The United States of America

FILE NAME: 	USA CUN 13 Soil EGGPLANT GROWN IN OPEN FIELDS 

Brief descriptive Title of Nomination: Methyl Bromide Critical Use
Nomination for Pre-plant Soil Use for Eggplants Grown in Open Fields
(Submitted in 2011 for 2013 Use Season)

Crop name (open field or protected): Pre-plant Soil Use for Eggplant
Grown in Open Fields 

Quantity of methyl bromide requested in each year of nomination:

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

Year	Nomination Amount 

2013	1,381 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).) 

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 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:	  HYPERLINK "mailto:Housenger.Jack@epa.gov" 
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 CUN13 Soil Egg plant grown in open fields 	15













	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 Eggplant Open Field 















* Identical to paper documents

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

EGGPLANT 

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

This nomination covers eggplant grown for fresh market in the States of
Florida and Georgia. The crop is generally grown in open fields and
followed by various other crops.  Harvest is mainly for fresh market. 

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.

Georgia

Continued efforts are underway in Georgia to implement effective and
economical alternatives to methyl bromide.  A 3-WAY fumigation system,
developed by University of Georgia, and dimethyl disulfide (DMDS,
currently unregistered in the US) plus chloropicrin are two alternatives
that appear to be potential replacements for methyl bromide. During
2008, 40% of the fumigated plasticulture land for vegetable crops was
treated with the 3-WAY which includes a systems approach of
1,3-dichloropropene, chloropicrin, and metam sodium.  Dimethyl disulfide
plus chloropicrin has also proven to be effective in managing many
pests, including nutsedge, and has the potential to be adopted once the
product is registered assuming it is economically feasible. 

Although both the Georgia 3-WAY and DMDS + chloropicrin appear
promising, neither fumigant system will stand alone in managing pests. 
An effective herbicide program must also be developed to complement
these fumigant systems.  The 3-WAY does not provide adequate nutsedge
control with summer/fall fumigations and the DMDS system does not
adequately control grasses or Amaranthus species.  Until a program using
fumigants and herbicides is developed, having methyl bromide available
is essential.

The two aforementioned fumigant systems also pose significant challenges
when determining the time interval needed between fumigating and
planting.  Initial research results suggest the plant back interval for
the 3-WAY will be at least 3 times longer than that noted with methyl
bromide. Early indications suggest that the plant back interval for DMDS
plus chloropicrin applied under high barrier mulch will be similar to
the 3-WAY fumigation system.

The latest research information indicates that 3-way system continues to
perform well in the spring, but perform poorly on nutsedge control in
the fall.  Applications of mixture of DMDS and chloropicrin (79:21), at
45 to 50 gallons/acre in the spring and fall will effectively control
nutsedge. Present and future research is focusing on developing and
implementing a herbicide program to compliment both the 3-WAY and DMDS
fumigant systems as well as determining the amount of time that must
pass between fumigating with these alternatives and planting.

Florida

The nutsedge, root-knot nematodes, and fungal diseases like phytopthora
blight, and southern blights are continued to be major problems in
eggplant production in Florida.  In this State, eggplant is grown
year-round, and often double cropped with pepper or cucumber following
the eggplant harvest. The crop that follows eggplant in a double
cropping production system depends upon prevailing environmental and
economic factors. Growers in Florida often plant eggplant as an extra
crop and grow okra, squash, or cucumbers after eggplant has been
harvested.  A spring crop of eggplant may follow as a second crop after
a fall crop of pepper or tomato.  Eggplant does best on well-drained,
fertile, sandy-loam soils at a pH of 6.0-6.5.  Poorly drained soils may
result in slow plant growth, reduced root systems, and low yields.
Eggplant requires a long, warm, frost-free growing season, usually of
14-16 weeks. Cold temperatures below 5oC injure this crop. The best
temperatures are 27-32oC during the day and 21-32oC during the night. 
Plant growth is curtailed at temperatures below 16oC.  Additionally,
soil temperature below 16oC restricts germination. However, most of the
eggplant is started in the field from transplants.  Methyl bromide is
always used in the full-bed mulch process. 

Until 1999, the chemical formulation primarily used was 98 percent
methyl bromide and two percent chloropicrin. Since then, growers have
shifted to formulations with lower concentrations of methyl bromide and
higher amounts of chloropicrin due to the phase-out schedule of methyl
bromide.  At present, the standard formulation contains 50% methyl
bromide in Florida.  

The best alternative, 1,3-D (Telone), may not be applied in Florida in
the areas overlying karst geology, which is common throughout the
Southeastern States.  There is also a 21-day planting delay (vs. 14 days
for MB) due to regulatory restrictions for 1,3-D + chloropicrin. 

Currently, the best alternative to use of methyl bromide in Florida
seems to be applying Telone C-35 (1,3-Dichloropropene +  35%
Chloropicrin), applied at prebed 35 gal./acre  rate 3 to 5 wks before
transplanting.  This fumigant application is supplemented by an
herbicide treatment (tank mixed treatment of 2 lbs of napropamide with
0.5 lbs of trifluralin per acre to achieve a proper weed control. 
However, the use of Telone in 63% of Florida eggplant production land is
restricted due to the presence of Kast topography.  

Iodomethane, a new methyl bromide alternative, was registered in the
U.S., in October, 2007.  Iodomethane, however, is not registered for use
on eggplant. EPA feels that it is appropriate not to include iodomethane
as a methyl bromide substitute for eggplant at this time. The U.S.
nomination is only for those areas in Georgia and Florida where the
alternatives are not feasible. 

If methyl bromide were to be unavailable for U.S. eggplant, growers in
the regions cited in this nomination would have to discontinue growing
this crop or suffer substantial losses.  Growers would either leave
agriculture entirely or switch to other crops that do not rely on
pre-plant fumigation to control soil pests.  The extent of this impact
on the affected growers is debatable, but given the early state of
commercial deployment of methyl bromide alternatives, it is possible
that growers who currently use methyl bromide would face this outcome.  

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.    

SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

Although both the 3-WAY and DMDS (dimethyl disulfide) plus chloropicrin
appear promising, neither fumigant system will stand alone in managing
pests.  An effective herbicide program must be developed to complement
these fumigant systems.   It is also important to keep in mind that DMDS
remains unregistered for use in the US. Current review of available
research indicate that the 3-WAY does not provide adequate nutsedge
control with summer/fall fumigations and the DMDS system does not
adequately control grasses or Amaranthus species. The most recent
studies have reported that a 79:21 mixture of DMDS and chloropicrin is
the most effective combination of these two fumigants (Culpepper et al.,
2008). 

In the Southern U.S., mainly in Florida and Georgia, where nutsedge is a
main methyl bromide target pest, 1,3-D or metam sodium, alone or in
combination, may not adequately control this weed.  In karst
topographical feature areas, which include 31 counties in Florida. 
1,3-D (Telone II) is highly restricted and metam sodium or metam
potassium is the best alternatives available.  However, further testing
of these chemicals in large scale commercial fields is needed.  In
Florida and Georgia, farmers using 1,3-D and metam sodium in the fall
would require longer waiting periods for planting.  Metam sodium or
1,3-D requires waiting periods of  28 and 21 days, respectively, whereas
only 14 days are needed for methyl bromide.  Such delays could result in
missed market windows.  Metam sodium efficacy appears to decline where
it is applied repeatedly due to enhanced degradation of its active
ingredient, methyl isothiocyanate, by soil microorganisms (Ashley, et
al., 1963; Ou et al., 1995; Verhagen et al., 1996; Gamlied et al.,
2003).  

Iodomethane, a new methyl bromide alternative, was registered for some
crops in the U.S., in October, 2007.  Iodomethane, however, is not
registered for use on eggplant. EPA feels that it is appropriate not to
include iodomethane as a methyl bromide substitute for eggplant at this
time. 

IS THE USE COVERED BY A CERTIFICATION STANDARD? 

Methyl bromide is not used to meet a certification standard for eggplant
production 

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.

A three-way fumigation system developed by University of Georgia, as
well as dimethyl disulfide (DMDS) plus chloropicrin are the two
alternatives that appear the most promising to replace methyl bromide.
During the spring of 2008, at least 40% of the land fumigated for
vegetable crops in the spring was treated with the 3-WAY which includes
a systems approach of 1,3-dichloropropene, chloropicrin, and metam
sodium.   It is likely that 30 to 40% of Georgia’s total crop will be
treated with this alternative during 2008.  Dimethyl disulfide (DMDS)
plus chloropicrin also proven to be effective in managing many pests and
has the potential to be adopted once the price structure is known.
Although both the 3-WAY and DMDS appear promising, neither fumigant
system will stand alone in managing pests.  An effective herbicide
program must be developed to compliment these fumigant systems.  The
3-WAY does not provide adequate nutsedge control with summer/fall
fumigations and the DMDS system does not adequately control grasses or
Amaranthus species.  The reader is reminded that DMDS remains
unregistered for use in the United States. Until a program using
fumigants and herbicides is developed, having methyl bromide available
is essential. 

In karst topographical feature areas, which include 31 counties in
Florida, Telone is highly restricted and metam sodium or metam potassium
is the best alternatives available.  However, further testing of these
chemicals in large scale commercial fields is needed.  In Florida and
Georgia, farmers using 1,3-D and metam sodium in the fall would require
longer waiting periods for planting.  Metam sodium or 1,3-D requires
waiting periods of  28 and 21 days, respectively, whereas only 14 days
are needed for methyl bromide.  Such delays could result in missed
market windows.  Metam sodium efficacy appears to decline where it is
applied repeatedly due to enhanced degradation of its active ingredient,
methyl isothiocyanate, by soil microorganisms (Ashley, et al., 1963; Ou
et al., 1995; Verhagen et al., 1996; Gamliel et al., 2003).  

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 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.  STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO
METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT
IS BEING REQUESTED 

A: KEY PATHOGENS: Phytophthora capsici, Pythium spp. and nematodes
(Meloidogyne spp.)

Summary of studies relevant to key pathogens

New research information on use of soil fumigants, specifically in
eggplant production is not available in the public domain. Hausbeck and
Cortright (2004) conducted a small-plot field trial on several
vegetables, including eggplant.  Results, submitted with the 2007 CUE
request, indicate that 1,3 D + 35 % chloropicrin treatments
(shank-injected at 56.7 liters/ha) for control of Phytophthora and
Fusarium resulted in a 44% yield loss, compared to methyl bromide plots.
 Chloropicrin plots alone (shank-injected at 233.6 l/ha) showed a 15.5%
loss compared to methyl bromide plots. Metam-potassium + chloropicrin
plots showed yields similar to those treated with methyl bromide.
Metam-sodium was not tested, but can be assumed to be equivalent to
metam-potassium since the active ingredient is the same. Even large
differences in average yields across various treatments were often not
statistically significant. 

In studies with other vegetable crops, fumigation with 1, 3 D +
chloropicrin has generally provided better control of fungi than
metam-sodium , 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.  P.
capsici was not present in test plots, though Fusarium spp. were. 
However, as compared to the methyl bromide standard treatment plots,
squash fruit weight was 63 % lower in the 1,3 D plots.  The proportion
of marketable squash fruit in the 1,3 D plots was 30 % lower than that
in the methyl bromide plots. 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.
Fusarium (but not P. capsici) was one of several pests present. 

These studies indicate that, trials show promise for
metam-sodium/potassium + chloropicrin, there is inconsistency in
efficacy and protection from yield losses. However, the trials were
conducted in June, and it is unclear whether these results would hold if
fumigation were done under cooler spring temperatures.  Further, no
large scale field trials have yet been performed to demonstrate
consistent pest control similar to that provided by methyl bromide. 

Culpepper and Langston (2004) compared the effectiveness of several soil
fumigants on nematodes affecting peppers in Tifton, Georgia.  Since
eggplants were not included in these tests, data from peppers are again
used to “bridge” a discussion.  Results show that 1,3-D followed by
chloropicrin was as effective as methyl bromide against nematodes. 
Spring and fall crop yield in these plots were similar to yield in
methyl bromide plots.  

Root knot nematodes Meloidogyne spp., also affect Georgia eggplants. 
Their damage to the root may facilitate plant invasion by fungal
pathogens, which can lead to wilt, loss of plant vigor, and yield
losses.  Fumigant alternatives such as metam-sodium have proven
inconsistent (Noling, 2003; FFVA, 2002).

Diseases caused by soil-borne fungi, (e.g., Phytophthora spp., Pythium
spp. and Sclerotium rolfsii) are endemic in many vegetable production
areas in Georgia.  Fungicides such as chlorothalonil and
azoxystrobilurin are only used prophylactically and may not offer
sufficient plant protection.  Resistance of Phytophthora spp. to
metalaxyl and mefenoxam has been reported in tomato and pepper (Lamour
and Hausbeck, 2003)

The use of 1,3-D and metam sodium in the fall is impractical because of
the long waiting periods for planting following application under
plastic mulch. For 1,3-D there is a 28 day waiting period; for metam
sodium, there is a 21-day waiting period.  Such delays would cost
growers at least half of the harvest season, thereby missing the higher
market windows.  Thus, since the fall crop is dependent upon timely
planting, the required waiting period would cost growers at least half
of the harvest season, thereby missing the higher market windows
(Kelley, 2003).

B: KEY WEEDS: Nutsedges

Table 2: data on trials of Fumigant Alternatives to Methyl Bromide for
Polyethylene-Mulched Tomato (Locascio et al. 1997) 

Chemicals	Rate (kg/ha)	Average Nutsedge Density

(#/m2)	Average Marketable Yield

(ton/ha)	% Yield Loss (compared to methyl bromide)

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 Na, Flat Fumigation	300 l	320 a	22.6 a	54.0

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



Narrative description of studies relevant to target weeds

For nutsedge, which is widespread in all requesting regions, growers do
not 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, metam sodium use may result in a 44% yield loss, while use of
1,3 D may result in a 29% loss.  These fumigants often provide less
control of nutsedges than methyl bromide.  Furthermore, there is
evidence that both 1,3 D and methyl isothiocynate levels decline more
rapidly due to enhanced degradation of these chemicals by soil
microorganisms, thus further compromising efficacy, in areas where these
are repeatedly applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et
al., 2003; Dungan and Yates, 2003). 

Results from small plot studies conducted in Tifton, Georgia, by
Culpepper and Langston (2004) show that 1,3-D followed by chloropicrin
was significantly less effective than methyl bromide against both purple
and yellow nutsedge, although this treatment performed as well as methyl
bromide relative to spring and fall crop yield.  1,3-D + chloropicrin,
followed by more chloropicrin was more effective than methyl bromide
against yellow nutsedge, but less effective against purple nutsedge. 
This treatment performed as well as methyl bromide in terms of spring
yield, but poorly in terms of fall yield.  1,3-D + chloropicrin,
followed by metam sodium was 36% less effective than methyl bromide for
purple nutsedge control, but as effective as methyl bromide against
yellow nutsedge.  However, test plots were small, and it is unclear if
these results will hold in commercial fields, considering the variable
results reported elsewhere for these alternatives.  The nutsedge
populations in this study were dominated by yellow nutsedge (90% of the
total).  It is not clear if populations where purple nutsedge is
dominant would be controlled as effectively, since other studies have
shown that purple nutsedge is a hardier species. Current review of
available research indicate that the 3-WAY does not provide adequate
nutsedge control with summer/fall fumigations and the DMDS system does
not adequately control grasses or Amaranthus species. The most recent
studies have reported that a 79:21 mixture of DMDS and chloropicrin is
the most effective combination of these 2 chemicals (Culpepper et al.,
2008).  Present and future research are focusing on developing and
implementing a herbicide program to compliment both the 3-WAY and DMDS
fumigant systems as well as determining the amount of time that must
pass between fumigating with these alternatives and planting.

  

In Florida, the best currently available alternative for eggplant
production (which cannot be used in areas containing karst topographical
features) is an application of Telone C-35 (1,3-D + 35% chloropicrin),
at 35 gallons per acre, 3-5 weeks before transplanting, followed by an
application of a herbicide mix of napropamide and trifluralin to the top
of the raised bed at the time of tarp laying (Noling and Botts, 2007).  

A soil treatment recently developed by the University of Georgia appears
to be promising as a methyl bromide replacement for Georgia’s eggplant
spring crop, although not for the summer or fall crops.  This treatment,
known as the “UGA 3-WAY”, consists of three successive soil
fumigations, beginning with 1,3-D, followed by a chloropicrin
application, followed by a metam-sodium or metam-potassium application
(Culpepper, 2007a). In 2006, Culpepper et al. (2007a) tested the
effectiveness of fall applications of methyl bromide alternatives,
including the UGA 3 WAY treatment, on nutsedges infesting the spring
bell pepper crop in Tyty, Georgia.   Results of this small-plot study
show that the UGA 3-WAY alternative (see above) performed as well as the
standard methyl bromide application.  Similarly, reducing the standard
rates of methyl bromide by 50%, from 392 kg/ha under standard LDPE film
to 196 kg/ha under metalized film, also provided excellent purple
nutsedge control.  Pepper yields were comparable in all treated plots.  

In a related small plot trial, conducted by Culpepper (2007b) in Echols
County, Georgia, during the spring of 2006, excellent purple nutsedge
control was achieved with 484 kg of methyl bromide/ha under standard
film and 336 kg of methyl bromide/ha under metalized film.  However,
further reducing the methyl bromide rate by 50% to 224 kg/ha, under
metalized film, resulted in poor nutsedge control.  Soil fumigation took
place in February.  Culpepper concludes that, based on research
conducted over the past three years with methyl bromide applied under
metalized film, a 33% reduction of the standard 67:33 formulation is
possible in fields heavily infested with weeds, and a 40% reduction in
fields with light weed infestations, whereas reducing the methyl bromide
rate by 50% would be unsustainable for weed control.

Although these results are promising, results from small plot research
need to be verified at the commercial level, in on-farm trials. 
Furthermore, most research in Georgia has so far focused on nutsedge. 
Additional work is needed to determine the efficacy of alternatives on
other weed species, such as morning glory and pigweed.  Finally, the
economics of transitioning to alternatives has not been fully worked
out, including the cost and durability of films and the modification of
fumigation equipment 

 

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 eggplant 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 eggplant growers with the decreasing availability of methyl
bromide.  The Georgia 3-Way (1,3-dichloropropene with chloropicrin
followed by metam sodium) was identified as being a technically feasible
alternative (in cases of low pest infestation and in spring fumigations
only) to methyl bromide in Georgia and Florida eggplant production.
1,3-D + chloropicrin is also being recognized as an alternative to
methyl bromide; however, it is not 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 eggplant 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.

Georgia and Florida

In Georgia and Florida, using the Georgia 3-Way on spring plantings is
believed to be a technically and economically feasible alternative to
methyl bromide, although some limitations exist. Referring to Tables 3
and 4, the loss of net revenue using the Georgia 3-Way is negligible for
Florida in comparison to methyl bromide, while gains in net revenue are
expected in Georgia. Unlike spring plantings, however, yield losses are
expected in fall plantings, with studies in Georgia’s application
showing 50% yield losses. The Georgia 3-Way also cannot be used on
eggplants 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 Florida’s eggplant
production. Note that data describing Georgia eggplant production is
based on double cropping production practices.  

 

Florida Analytical Notes:

Florida’s application for methyl bromide critical use indicated that
more than one crop is typically grown per growing season but did not
provide specific production and sales data for this crop.  As a result
of this gap in data, economic assessment of Florida eggplant production
was based on a single crop production system.  This characterization of
growing conditions could result in the critical need for methyl bromide
appearing smaller than it actually is, because the value the second crop
derives from methyl bromide is not included in the analysis.

Table 3: Georgia - Economic Impacts of Methyl Bromide Alternatives

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

PRODUCTION LOSS (%)	0%	0%	50%

    PRODUCTION PER HECTARE	7,070	7,070	3,535

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

= GROSS REVENUE PER HECTARE (US$)	$57,547	$57,547	$28,774

- OPERATING COST PER HECTARE (US$)	$45,271	$34,610	$34,610

= NET REVENUE PER HECTARE (US$)	$12,277	$22,938	-$5,836

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0 	($10,661)	$18,113 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0 	($71)	$121 

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	-87%	148%

5. OPERATING PROFIT MARGIN (%)	21%	40%	-20%

Note: Georgia eggplant revenue and cost measures were calculated using
data from a two crop per growing season production system.

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 4: Florida - Economic Impacts of Methyl Bromide Alternatives

FLORIDA EGGPLANT	METHYL BROMIDE	GEORGIA 3-WAY: SPRING APPLICATION 	1,3-D
+ CHLOROPICRIN

PRODUCTION LOSS (%)	0%	0%	29%

    PRODUCTION PER HECTARE	1,764	1,764	1,252

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

= GROSS REVENUE PER HECTARE (US$)	$19,983	$19,983	$14,188

- OPERATING COST PER HECTARE (US$)	$17,891	$17,976	$17,303

= NET REVENUE PER HECTARE (US$)	$2,092	$2,007	-$3,116

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0 	$85 	$5,208 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0 	$1 	$70 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	0%	26%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	4%	249%

5. OPERATING PROFIT MARGIN (%)	10%	10%	-22%

* 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 5. 

Table 5. Nomination Amount:  

Citations



Aerts, M. 2003. Asst. Director, Environmental and Pest Management
Division, Florida Fruit and Vegetable Association.  Personal
Communication with G. Tomimatsu, December 2, 	2003.

Banks, H. J.  2002.  2002 Report of the Methyl Bromide Technical Options
Committee, 2002 Assessment.  Pg 46.

Chellemi, D.O., R. C. Hochmuth, T. Winsberg, W. Guetler, K. D. Shuler,
L. E. Datnoff, D. T. Kaplan, R. McSorley, R. A. Dunn, and S. M. Olson.
1997. Application of soil solarization to fall production of cucurbits
and pepper. Proc. Fla. State Hort. Soc. 10:333-	336.

Cortright, B. 2003.  Field Research Associate University of Michigan. 
Personal Communication with G. Tomimatsu, November 24, 2003.

Cortright, B.D. and M.K. Hausbeck. 2004. Evaluation of fumigants for
managing Phytophthora crown and fruit rot of solanaceous and cucurbit
crops, plot two, 2003.  Unpublished study (MI CUE # 03-0061).

Csinos, A.S., D.R. Sumner, R.M. McPherson, C. Dowler, C.W. Johnson, and
A.W. Johnson. 1999. Alternatives for methyl bromide fumigation of
tobacco seed beds, pepper, and tomato seedlings.  Proc. Georgia Veg.
Conf. Available on the Web at
http://www.tifton.uga.edu/veg/Publications/Gfvga99.pdf

Culpepper, A.S.  2007a.  Methyl bromide CUE data generated in Georgia
(Fall, 2006 – Spring, 	2007), Appendix 1.  

Culpepper, A.S.  2007b.  Impact of mulch type on rate of methyl bromide
needed to control 	nutsedge.  Methyl bromide CUE data generated in
Georgia (Fall, 2006 – Spring, 2007), 	Appendix 4. 

Culpepper, A.S., A.L. Davis, T.M. Webster, A.W. MacRae, and D.L.
Langston.  2007a.  Bell 	pepper and nutsedge response to fall applied
methyl bromide alternative fumigants in 	Georgia.  UGA Weed Science. 
At:   HYPERLINK "http://www.gaweed.com"  www.gaweed.com 

Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J.
Mayfied, T. Webster, and W. 	Upchurch.  2007b. Can Georgia growers
replace methyl bromide?  MBAO Conference, 	San Diego, California, 2007. 
              

	  HYPERLINK "http://mbao.org/2007/PDF/Preplant/PP4/Culpepper(20).pdf" 
http://mbao.org/2007/PDF/Preplant/PP4/Culpepper(20).pdf 

Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J.
Mayfied, T. Webster, and W. Upchurch.  2008. DMDS or the 3-Way: Which is
more effective in Georgia.  Orlando, Florida, 2008.   HYPERLINK
"http://mbao.org/2008/007Culpepper.pdf" 
http://mbao.org/2008/007Culpepper.pdf 

Duncan, R. S. and S. R. Yates. 2003. Degradation of fumigant pesticides:
1,3-Dichloropropene, Methyl isothiocyanate, chloropicrin, and methyl
bromide.  Vadose Zone Journal 2:279-286.

Florida Fruit and Vegetable Association (FFVA).  2002. Application for
the Methyl Bromide Critical Use Exemption on Solanaceous Crops (other
than tomato).  September 9, 2002.

Frank, J.R., P. H. Schwartz and W.E. Potts. 1992. Modeling the effects
of weed interference periods and insects on bell peppers (Capsicum
annuum). Weed Sci. 40:308-312.

Gevens, A.J. and M.K. Hausbeck. 2003. A first report of Phytophthora
capsici in irrigating water near cucurbit fields in Michigan (Abstr).

Gilreath, J. P. B. M. Santos, T. N. Motis, J. W. Nolling, and J. M.
Mirusso.  2005.  Methyl Bromide alternatives for nematode and Cyperus
control in bell pepper (Capsicum annum). Crop Protection  24:903-908. 

Kelley, W. T. 2003, Professor, University of Georgia. Personal
communication with G. Tomimatsu, November 24, 2003.

Lamour, K. H.  and M. Hausbeck.  2003.  Effect of Crop Rotation on the
survival of Phytophthora capsici in Michigan. Plant Dis. 87:841-845.

Lewis, C. 2003 (President, Hy-Yield Bromine).  Personal communication
through S.A. Toth (  HYPERLINK "mailto:steve_toth@ncsu.edu" 
steve_toth@ncsu.edu ) , Extension Entomologist & Pest Management
Information Specialist, North Carolina State University; message
forwarded electronically to G. Tomimatsu, December 29, 2003.

Melban, K. 2003. California Pepper Commission. Personal Communication
with G. Tomimatsu.   HYPERLINK "mailto:Kenny@tabcomp.com" 
Kenny@tabcomp.com . 11/26/2003.

Noling, J. W. 2003. University of Florida-Lake Alfred. Personal
Communication with G. Tomimatsu.   HYPERLINK "mailto:Jwn@lal.ufl.edu" 
Jwn@lal.ufl.edu . 11/25/2003.

Noling, J.W., E. Rosskopf, and D.L. Chellemi. 2000. Impacts of
alternative fumigants on soil pest control and tomato yield. Proc.
Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions
Reductions. Available on the web at   HYPERLINK
"http://www.mbao.org/mbrpro98.html"  http://www.mbao.org/mbrpro00.html .

Noling, J.W. and D.A. Botts.  2007.  Alternatives to methyl bromide soil
fumigation for 	Florida 	vegetable production.  University of Florida
IFAS Publication.  At:    

	  HYPERLINK "http://edis.ifas.ufl.edu/CV290" 
http://edis.ifas.ufl.edu/CV290   and:

	  HYPERLINK "http://edis.ifas.ufl.edu/pdffiles/CV/CV29000.pdf" 
http://edis.ifas.ufl.edu/pdffiles/CV/CV29000.pdf 

Stall, W.M. and J. Morales-Payan. 2000. The critical period of nutsedge
interference in tomato. S.W. Florida Research & Education Center.  
HYPERLINK "http://www.imok.ufl.edu/liv/groups/IPM/weed_con/nutsedge.htm"
 www.imok.ufl.edu/liv/groups/IPM/weed_con/nutsedge.htm 

USDA.  2002.  Crop Profiles: Florida Eggplant.    HYPERLINK
"http://pestdata.ncsu.edu/cropprofiles/docs/FLeggplant_.html" 
http://pestdata.ncsu.edu/cropprofiles/docs/FLeggplant_.html 

U.S. EPA. 2002. Peppers-Field. Peppers Grown Outdoors on Plastic Mulch. 
CUN2003/058

Webster, T. M., A.S. Csinos, A.W. Johnson, C. C. Dowler, D. R. Sumner,
R. L. Fery. 2001. Methyl bromide alternatives in a bell pepper-squash
rotation. Crop Protection 20:605-614.

 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.

USA CUN13 Soil Eggplant Grown in Open Fields		Page   PAGE  1  of  
NUMPAGES  16 

	

COVER SHEETS

For Administrative Purposes only:

Date received by Ozone Secretariat:

YEAR:	CUN:

