**USA CUN11 SOIL Peppers Open Field**  **Page 1 of 15**

NOMINATING PARTY: **The United States of America**

FILE NAME: **USA CUN11 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 2009 for 2011 Use Season)** 

CROP NAME (OPEN FIELD OR PROTECTED): **Peppers Open Field** 

QUANTITY OF METHYL BROMIDE REQUESTED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION

Year N OMINATION A MOUNT

2011 212,775 kilograms

NOMINATING PARTY CONTACT DETAILS: **Contact Person: Hodayah Finman Title: Foreign Affairs Officer**  **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) 647-1123**  **Fax: (202) 647-5947**
**E-mail: finmanhh@state.gov** 

Following the requirements of Decision IX/6 paragra ph (a)(1) The United States of America has determin ed that the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for this use would result in a significant market disru ption

**.** . **■ Yes**   **No**

**Signature Name Date**

**Title:**

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat w ebsite under Decision Ex. I/4(8).)

This form is to be used by holders of single-year e xemptions to reapply for a subsequent year’s exempt ion (for example, a Party holding a single-year exemption fo r 2005 and/or 2006 seeking further exemptions for 2 007). It does not replace the format for requesting a critic al-use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation 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 Pa rty need not re-submit that earlier information.**USA CUN11 SOIL Peppers Open Field**  **Page 2 of 15**

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:
**Contact/Expert Person: Jack Housenger Title: Director (Acting)**  **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: 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 CUN11 SOIL PEPPERS Open Field 15**

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat
**USA CUN11 SOIL PEPPERS OPEN FIELD**

*** Identical to paper documents USA CUN11 SOIL Peppers**  **Open Field Page 3 of 15** 



### METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONM ENT)

PEPPERS

1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICA L 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 met hyl bromide dose rates (see BUNNIE in**  **Appendix A) for the southern regions of US pepper p roduction, since increased use of high**  **barrier films in conjunction with lower rates has b een reported there.** 

**In developing this renomination the USG examined se veral recent studies to determine whether**  **yield losses and market window losses associated wi th the best available fumigant alternative**  **could be altered from previous nominations. Unfortu nately 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 t he monitoring of yields under each treatment.**  **Several such studies included a methyl bromide trea tment or an untreated control but not both, or**  **included both but did not monitor yield, or include d unregistered alternatives. However, research**  **conducted at the University of Georgia that examine d use of a three way combination of**  **alternative fumigants (1,3 D followed by chloropicr in followed by metam-sodium) did meet**  **these criteria, Therefore, nominations for the sou thern US areas were adjusted to reflect the**  **apparent technical feasibility of this three way co mbination of alternative fumigants under VIF**  **or metallized films, as a replacement for spring-t ime 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 i odomethane, along with its registration at the**  **state level in all the pepper producing regions cov ered 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 need ed for the industry to transition to the use of** 
**this material in areas where it is feasible. This t ransition is part of the BUNNIE included in**  **Appendix A.**

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

**The U.S. nomination is only for those areas where t he alternatives are not suitable. In U.S.**  **pepper production there are several factors that ma ke the potential alternatives to methyl bromide** 
**unsuitable. These include: USA CUN11 SOIL Peppers**  **Open Field Page 4 of 15** 

**- Pest control efficacy of alternatives: the efficacy**  **of alternatives may not be comparable to methyl bromide in some areas, making these alternat**  **ives 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 pr**  **essure, and in such cases the U.S. is only nominating a CUE for peppers where the key pes**  **t 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 sout**  **heastern US, even with the best available combination of alternatives (1,3 D + chloropicrin f**  **ollowed by chloropicrin followed by metam-sodium).** 

**Florida, Georgia, and the Southeastern U.S. (outsid e Florida and Georgia) are each presented as**  **separate regions in this nomination to reflect the separate applications from growers in these**  **areas. 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 W HAT ALTERNATIVE STRATEGIES ARE USED TO
CONTROL THE TARGET PATHOGENS AND WEEDS W ITHOUT METHYL
BROMIDE THERE.

**In southeastern U.S., Florida, and Georgia, areas n ot 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.** 

6. SUMMARY OF RECENT RESEARCH

**As mentioned earlier in this document, iodomethane formulated with chloropicrin has shown**  **good efficacy against key pepper pests, including n utsedge, in a number of trials with peppers**  **and related vegetables such as tomatoes (e.g., Louw s 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-leve l approval in 47 US states (California,**  **Washington, and New York are the exceptions at this time). However, other important** **USA CUN11 SOIL Peppers Open Field**  **Page 5 of 15**

**constraints must be considered when assessing the f easibility 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 ap plicators will need to make some equipment**  **modifications to adapt to the lower flow rates typi cal with less expensive iodomethane**  **application rates and to avoid the corrosion of som e 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 te chnically feasible to manage key pepper**  **pests in all parts of the US where it has been regi stered, time will be needed for growers and**  **extension service experts to adapt its use successf ully. Therefore, the amount of methyl bromide**  **nominated for peppers has been adjusted downward wh ile also considering the time needed to** 
**transition to iodomethane.**

**In the short term, and in situations where pepper p roducers cannot use iodomethane, the USG**  **concludes that other fumigant alternatives to methy l 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 we eds and nematodes

**For nutsedge pests, which are widespread in all req uesting 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 eff icacy in small-plot trials in other vegetable**  **crops (e.g, tomato). However, at best, metam sodiu m may allow at least 44 % yield loss, while**  **1,3 D may allow at least 29 % loss. Both often sho w less control than methyl bromide (in terms**  **of population suppression) of nutsedges. These fac tors suggest that even this alternative will not**  **be economically feasible even in the best-case tech nical scenario. It should be noted also that**  **there is evidence that both 1,3 D and methyl isothi ocyanate 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 pr obably 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) a re 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 size s were 20 feet X 32 inches (4.94 m**  **2 ).**  **Treatments were: Methyl bromide standard (67:33 for mulation), untreated control, 2**  **formulations of Telone (1,3 D + chloropicrin) at va rious 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.** **USA CUN11 SOIL Peppers Open Field**  **Page 6 of 15**

**Some important caveats must be mentioned when consi dering these results:**  **(1) Plots used were quite small, and it is not at all c**  **lear if the promising results will hold reliably in larger commercial fields. This is part**  **icularly worrisome given the highly variable results reported by other researchers for**  **the same methyl bromide alternatives. (2)**  **The nutsedge populations in this study were dominat ed by yellow nutsedge (90 % of the**  **total number). It is not clear if populations wher e purple nutsedge is dominant will be**  **controlled as effectively. A number of other studi es have indicated that purple nutsedge**  **is a hardier species, and even in Culpepper and Lan gston’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 nut sedge 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 nem atodes as the key pests present. In the other**  **2 trials yields were not significantly different ac ross different fumigant treatments, but nutsedge**  **pressure was lower in those trials as compared to t he third. Other important caveats to these**  **results are - this was a small-plot study and was d one in Florida. Thus it is not clear how**  **applicable the results are to the more northern reg ions 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 hav e examined several fumigant alternatives to**  **methyl bromide, most done in crops other than peppe rs (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 nutsed ges, diseases, and nematodes. However,**  **USG has examined these papers and concludes that fo r 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 alternative s registered for the crop nominated, the**  **presence of both a methyl bromide standard and an u ntreated 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 (San tos 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, chloropic rin, 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+chlorop icrin in fall-season fumigations to control**  **nutsedge and nematode pests, the yield loss estimat es 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 se ction.** **USA CUN11 SOIL Peppers Open Field**  **Page 7 of 15**

T ABLE 2. DATA ON YIELD LOSSES WITH LIKELY METHYL BROMIDE AL TERNATIVES AND NUTSEDGE

PRESENT AS A CROP PEST

.

Chemicals Rate (kg/ha) Average Nutsedge Density (#/m 2 ) Average

Marketable
Yield (ton/ha) % Yield Loss

(compared to MB)

Untreated (control) **- 300 ab**  **20.1 a**  **59.1** methyl bromide + Pic(67-33), chiselinjected **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 alte rnatives 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 indicat e that a 3-way, sequential combination of**  **several fumigant alternatives is technically feasib le for spring-time fumigation of most vegetable**  **crops. The 3-way combination consists of 1,3 D + ch loropicrin (“Telone C35” brand), followed**  **by chloropicrin at about 168 kg/ha, followed by met am-sodium, all under VIF or metallized**  **(high barrier) tarps, and will henceforth be referr ed 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 r esearch reports available from the University of**  **Georgia at www.gaweed.com**  **).**

T ABLE 3. **N UMBER OF**  **P EPPER**  **F RUIT** 

**- M**  **ETHYL B**  **ROMIDE :**  **C HLOROPICRIN**  **V ERSUS**  **T HREE**  **W AY**  **C OMBINATION** 

**. S**  **PRING 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 o r a sequential treatment. Plots were 3 rows**  **by 100 feet long.**

**Since Georgia is similar to other areas of the sout heastern 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** **USA CUN11 SOIL Peppers Open Field**  **Page 8 of 15**

**indicate that** summer **/** fall **fumigation is not similarly effective with this co mbination of**  **alternatives (Culpepper, personal communication, Cu lpepper 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. S oil 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, wi th a roughly 50 % reduction in both number**  **and weight of harvested vegetables (Table 4). The e conomic implications of this level of yield**  **loss for Georgia pepper growers are further describ ed in section 7, below.** 

**Table 4. Comparing methyl bromide and the 3-Way f or 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 + chloropicr in (“Telone C35” brand) at approximately 192 kg/ha,**  **followed by chloropicrin at 168 kg/ha, followed by metam-sodium at approximately 358 kg/ha. Methyl bro**  **mide + chloropicrin was applied in a 50:50 mix at approxim**  **ately 160 kg/ha of each. Rates as shown are not pla nting bed**  **strip adjusted. (2) “Mulch” refers to the tarp typ e. LDPE = traditional high permeability tarp; Block**  **ade = 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 severa l application modifications to properly use**  **the approach, and this may incur significant capita l 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 communicati on).** 

**Time and further research and extension education w ill also be needed to implement the ‘UGA**  **3-way’ method in areas outside Georgia where the me thod has been less-studied, and where**  **different problems may need to be resolved. An exam ple of this issue is illustrated in recent work** **USA CUN11 SOIL Peppers Open Field**  **Page 9 of 15**

**by Chellemi et al. (2008). These researchers evalua ted 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 w ay’ as compared to the methyl bromide**  **standard. The cause appeared to be an overload of p otassium in the soil, created by the combined**  **use of the metam-potassium in the ‘UGA 3 way’ and t he growers’ standard practice of applying**  **a high-potassium fertilizer.**

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

**The following economic analysis is organized by met hyl 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 los ses of income that may be experienced by the** 
**users. It should be noted that net revenue does no t represent net income to the users. Net**  **income, which indicates profitability of an operati on of an enterprise, is gross revenue minus the**  **sum of operating and fixed costs. Net income shoul d be smaller than the net revenue measured**  **in this study. We did not include fixed costs beca use these costs are often difficult to measure**  **and verify.**

Summary of Economic Feasibility

**The economic analysis of pepper applications compar ed data on the yields, crop prices, revenues**  **and costs of using methyl bromide or alternative pe st control regimens. This was done in order to**  **estimate impacts on pepper growers with the decreas ing availability of methyl bromide. The**  **alternatives identified as technically feasible (in cases of low pest infestation**  **1 ) 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 chlo ropicrin followed by metam sodium.** 

**The economic reviewers then analyzed crop budgets f or 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 isola tion.** 

**(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**

**1 It should be noted that the USG does not request m**  **ethyl 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 CUN11 SOIL Peppers Open Field Page 10 of 15** 

**operation. However, high value commodities or crop s may provide high revenues but may also**  **entail high costs. Losses of even a small percenta ge 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 goo**  **d 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 oper ating 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 en terprise. Again, operating costs may be** 
**difficult to measure and fixed costs even more diff icult, therefore fixed costs were not included**  **in the analysis.**

**These measures represent different ways to assess t he economic feasibility of methyl bromide**  **alternatives for methyl bromide users, who are pepp er producers in this case. Because producers**  **(suppliers) represent an integral part of any defin ition 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 provid e 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 thus ec onomically) feasible alternatives to methyl**  **bromide, although some limitations exist. Referring to Table 5, 6, and 7, the loss of gross**  **revenue using the Georgia 3-Way is negligible in Fl orida and the Southeastern U.S. in**  **comparison to methyl bromide, while gains in gross revenue are expected in Georgia. Although**  **no gains in gross revenue are expected when using i odomethane, losses in net revenue are**  **negligible. One drawback to the Georgia 3-Way is th at yield losses are expected in fall plantings,**  **with studies in Georgia’s application show a 50% yi eld 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 topograph y. Note that data describing Georgia and**  **Florida pepper production are based on double cropp ing production practices.** **USA CUN11 SOIL Peppers Open Field Page 11 of 15** 

T ABLE 5. G EORGIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

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. Negativ e numbers presented in rows indicating a “loss” sho**  **uld be interpreted as a “gain”. Positive numbers can be i**  **nterpreted as losses.**

T ABLE 6. F LORIDA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

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. Negativ e numbers presented in rows indicating a “loss” sho**  **uld be interpreted as a “gain”. Positive numbers can be i**  **nterpreted as losses. USA CUN11 SOIL Peppers**  **Open Field Page 12 of 15**

T ABLE 7. S OUTHEASTERN USA ( EXCEPT G EORGIA ): E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES 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. Negativ e numbers presented in rows indicating a “loss” sho**  **uld be interpreted as a “gain”. Positive numbers can be i**  **nterpreted as losses.**

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTI TIES

**The USG has applied an aggressive transition rate, which is reflected in the nomination amount** 
**and detailed in Table 8.**

TABLE 8. N OMINATION A MOUNT : **2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) – Transition Use Reduction**  **Description Spreadsheet**

.

Southeast Pepper Georgia Pepper Florida Pepper Sector Total / Average

Quantity Requested for 2010: Amount (kgs) 21,579 75,510

359,995

457,084

Quantity Recommended by
MBTOC/TEAP for 2010 : Amount (kgs) 21,579 75,510

359,995

457,084

Amount (kgs) 21,579

75,510

359,995

457,084

Area (ha) 127

444

2,118

2,689

Rate 170

170

170

170

Transition from 2010 Baseline Adjusted Value Percentage (%) -83% -80% -77% -78%

Amount (kgs) 

### 9,140

33,201

170,434

212,775

Area (ha) 61 221 1136 1418

Rate 150 150

150

150 SECTOR PEPPERS

Quantity Approved by Parties

for 2010:

Quantity Required for

2011 Nomination:**USA CUN11 SOIL Peppers Open Field Page 13 of 15** 



### CITATIONS

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