Nominating Party: 	The United States of America

FILE NAME: 	USA CUN13 Soil peppers Open Field 

Brief descriptive Title of Nomination:

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

Crop name (open field or protected): Peppers Open Field

Quantity of methyl bromide requested:

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

Year	Nomination Amount (Kilograms)

2013	5,673 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 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 peppers Open Field 	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 peppers Open field















* Identical to paper documents



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

PEPPERS

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

This renomination covers only peppers grown in the southeastern US,
Georgia, Florida,. 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
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 pepper production, since
increased use of high barrier films in conjunction with lower rates has
been reported there. 

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 such 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, nominations for the southern US areas were adjusted to
reflect the apparent 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 the presence of karst topographical features.

The recent renewal of the federal registration of iodomethane, along
with its registration at the state level in all the pepper producing
regions covered by this nomination, will be factored into calculations
of the total amount of methyl bromide being requested for peppers. This
calculation takes into account the issue that time will be needed for
the industry to transition to the use of this material in areas where it
is feasible. This transition is part of the BUNNIE included in Appendix
A.

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

The U.S. nomination is only for those areas where the alternatives are
not suitable.  In U.S. pepper production there are several factors that
make the potential alternatives to methyl bromide unsuitable.  These
include:

Pest control efficacy of alternatives: the efficacy of alternatives may
not be comparable to methyl bromide in some areas, making these
alternatives technically and/or economically infeasible for use in
pepper production.

Geographic distribution of key target pests: i.e., some alternatives may
be comparable to methyl bromide as long as key pests occur at low
pressure, and in such cases the U.S. is only nominating a CUE for
peppers where the key pest pressure is moderate to high such as nutsedge
in the Southeastern U.S.

Regulatory constraints: e.g., 1,3 D use is limited in Georgia and
Florida due to the presence of karst topography.

Infeasibility of fall-season fumigation in the southeastern US, even
with the best available combination of alternatives (1,3 D followed by
chloropicrin followed by metam-sodium).

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).  

Florida, Georgia, and the Southeastern U.S. (outside Florida and
Georgia) are each presented as separate regions in this nomination to
reflect the separate applications from growers in these areas. In this
nomination, the Southeastern U.S. includes the following states:
Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina,
South Carolina, Tennessee, and Virginia. A brief description of their
need for methyl bromide follows, also presented on a regional basis. 

	

3.	is the use covered by A certification STANDARD?

Methyl bromide is not used to meet a certification standard for pepper
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., Florida, and Georgia, areas not treated have low
levels of nutsedge or nematodes in pepper fields

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?

Better, more consistent pest control efficacy from the alternatives
would be required.

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

As mentioned earlier in this document, iodomethane formulated with
chloropicrin has shown good efficacy against key pepper pests, including
nutsedge, in a number of trials with peppers and related vegetables such
as tomatoes (e.g., Louws et al. 2006, Culpepper 2006, 2007, 2008,
Culpepper et al. 2008, Olsen 2008). Iodomethane had time limitations
removed from its federal label in October, 2008, and has received
state-level approval in 47 US states (California, Washington, and New
York are the exceptions at this time).  However, other important
constraints must be considered when assessing the feasibility of
iodomethane as a methyl bromide alternative. These include: (1) the cost
of iodomethane formulations is higher than methyl bromide, and will
probably remain so for the next several years, (2) growers and
researchers will need time to evaluate iodomethane use in the various
local production conditions covered by this nominations, and (3) growers
and applicators will need to make some equipment modifications to adapt
to the lower flow rates typical with less expensive iodomethane
application rates and to avoid the corrosion of some metals that can
occur with iodomethane (Sumner 2005, Noling et al. 2006).  The economic
impact of using iodomethane is further described in Part E of this
document (below). A consideration of these aspects has led the USG to
conclude that while iodomethane appears to be technically feasible to
manage key pepper pests in all parts of the US where it has been
registered, time will be needed for growers and extension service
experts to adapt its use successfully. Therefore, the amount of methyl
bromide nominated for peppers has been adjusted downward while also
considering the time needed to transition to iodomethane. 

In the short term, and in situations where pepper producers cannot use
iodomethane, the USG concludes that other fumigant alternatives to
methyl bromide would have to be used. The details of this conclusion are
similar to the previous year’s pepper CUN, and are further discussed
below.

Narrative description of studies relevant to key weeds and nematodes

For nutsedge pests, which are widespread in all requesting regions,
pepper 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 peppers,

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. 

Some 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. 

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 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 peppers, 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 pepper
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 2 below, and are used as the basis of part of the
economic assessment in the following section.

Table 2. 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 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

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. Also see several research reports available from the
University of Georgia at   HYPERLINK "http://www.gaweed.com" 
www.gaweed.com ).

Table 3.  Number of Pepper Fruit - Methyl Bromide: Chloropicrin Versus
Three Way Combination.  Spring 2006  

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 peppers 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 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 4). The economic implications
of this level of yield loss for Georgia pepper growers are further
described in section 7, below.

Table 4.  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. 2007b). 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 trials 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.  

Reader, 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 experienced 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 these costs are often
difficult to measure and verify. 

Summary of Economic Feasibility

The economic analysis of pepper 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 pepper growers with the decreasing availability of methyl
bromide.  The alternatives identified as technically feasible (in cases
of low pest infestation) for Georgia, Florida, and the Southeaster U.S.
for peppers are: (a) Iodomethane and (b) the Georgia 3-Way Method, which
includes 1,3-dichloropicrin with chloropicrin followed by metam sodium. 


The economic reviewers then 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 pepper 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, Florida, and the southeastern u.s. 

In Georgia, Florida, and the Southeastern U.S., the Georgia 3-Way on
spring plantings and iodomethane are considered technically and
economically feasible alternatives to methyl bromide, although some
limitations exist. Referring to Table 5, 6, and 7, the loss of net
revenue using the Georgia 3-Way is negligible in Florida and the
Southeastern U.S. in comparison to methyl bromide, while gains in net
revenue are expected in Georgia. Although no gains in gross revenue are
expected when using iodomethane, losses in net revenue are negligible.
One drawback to the Georgia 3-Way is that yield losses are expected in
fall plantings, with studies in Georgia’s application show a 50% yield
loss. These losses are not expected when iodomethane is used. The
Georgia 3-Way also cannot be used on peppers that are grown in karst
soils since it contains 1,3-D; however, iodomethane can be, making
methyl bromide unnecessary for pepper production in areas with karst
topography.  Note that data describing Georgia and Florida pepper
production are based on double cropping production practices.  

Table 5. Georgia : Economic Impacts of Methyl Bromide Alternatives

GEORGIA PEPPER 	METHYL BROMIDE	GEORGIA 3-WAY: SPRING APPLICATION 
GEORGIA 3-WAY: FALL APPLICATION 	IODOMETHANE

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

    PRODUCTION PER HECTARE	5,797	5,797	2,899	5,797

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

= GROSS REVENUE PER HECTARE (US$)	$67,907	$67,907	$33,954	$67,907

- OPERATING COST PER HECTARE (US$)	$55,279	$41,211	$41,211	$56,433

= NET REVENUE PER HECTARE (US$)	$12,629	$26,696	-$7,258	$11,475

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	-$14,067	$19,886	$1,154

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	-$151	$214	$12

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%)	0%	-21%	29%	2%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	-111%	157%	9%

5. OPERATING PROFIT MARGIN (%)	19%	39%	-21%	17%

* 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 6. Florida:  Economic Impacts of Methyl Bromide Alternatives 

FLORIDA PEPPER-DOUBLE CROP	METHYL BROMIDE	GEORGIA 3-WAY	IODOMETHANE

PRODUCTION LOSS (%)	0%	0%	0%

    PRODUCTION PER HECTARE	4,379	4,379	4,379

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

= GROSS REVENUE PER HECTARE (US$)	$51,756	$51,756	$51,756

- OPERATING COST PER HECTARE (US$)	$48,934	$49,030	$49,522

= NET REVENUE PER HECTARE (US$)	$2,822	$2,726	$2,234

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0	$96	$588

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0	$1	$6

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	3%	21%

5. OPERATING PROFIT MARGIN (%)	5%	5%	4%

* 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):  Economic Impacts of Methyl
Bromide Alternatives

SOUTHEASTERN USA (EXCEPT GEORGIA) PEPPER	METHYL BROMIDE	GEORGIA 3-WAY
IODOMETHANE

PRODUCTION LOSS (%)	0%	0%	0%

    PRODUCTION PER HECTARE	2,965	2,965	2,965

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

= GROSS REVENUE PER HECTARE (US$)	$24,463	$24,463	$24,463

- OPERATING COST PER HECTARE (US$)	$21,955	$22,051	$22,543

= NET REVENUE PER HECTARE (US$)	$2,508	$2,412	$1,920

LOSS MEASURES *

1. LOSS PER HECTARE (US$)	$0 	$96 	$588 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$)	$0 	$1 	$6 

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%)	0%	4%	23%

5. OPERATING PROFIT MARGIN (%)	10%	10%	8%

* 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 8. 

Table 8. Nomination Amount:  

Citations



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 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 Peppers Open Field		Page   PAGE  1  of   NUMPAGES  16 

