USA CUN11 SOIL Orchard Replant Open Field Page 1 of 20 

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 SOIL ORCHARD REPLANT Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Orchard Replant in Open 

Fields (Submitted in 2009 for 2011 Use Season) 

CROP NAME (OPEN FIELD OR PROTECTED): Orchard Replant Open Field

QUANTITY OF METHYL BROMIDE REQUESTED: 

TABLE 1: QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

Year NOMINATION AMOUNT

2011 203,591 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 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. 
USA CUN11 SOIL Orchard Replant Open Field Page 2 of 20 

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 ORCHARD REPLANT Open Field 

 

 

 

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 CUN11 SOIL ORCHARD REPLANT Open Field 

 

 

 

* Identical to paper documents 
USA CUN11 SOIL Orchard Replant Open Field Page 3 of 20 

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

ORCHARD REPLANT 

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

The U.S. nomination for methyl bromide for orchard replant in 2011 is for the portion of replant 

sites where alternatives are not suitable, either because of legal restrictions or physical 

characteristics, such as unacceptable soil type or moisture or topography. The orchard area 

previously nominated for methyl bromide ranged from 37 ha for raisin grapes to 752 ha for stone 

fruit replant. These critical areas represent a small portion of the entire orchard replant in 

California. 

Research studies are ongoing to identify methods and technologies to reduce reliance on high 

rates of fumigants, including the use of GPS-based application equipment (e.g., Browne et al., 

2008; Upadhyaya et al., 2008). According to Browne et al. (2008) “orchardists have shifted 

heavily towards use of 1,3-dichloropropene instead of MB for soil fumigation, but this transition 

does not appear to be stable in a regulatory sense or completely effective in terms of resulting 

crop performance.” Previously, McKenry et al. (2007, 2006) and Caprile and McKenry (2006) 

have reported on methods that can help to replant many orchard sites without methyl bromide. 

Methyl bromide continues to be a critical tool for sites that are not amenable to other treatments 

due to features such as soil type or soil moisture, or regulatory restrictions, or activity against 

certain pests, such as Armillaria root rot (e.g., UC Pest Management Guidelines, 2008). In 

addition, new regulations to reduce volatile organic compound emissions may cause a delay of 

fumigation beyond October into November and December in some locations (e.g. San Joaquin 

Valley) when soils are colder. This may result in reduced efficacy of the primary alternative 1,3-

D. 

The Orchard Replant sector comprises stone fruit, almond, and walnut orchards, and grape 

vineyards grown in California. Fumigation prior to replanting orchards or vineyards is used to 

optimize initial growth of young plants in orchard sites with minimal pest populations. Because 

of the perennial nature of orchards, fumigation occurs only once and is the most efficient system 

to avoid slow tree growth, early tree removal, added costs, and lost revenue. In addition, 

effective fumigation appears to reduce the effects of a poorly understood disease complex called 

orchard replant “problem”, or “disorder” The problem can be of varying severity depending on 

orchard location, crop, soil texture, soil moisture, or other factors. Orchards with replant 

problem have several visible symptoms—the most apparent is poor tree growth during the early 

years of establishment (rejection component). Orchard replant problem presents a challenge to 

growers when replanting orchards and vineyards, considering the long-term investment 

(typically fruit orchards and vineyards can produce for 20-25 years, walnut orchards can produce 

for 40 years, and almond orchards produce on average 25-30 years) that is necessary for fruit and 

nut orchard production. For orchard replant situations where other fumigants are not available, 

methyl bromide is critical.
USA CUN11 SOIL Orchard Replant Open Field Page 4 of 20 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

Alternatives are considered not feasible where 1) they have not been sufficiently tested or 

protocols have not been sufficiently developed for their use, 2) costs are excessive, 3) application 

difficulties exist due to such factors as hilly terrain or equipment requirements, 4) areas of 

environmental sensitivity or characteristics reduce their efficacy, 5) regulatory restrictions 

prevent their use, 6) pest pressure is to such an extent that alternatives are not effective. 

Only those orchard replant sites that have no alternatives are being nominated for critical use of 

methyl bromide, which represents a small portion of total replant sites (Table 1). There is a 

critical need for methyl bromide where there are legally mandated township caps for 1,3-D, or 

because surface moisture requirements cannot be met (e.g., soils can not be adequately dried 

prior to use of 1,3-D). New regulations to reduce volatile organic compound emissions may 

reduce the efficacy of 1,3-D by requiring a delay in fumigation to November or December when 

soils are colder. The best alternatives for orchard replant that have been identified are 1,3-D or 

1,3-D with chloropicrin, and/or metam-sodium, especially in coarse-textured soils. Under 

certain soil and moisture conditions (less than 12% to 1.5 meters) 1,3-D is an effective 

management tool for replant problems and is currently used to replant the majority of orchard 

and vineyard sites. 

3. IS THE USE OF METHYL BROMIDE COVERED BY A CERTIFICATION 

STANDARD?

Methyl bromide is not used to meet a certification standard for orchard replant. 

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. 

The current best alternatives for orchard replant are 1,3-D or 1,3-D with chloropicrin, and/or 

metam-sodium, especially in light soils (e.g., Caprile and McKenry, 2006). These alternatives 

are used effectively under optimal soil and moisture conditions (high moisture at surface and less 

than 12% at depths to 1.5 meters) and methyl bromide is not critical. There is a critical need for 

methyl bromide in orchards in California where alternatives cannot be used, either because of 

legally mandated township caps for 1,3-D, local permit requirements for chloropicrin, buffer 

zone limitations, or surface moisture requirements cannot be met. If rain does not occur, growers 

without sprinkler systems have difficulty applying water for 1,3-D application. 
USA CUN11 SOIL Orchard Replant Open Field Page 5 of 20 

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 replacement of methyl bromide to treat soils with alternatives is taking place as research and 

extension work indicates is appropriate. The current nomination for methyl bromide is an 

amount that allows a reasonable transition to alternatives in the small portion of replant sites that 

cannot use alternative treatments. Field studies on the perennial crops of this sector require a 

multi-season timeframe. Until replicated trials can be analyzed methyl bromide is being 

nominated for a small portion of replant sites (see Browne et al., 2008; Beede et al., 2008; 

Upadhyaya et al., 2008; Wang et al., 2008). 

The best alternatives for orchard replant that have been identified in research plots are 1,3-D or 

1,3-D with chloropicrin (e.g., Browne et al., 2008; Beede et al., 2008). Under specific soil and 

moisture conditions (high moisture at surface and less than 12% at depths to 1.5 meters) 1,3-D 

can be an effective management tool for replant problems. However, there is a critical need for 

methyl bromide in some orchards in California, either because of legally mandated township 

caps for 1,3-D or chloropicrin, or because surface moisture requirements cannot be met due to 

heavy soils (e.g., soils can not be adequately dried prior to use of 1,3-D). In addition, a failure of 

an alternative to manage some pests, such as Armillaria root rot (UC Pest Management 

Guidelines, 2008), may require the critical use of methyl bromide. 

Regulations to meet air quality standards for ground level ozone may change fumigation 

practices. Pesticides that have been identified as volatile organic compounds (VOC) react with 

nitrous oxides (NOx) to form ozone. In California, the most at-risk period for fumigation has 

been identified as May 1 through October 31. 

Several areas in California, including the San Joaquin Valley and some areas of Ventura County, 

will be subject to new regulations. The San Joaquin Valley contains about two-thirds of the 

almond and stone fruit land, about one-half of the walnut land, and nearly all of raisin grape land. 

All sources of NOx and VOCs are being evaluated by the California Department of Pesticide 

Regulation (CDPR), which has the authority to regulate the use of soil fumigants. CDPR has 

issued a rule to reduce the emissions, including restrictions on timing and methods of fumigation. 

For example, for orchard replant, the only method of application allowed for methyl bromide or 

chloropicrin is HDPE-tarped, deep-shank, broadcast fumigation. Strip applications are not 

allowed in the May-October period. In the past, most orchard replant fumigations occurred 

during this period. Use of 1,3 D, however, may not be impacted as much as other soil 

treatments. 

6. SUMMARY OF RECENT RESEARCH 

Research in California continues to identify ways to optimize orchard replant to improve tree 

survival and orchard health. Recent research results for this sector were outlined in reports to the 

2008 Annual International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions (Browne et al., 2008; Upadhyaya et al., 2008; Wang et al., 2008; Beede et al., 2008) 
USA CUN11 SOIL Orchard Replant Open Field Page 6 of 20 

as well as the 2007 Research Conference (Browne et al., 2007; Kluepfel and Beede, 2007; 

McKenry et al., 2007; Coates et al., 2007; Wang et al., 2007). 

In general, due to new regulations in California to reduce volatile organic compound emissions, 

the timing of fumigation in some areas (e.g., San Joaquin Valley) may shift from October to 

November or December. This could result in application of 1,3-D in cooler soils and a reduced 

efficacy of this alternative. 

Stone Fruit and Almond: Research as part of the USDA Pacific Area-wide Pest Management 

Program for Integrated Alternatives to Methyl Bromide has been ongoing for stone fruit and 

almond (Browne et al., 2008). Objectives of research are 1) To develop and demonstrate 

optimized integrated pest management (IPM) strategies for control of almond and stone fruit 

replant problems without MB; 2) To provide comprehensive economic assessments of 

alternatives replant management strategies; 3) Educational outreach with a field demonstration 

day, May 2008. Stone fruit and almond replant trials continue since their establishment in 2006. 

Thus far, results indicate that chloropicrin, iodomethane/chloropicrin, and 1,3-D/chloropicrin 

“are effective MB alternatives” for control of Prunus replant disease (PRD). Results also 

indicate that GPS-directed shank or drip spot applications may be “nearly” as effective as strip or 

broadcast application (see also, Upadhyaya et al., 2008, for a description of experimental sitespecific fumigant applications using GPS). Therefore, drip application of 1,3-D and chloropicrin 

can reduce overall fumigant emissions. Nematodes have not been significant factors in replanted 

sites, although sites selected for trials in 2009 appear to be infested with ring nematode. Browne 

et al. (2008) stated that “future years’ growth and yield data are needed and will be accumulated 

for economic assessments of these treatments”. Iodomethane is not currently registered in 

California and 1,3-D and chloropicrin are highly regulated. 

Wine Grapes, Raisin and Table Grapes: Research is part of the USDA Pacific Area-wide Pest 

Management Program for Integrated Alternatives to Methyl Bromide (Wang et al., 2008) and a 

continuation of an ongoing 3-year project (see Wang et al., 2007). Fumigants included were 

various experimental rates of 1,3-D/chloropicrin with VIF or not tarped, a cover crop, and 

methyl bromide (448 kg/ha with HDPE film). Citrus nematodes in buried bags were killed in all 

fumigant-treated plots, but survived in non-fumigated plots. Only methyl bromide controlled 

Fusarium in the surface 15 cm of soil. No significant differences were found in Fusarium

populations between any of the other treatments. All fumigated plots successfully control 

Pythium—non-fumigated plots did not control Pythium. VIF film significantly reduced 

emissions in the shank and subsurface drip treatments. 

Walnuts: There appears to be an increasing shift to alternatives where they are not restricted by 

regulatory actions. According to the request from the California Walnut Commission, “walnut 

growers appear to be shifting to tree site or strip applications, a short-sighted change driven by 

economic pressure.” A reduction in the use of all fumigants is likely due to regulations to reduce 

volatile organic compound emissions. Restrictions on the use of fumigants may reduce the 

ability to use tree-site or strip fumigation (see Section 7 below). 
USA CUN11 SOIL Orchard Replant Open Field Page 7 of 20 

Results of research on walnut was recently reported (Beede et al., 2008) and is an ongoing 

attempt to: 1) identify cost-effective commercial fumigant alternatives to methyl bromide, 2) test 

new application technologies, and 3) initiate outreach to growers for walnut production, and 4) 

test clonal vs. seedling plant material. 

Research indicates that the continued use of the preferred rootstock Paradox is not advisable. 

Research continues to search for resistance to ring and lesion nematode pests. Various regimes 

(different rates and application methods) with 1,3-D, chloropicrin, and methyl bromide were 

evaluated. Conclusions thus far indicate that “a combination of 1,3-D and chloropicrin” are the 

best alternatives for the walnut industry. In addition, researchers concluded that fumigation 

alters the soil microbe community whereby pathogens appear to recolonize to higher population 

levels in previously fumigated soils as compared to non-fumigated soils. 

7. ECONOMIC INFEASIBILITY OF ALTERNATIVES 

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. 

The economic analysis of the orchard replant application compares data on yields, crop prices, 

revenues and costs using methyl bromide and using alternative pest control regimens in order to 

estimate the costs from the loss of methyl bromide availability. The alternatives identified as 

technically feasible - in cases of low pest infestation1

 – are different combinations of 

chloropicrin, metam sodium and 1,3-Dichloropropene (1,3-D). 

The critical use nomination (CUN) for this sector does not include areas where soil conditions 

are ideal and township caps do not restrict the use of 1,3-D. This CUN only applies to areas 

where township caps or certain soil types do not permit the use or effective use of 1,3-D. Where 

1,3-D is not permitted there are no effective nematicide alternatives to methyl bromide. Trees 

and vines that survive are not likely to be as healthy and could suffer yield losses. If a nematode 

infestation causes the death of trees and vines, then replacement trees would also suffer the same 

infestation unless there use of an effective nematicide, or possibly several years of fallow. 

Without methyl bromide growers replanting orchards or vineyards can face losses from several 

sources. These sources include: 

• Delayed planting 

• Fallow 

• Additional use of herbicides 

• Tree loss 

 

1

 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 CUN11 SOIL Orchard Replant Open Field Page 8 of 20 

• Replant costs to replace tree losses 

• Loss of trees replanted 

• Yield loss of fruit or nuts 

• Delayed achievement of full yield potential 

• Earlier loss of productivity of whole orchard 

A number of soil pathogens and nematodes, many still poorly understood, occur over the lifespan 

of an orchard. It is important that the grower be able to reduce the amount of inoculum in the 

soil to ensure that the young trees and vines have the opportunity to get off to a vigorous start to 

ensure survival. 1,3 D, chloropicrin, and metam-sodium have shown promise on some soil 

types, but long-term research on tree survival and on yield impacts is incomplete. If the 

alternatives do not work as effectively as methyl bromide, then it is possible that other losses 

could occur, such as additional replanting, higher yield losses, and shorter lifespan of the whole 

orchard or vineyard reducing the ability to amortize the initial investment costs. 

The benefits of fumigation with methyl bromide for orchard or vineyard replant can be measured 

by future yields (orchard crops require several years to begin bearing) when production may be 

adversely affected by poor tree growth and high pest populations. In addition, fumigant 

treatments result in healthier young plants. Other fumigants besides methyl bromide are used for 

fumigation, but in some cases, such as where there are heavy soils or township caps on 1,3-

Dichloropropene, these alternatives may not be available. 

The effects of orchard replant problem and nematode damage to young seedlings are experienced 

within the first three years of orchard and vine establishment, and are commonly observed within 

the first year. Costs associated with individual tree replacement include delayed production as 

newly replanted trees lag behind previously planted ones. In more severe cases, when replant 

disorder or high nematode populations are not properly managed at the time of orchard 

establishment, the entire orchard or vineyard might be lost. Because of the long life of these 

perennial crops, optimal soil preparation, along with appropriate rootstocks, is a priority for 

successful production. 

Typically, the alternatives to methyl bromide would be evaluated using a partial budget analysis 

to estimate the impacts of changes in production practices. That is, the consequences on a 

typical hectare of the crop grown are evaluated, rather than attempt to assess the impacts in the 

context of a whole enterprise, which could include multiple crops under cultivation. This 

approach allows the Agency to compare estimated losses to net operating revenue, which is 

defined as the difference between gross revenue and variable operating costs, on a per-hectare 

basis. The analysis ignores fixed costs, which are highly dependent on land ownership and the 

size and diversity of the grower’s operation, and therefore difficult to define on a per-hectare 

basis. As such, this analysis may understate the impacts as a percentage of the grower’s income. 

An analysis of a single year, however, does not capture the full benefit of fumigation. 

Establishing an orchard involves considerable costs, including the maintenance of the orchard 

during the non-bearing years. The returns to this investment occur in the future. Therefore, 

another approach to evaluating the benefits fumigation is to calculate the net present value of the 

orchard under different streams of costs and returns. Net present value (NPV) is a way of 
USA CUN11 SOIL Orchard Replant Open Field Page 9 of 20 

comparing different investments by summing the discounted costs and returns over time to 

calculate the value of the investment. The formula for NPV is: 

∑=

+

−

=

T

t

t

t t

r

NPV

0

1( )

Revenue Cost

where t is the time period (year), T is the last year the orchard is in production and r is the 

discount rate. This analysis uses a rate of 7% to represent a private discount rate or an 

individual’s trade-off of money between time periods

2

. Since revenues and costs are not adjusted 

for future inflation, all measures are in real terms. 

Since the choice of discount rate is somewhat arbitrary, BEAD also presents the internal rate of 

return (IRR), which is the discount rate that makes NPV = 0. One interpretation of this value is 

that it represents the maximum rate of return on an investment that an individual must be willing 

to accept before the investment would be considered. That is, if the IRR is 5%, only individuals 

willing to accept a rate of return less than 5% would find the investment worthwhile. 

California Walnuts and Almonds 

The current practice for walnut replant is to fumigate with methyl bromide and chloropicrin. An 

alternative is to use 1,3-D with chloropicrin, but 1,3-D does not penetrate heavier soils as well as 

methyl bromide and may not provide as effective control of nematodes and soil pathogens. 

Some growers may not be able to obtain permission to use 1,3-D under California township caps, 

but in this case that possibility is not considered. Comparing methyl bromide and 1,3-D, both 

with chloropicrin, for establishing an orchard will be the basis for evaluating the benefits of 

methyl bromide. 

Replacing methyl bromide with 1,3-D, is estimated to result in a 4% decrease in yields during 

production (Carpenter et al., 2000). Yield losses are due to soil pathogens that infect the trees at 

an early age, stunting their growth. Table 7 presents the expected differences in production and 

revenue for California walnut, where operating costs are taken from Buchner et al. (2002). 

Elements of harvest costs are assumed to be directly proportional to yield and we adjust costs 

accordingly. 

 

2

 The United States Office of Management and Budget suggests using a 3% and 7% rate when evaluating 

the cost and benefits of government regulation, where 7% is an estimate of the before-tax rate of return to 

private capital (OMB, 2003). 
USA CUN11 SOIL Orchard Replant Open Field Page 10 of 20 

Table 2. Gross revenue, operating costs, and net operating revenues, California walnuts 

orchard at full production. 

 methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

(% change) 1

Yield (kg/hectare) 1,505 1,445 

(-4.0%) 

Price ($/kg) 1.43 1.43 

Gross Revenue 

($/hectare) 

5,315 5,101 

(-4.0%) 

Operating Costs 

($/hectare) 

1,403 1,403 

Harvest Costs ($/hectare) 895 867 

(-2.8%) 

Net Operating Revenue 

($/hectare) 

3,018 2,660 

(-11.9%) 

Source: USDA NASS (2002-2006), Buchner et al. (2002), BEAD calculations. Figures may not sum due 

to rounding.

1

 Percent change in comparison to methyl bromide with chloropicrin. 

The analysis in Table E.1 indicates that even relatively minor changes in yield can have large 

effects on net operating revenue. A 4% change in yield results in a 12% change in net operating 

revenue. The analysis suggests that methyl bromide is worth about $150/hectare each year in 

terms of improved yield during the lifespan of the walnut orchard. If growers did not have access 

to methyl bromide or 1,3-D (because of township caps, for example), the consequences would be 

far more dire. 

The analysis in Table E.1 does not consider the investment producers must make in establishing 

an orchard and maintaining it through several non-bearing years. Table E.2 presents the 

information on the net operating revenues, NPV and IRR for a walnut orchard under the four 

treatment options. Field preparation costs are similar for any type of fumigation, but fumigation 

costs differ according to the mix of chemicals and the cost of application. Chemical costs are 

average per-hectare cost of products, which incorporates typical application rates. Tree planting 

costs are identical regardless of fumigant. BEAD assumes that some trees must be replanted the 

following year. We assume that 4%, or two trees, are replanted following fumigation with 

methyl bromide and chloropicrin (Buchner et al., 2002) but 6% are replanted with 1,3-D and 

chloropicrin. The higher replant rates represent the lower survival rate if nematodes are 

controlled but orchard replant disorder or pathogens are not. Trees begin to produce in the fourth 

year, initially at 10% of production, climbing to full production in the eighth year (Buchner et 

al., 2002). Returns during full production are shown in Table E.1. 
USA CUN11 SOIL Orchard Replant Open Field Page 11 of 20 

Table 3. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a walnut orchard. 

Year Stage Methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

Field Preparation -585 -585 

Fumigation 1 -3,127 -1,855 

1 

Establishment -3,789 -3,789 

2 Non-bearing 2 -978 -1,018 

3 Non-bearing -897 -897 

4 Initial production 3 -637 -657 

5 Partial production 5 -417 -457 

6 Partial production 6 -106 -165 

7 Partial production 6 1,331 1,213 

8 Full production 7 3,018 2,660 

9-25 Full production 7 3,018 2,660 

NPV (7% discount rate) 9,495 9,495 

IRR 13.8% 13.9% 

Source: Buchner et al. (2002), and BEAD calculations. Net operating revenues are not discounted; 

negative numbers represent costs greater than income. Net present value is calculated assuming 7% 

discount rate. 

1

 Fumigation costs include chemical costs and application costs. 

2

 In addition to operating costs, non-bearing costs include replanting trees. 

3

 Initial production is 10% of full production. 

4

 Production in the fifth year is 20% of full for combination treatments. 

5

 Production in the sixth year is 30% of full for combination treatments. 

6

 Production in the seventh year is 60% of full production for combination treatments. 

Assuming a 7% discount rate, establishing a walnut orchard, fumigating with methyl bromide 

and chloropicrin, yields future returns valued at almost $9,500/hectare today. This is about $530 

more per hectare than an hectare treated with 1,3-D and chloropicrin, although the lower initial 

cost of fumigating with 1,3-D and chloropicrin means that the internal rate of return on the two 

investments are approximately equal. The IRR for an orchards treated with methyl bromide or 

1,3-D are similar, and close to 14%. 

These results would also apply almonds grown on heavier soils. Where almonds are replanted 

after an existing almond orchard, poor vegetative growth has been observed and tree mortality 

has been estimated as high as 50% (Browne et al., 2006). This would be the case where no 

fumigant is used on replant sites. With a one year fallow, but no fumigant treatment, a 25-40% 

yield loss might be experienced (depending on rootstock) with a 24-35% reduction compared to 

methyl bromide treatment (Carpenter et al., 2000). 

BEAD estimates that nearly 43% of almond hectares planted and 86% of walnut plantings are 

currently treated with methyl bromide. The benefits of methyl bromide would eventually accrue 

to almost 97,000 bearing hectares of almonds and 74,000 hectares of walnut. At full production, 

additional yield is valued at about $370/hectare, therefore methyl bromide adds about $63.3 
USA CUN11 SOIL Orchard Replant Open Field Page 12 of 20 

million annually to the value of California nut production. Currently, metam sodium provides 

little benefit to producers on heavy soils. However, if chloropicrin and methyl bromide were not 

available, control of soil pathogens would depend on metam sodium. Without these fumigations, 

some orchards would probably not be established at all; thus these figures may understate the full 

value of the methyl bromide. 

California Stone Fruit 

Planting orchards with stone fruit trees requires a large investment of resources as well as 

numerous choices to establish a long-bearing and productive orchard. Many of the pests 

associated with these crops and fumigation requirements are similar from crop to crop and 

location to location. However, management of these pests differs depending on particular crop, 

soil type, climatic region, availability and cost of orchard land, availability of resistant rootstock

to specific key pests, and local regulatory restrictions of some fumigants. In general, when 

fumigation is deemed necessary, few choices are available to the orchard manager. 

We assess the benefits of fumigation with methyl bromide by comparing production under 

alternative approaches for controlling orchard replant disease. In this case, we focus on prune 

production in California that is broadly representative of stone fruit production with high 

fumigant use. This represents a heavy soil environment where methyl bromide and chloropicrin 

are used. We compare this use to fumigation with 1,3-D and chloropicrin, 1,3-D and metam 

sodium, and 1,3-D alone to evaluate the benefits of methyl bromide and chloropicrin. This result 

would also apply to cherry, peach and nectarine, and plum grown on heavier soils. We assume 

in this analysis that 1,3-D is available for use as a fumigant, which will not necessarily be the 

case, due to township caps in California. If neither methyl bromide or 1,3-D are available, the 

consequences are expected to be more dire. 

Replacing methyl bromide with 1,3-D, while maintaining the use of chloropicrin, is estimated to 

result in a 4% decrease in prune yields during production (Carpenter et al., 2000). Yield losses 

are due to soil pathogens that infect the trees at an early age, stunting their growth. Table E.3 

presents the expected differences in production and revenue for California prune, where 

operating costs are taken from Buchner et al. (2001). Harvest costs are assumed to be directly 

proportional to yield. Differences in net operating revenue for even small changes in yield can 

be substantial. This analysis suggests that the benefits of methyl bromide alone are 

approximately $125/hectare. 
USA CUN11 SOIL Orchard Replant Open Field Page 13 of 20 

Table 4. Gross revenue, operating costs, and net operating revenues, California prune 

orchard at full production. 

 Methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

(% change) 1

Yield (dried ton/hectare) 4.4 4.2 

(-4.0%) 

Price ($/ton) 1,125 1,125 

Gross Revenue 

($/hectare) 

5,002 4,802 

(-4.0%) 

Operating Costs 

($/hectare) 

2,080 2,080 

Harvest Costs ($/hectare) 1,894 1,818 

(-4.0%)

Net Operating Revenue 

($/hectare) 

1,028 904 

(-12.1%) 

Source: USDA NASS (2002-2006), Bruchner et al. (2001), BEAD calculations. Figures may not sum 

due to rounding.

1

 Percent change in comparison to methyl bromide with chloropicrin. 

The analysis in Table E.3 does not consider the investment producers must make in establishing 

an orchard and maintaining it through several non-bearing years. Table E.4 presents the 

information on net operating revenue, NPV, and IRR for a prune orchard under the four 

treatment options. Field preparation costs are similar for any type of fumigation, but fumigation 

costs differ according to the mix of chemicals and the cost of application. Chemical costs are 

average per-hectare cost of products, which incorporates typical application rates. Trees are 

planted the following spring and costs are identical regardless of fumigant. BEAD assumes that 

some trees must be replanted the following year. We assume that 2% are replanted following 

fumigation with methyl bromide an chloropicrin (Bruchner et al., 2001); 3% are replanted with 

1,3-D and chloropicrin; The higher replant rate represents the lower survival rate if nematodes 

are controlled but soil pathogens are not and amount to two or four trees. Trees begin to produce 

in the fourth year, initially at 20% of production, climbing to full production in the seventh year 

(Bruchner et al., 2001). Returns during full production are shown in Table E.3. 
USA CUN11 SOIL Orchard Replant Open Field Page 14 of 20 

Table 5. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a prune orchard. 

Year Stage Methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

0 Field Preparation -618 -618 

Fumigation 1 -2,519 -2,025 

1 Establishment -3,137 -3,137 

2 Non-bearing 2 -995 -1,018 

3 Non-bearing -1,294 -1,294 

4 Initial production 3 -1,336 -1,361 

5 Partial production 5 -1,023 -1,072 

6 Partial production 2 -82 

7 Full production 1,028 904 

8-40 Full production 1,028 904 

NPV (7% discount rate) -874 -1,529 

IRR 6.3% 5.7% 

Source: Buchner et al. (2001), and BEAD calculations. Net operating revenues are not discounted; 

negative numbers represent costs greater than income. Net present value is calculated assuming 7% 

discount rate. 

1

 Fumigation costs include chemical costs and application costs. 

2

 In addition to operating costs, non-bearing costs include replanting trees. 

3

 Initial production is 20% of full production. On-set of production is delayed one year if 1,3-D is used 

alone. 

4

 Production in the fifth year is 40% of full for combination treatments. 

5

 Production in the sixth year is 67% of full for combination treatments. 

Assuming a 7% rate of interest, prune production does not appear to be a good investment using 

any of the fumigation options. It may be that the information we have on production costs are 

somewhat high. Relatively speaking, however, methyl bromide provides substantial benefits 

over 1,3-D. Failure to adequately control soil pathogens substantially reduces the return to 

investing in a prune orchard. This result would also apply to cherry, peach and nectarine, and 

plum grown on heavier soils. 

California Grape 

It appears that the current practice for vineyard replant is to fumigate with 1,3-D and 

chloropicrin. Methyl bromide, with chloropicrin, is used on a few vineyards. Methyl bromide 

penetrates heavier soils, i.e., higher clay content or lower porosity soils, better than 1,3-D, but 

vineyards tend to be planted on coarser soils. However, some growers may not be able to obtain 

permission to use 1,3-D under California township caps, which would severely limit their 

options. Table E.5 presents the expected differences in production and revenue for California 

table grape where 1,3-D cannot be used. According to McKenry (1999), yield losses of up to 

20% could occur on some highly problematic sites if no fumigation is conducted. Using metam 
USA CUN11 SOIL Orchard Replant Open Field Page 15 of 20 

sodium alone would result in higher yields than without any fumigation, but would probably not 

be as effective as 1,3-D alone since metam sodium is the least efficient at dispersing through soil. 

For situation where 1,3-D is a workable alternative, such as those areas without heavy soils or 

restrictions from township caps, we assume that yields of a producing vineyard are the same with 

1,3-D and methyl bromide. In heavy soils, or without 1,3-D as an alternative, we assume that 

growers replanting orchards will instead use metam sodium, or no fumigation. Table E.5 

presents the expected differences in production and revenue for California table grapes with 

these fumigation treatments. Baseline yield for table grape and price for the fresh market are 

averages of 2001-2005, reported by USDA NASS (2002-2006). Operating costs are taken from 

Vasquez et al. (2004). Harvest costs are assumed to be directly proportional to yield and BEAD 

adjusts costs accordingly. 

As shown in Table E.5, methyl bromide shows no benefit over 1,3-D once a vineyard is in 

production. In places where 1,3-D cannot be used, the loss of methyl bromide would be 

extremely costly. Fumigating with methyl bromide and chloropicrin is worth $270 per hectare 

relative to metam sodium, and almost $400 per hectare more than no fumigation. 

Methyl bromide with chloropicrin is used on a few vineyards. Methyl bromide penetrates 

heavier soils, i.e., higher clay content or lower porosity soils, better than 1,3-D, but vineyards 

tend to be planted on coarser soils. However, some growers may not be able to obtain 

permission to use 1,3-D under California township caps, which would severely limit their 

options. Table E.5 presents the expected differences in production and revenue for California 

table grape where 1,3-D cannot be used. According to McKenry (1999), yield losses of up to 

20% could occur on some highly problematic sites if no fumigation is conducted. Using metam 

sodium alone would result in higher yields than without any fumigation, but would not be as 

effective as 1,3-D or methyl bromide. 
USA CUN11 SOIL Orchard Replant Open Field Page 16 of 20 

Table 6. Gross revenue, operating costs, and net operating revenues, California table 

grape vineyard at full production. 

 Methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

Metam 

Sodium 

(% change) 1

No 

fumigation 

(% change) 1

Yield (ton/hectare) 22 22 20 

(-10%) 

19 

(-15%) 

Price ($/ton) 720 720 720 720 

Gross Revenue 

($/hectare) 15,828 15,828 14,244 

(-10%) 

13,454 

(-15.0%) 

Operating Costs 

($/hectare) 5,362 5,362 5,362 5,362 

Harvest Costs 

($/hectare) 9,137 9,137 8,223 

(-10%) 

7,776 

(-15.0%) 

Net Operating 

Revenue ($/hectare) 1,329 1,329 659 

(-50.3%) 

326 

(-75.5%) 

Source: USDA NASS (2002-2006), Vasquez et al. (2004), BEAD calculations. Figures may not sum due 

to rounding.

1

 Percent change in comparison to methyl bromide with chloropicrin.

In situations where 1,3-D is not available or feasible, growers obtain substantial benefits from 

fumigation with methyl bromide and chloropicrin. The increased value of production throughout 

the life of the orchard is worth about $670/hectare annually compared to metam sodium and 

about $990/hectare annually compared to no fumigation. 

The analysis in Tables E.5 does not consider the investment producers must make in establishing 

an orchard and maintaining it through several non-bearing years. Table E.6 presents the 

information on net revenue through time, the NPV and the IRR for a table grape vineyard, 

assuming that 1,3-D is available. Field preparation costs are similar for any type of fumigation, 

but fumigation costs differ according to the mix of chemicals and the cost of application. 

Chemical costs are average per-hectare cost of products, which incorporates typical application 

rates. Vine planting costs are identical regardless of fumigant. In the second year, a trellis is 

installed, which represents the majority of costs. BEAD assumes that some vines must be 

replanted the second year. We assume that 2% or nine vines are replanted following fumigation 

with 1,3-D and chloropicrin (Vasquez et al., 2002); 6% are replanted with metam sodium; and 

8% are replanted if there is no fumigation. The higher replant rates represent the lower survival 

rate of vines if nematodes are controlled but soil pathogens are not. Vines begin to produce in 

the third year, initially at 80% of production, but are not of sufficient quality for the fresh market. 

Grapes are harvested mechanically and sold for wine (Vasquez et al., 2004). 
USA CUN11 SOIL Orchard Replant Open Field Page 17 of 20 

Table 7. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a California table grape vineyard. 

Year Stage Methyl Bromide 

+ chloropicrin 

1,3-D + 

chloropicrin 

Field Preparation -741 -741 

Fumigation 1 -3,127 -1,198 

1 

Establishment -4,036 -4,036 

2 Non-bearing 2 -9,164 -9,164 

3 Initial production 3 62 62 

4 Full production 1,329 1,329 

5-25 Full production 4 1,329 1,329 

NPV (7% discount rate) -3,359 -1,554 

IRR 4.5% 5.7% 

Source: Vasquez et al. (2004), and BEAD calculations. Net operating revenues are not discounted; 

negative numbers represent costs greater than income. Net present value is calculated assuming 7% 

discount rate. 

1

 Fumigation costs include chemical costs, according to EPA proprietary data, and application costs. 

1,3-D and chloropicrin are applied as a single product, but 1,3-D and metam sodium must be applied 

separately. 

2

 In addition to operating costs, non-bearing costs include replanting vines. The major expense is 

construction of a trellis system. 

3

 Initial production is 80% of full production (Vasquez, et al., 2004). Initial production is 

mechanically harvested and sold for wine. 

4

 Production ceases one year earlier with 1,3-D alone.

Table grapes do not appear to make a particularly attractive investment. Using a 7% discount 

rate, the NPV is negative. The IRR for a vineyard established with a fumigation of 1,3-D and 

chloropicrin is about 5.7%. The difference in NPV’s between fumigant treatments, however, is 

substantial. Estimates of NPV and IRR for metam sodium alone and no fumigation are not 

provided, because losses are so great that they are negative for all discount rates, which is 

equivalent to a negative IRR. 

About 200 hectares of grapes are fumigated with methyl bromide and chloropicrin in California 

each year on average. This represents about 3.3% of the planted hectares. The benefits of 

fumigation therefore accrue to about 10,800 bearing hectares. Assuming that this represents 

growers who cannot use 1,3-D because of township caps, and that the benefits of methyl bromide 

and chloropicrin are about $670/hectare to wine grapes as well as table grapes, methyl bromide 

and chloropicrin contribute about $7.2 million annually to the California economy. This does 

not include the possibility that fumigating with methyl bromide and/or chloropicrin make an 

investment in grape production viable for some growers. 
USA CUN11 SOIL Orchard Replant Open Field Page 18 of 20 

TABLE 8. NOMINATION AMOUNT: 2011 Methyl Bromide Usage Newer Numerical 

 Index (BUNNI) – Transition Use Reduction Description Spreadsheet.

 CA G&TFL - 

Stone Fruit 

 CA G&TFL - 

Raisin Grape 

 CA Walnut 

Commission 

 Almond Hullers 

& Processors 

 CA Wine Grapes 

Replant 

 Sector Total / 

Average 

Quantity Requested for 2010: Amount (kgs) 9,255 153,333 22,255 18,887 22,290 226,020 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 7,400 150,400 21,800 18,600 17,600 215,800 

Amount (kgs) 7,400 150,400 21,800 18,600 17,600 215,800 

Area (ha) 37 752 109 93 88 1,079 

Rate 200 200 200 200 200 200 

Transition from 2010 

Baseline Adjusted Value Percentage (%) -12% -8% 0% -7% -8% -10%

Amount (kgs) 8,544 134,695 22,200 17,575 20,577 203,591 

Area (ha) 673 43 111 88 103 1018

Rate 199 200 200 200 200 200 

SECTOR

ORCHARD REPLANT

Quantity Approved by Parties 

for 2010:

Quantity Required for 

2011 Nomination:
USA CUN11 SOIL Orchard Replant Open Field Page 19 of 20 

CITATIONS 

Beede, R. H., Kluepfel, D. A., McKenry, M, Yakabe, L. Garcia, T. 2008. Examination of preplant 

methyl bromide alternatives in a walnut tree replant site. Annual International Research 

Conference on Methyl Bromide Alternatives (2008). 

Browne, G., Lampinen, B., Holtz, B., Doll, D., Edstrom, J., Schmidt, L., Upadhyaya, S., Shafii, M., 

Hanson, B., Wang, D., Gao, S., Goodell, N., and Klonsky, K. 2008. Integrated pre-plant 

alternatives to methyl bromide for almonds and other stone fruits. Annual International 

Research Conference on Methyl Bromide Alternatives (2008). 

Browne, G., Lampinen, B., Holtz, B., Upadhyaya, S., Wang, D., Gao, S. Doll, D., Schmidt, L., 

Hanson, B., Goodell, N., McKenry, M., and Klonsky, K. 2007. Integrated pre-plant alternatives 

to methyl bromide for almonds and other stone fruits. 

http://www.mbao.org/2007/Proceedings/008BrowneGmbao2007.pdf

Browne, G. T., Connell, J. H., Schneider, S. M. 2006. Almond replant disease and its management 

with alternative pre-plant soil fumigation treatments and rootstocks. Plant Disease 90:869-876. 

Caprile, J. and McKenry, M. 2006. Orchard replant considerations. University of California 

Extension, Contra Costa County Crop Currents, Fall 2006, attached in University of 

California Extension Tree Topics Oct. 30, 2006, vol 31, issue 8.

http://cecontracosta.ucdavis.edu/newsletterfiles/Crop_Currents10064.pdf

Coates, R., Shafii, M., Upadhyaya, S. K., and Browne, G. 2007. Tree planting site-specific fumigant 

application to control almond replant disease. Annual International Research Conference on 

Methyl Bromide Alternatives (2007). 

http://www.mbao.org/2007/Proceedings/009UpadhyayaSMBATreePlantingSite.pdf 

Kluepfel, D. and Beede, B. 2007. Methyl bromide alternatives for use in walnut production systems. 

Annual International Research Conference on Methyl Bromide Alternatives (2007). 

http://www.mbao.org/2007/Proceedings/010KluepfelMethylbromidealterantives.pdf 

McKenry, M., Buzo, T., and Kaku, S. 2007. Replanting vineyards without soil fumigation. . Annual 

International Research Conference on Methyl Bromide Alternatives (2007). 

http://www.mbao.org/2007/Proceedings/050McKenryMReplantVineyardswoutsoifumigMBAO2007.pdf 

McKenry, M., Buzo, T., and Kaku, S. 2006. Replanting stone fruit orchards without soil fumigation. 

Annual International Research Conference on Methyl Bromide Alternatives. 

http://www.mbao.org/2006/06Proceedings/028McKenrySummary2006.pdf. 

NASS-USDA. 2006. Noncitrus Fruits and Nuts, Summary. National Agricultural Statistics Service, 

U.S. Department of Agriculture. 

http://usda.mannlib.cornell.edu/usda/nass/NoncFruiNu//2000s/2006/NoncFruiNu-07-06-

2006_final.pdf
USA CUN11 SOIL Orchard Replant Open Field Page 20 of 20 

UC (University of California) Pest Management Guidelines. 2008. Armillaria root rot (oak root 

fungus)—Grapes. http://www.ipm.ucdavis.edu/PMG/r302100811.html

Upadhyaya, S. K., Browne, G. T., Lampinen, B. D., Shafii, M., and Udompetaikul, V. 2008. Tree 

planting site-specific fumigant application to control almond replant disease. Annual 

International Research Conference on Methyl Bromide Alternatives (2008). 

Wang, D., Gao, S., Gerik, J., Hanson, B., Tharayil, N., Qin, R., Browne, G., Smith, C., Klonsky, K., 

Westerdahl, B., Vasquez, S., and Yates, S. 2008. Methyl bromide alternatives for vineyard 

replant. Annual International Research Conference on Methyl Bromide Alternatives (2008). 

Wang, D., Gao, S., Gerik, J., Hanson, B., Smith, C., Klonsky, K., Westerdahl, B., Vasquez, S., 

Browne, G., and Yates, S. 2007. Methyl bromide alternatives for vineyard replant—assessment 

of control efficacy, fumigant movement, and crop response. Annual International Research 

Conference on Methyl Bromide Alternatives (2007). 

http://www.mbao.org/2007/Proceedings/011WangDMBAO2007areawide.pdf