USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 1 of 17 

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 SOIL FOREST SEEDLING NURSERIES Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Forest Seedling Nurseries in 

Open Fields (Submitted in 2009 for 2011 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Forest Seedling Nurseries Open Field

QUANTITY OF METHYL BROMIDE REQUESTED: 

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

Year NOMINATION AMOUNT

2011 106,043 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).) 

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 Forest Seedling Nurseries Open Field Page 2 of 17 

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 FOREST SEEDLING NURSERIES Open Field 17 

 

 

 

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 FOREST SEEDLING NURSERIES Open Field 

 

 

 

* Identical to paper documents 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 3 of 17 

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

FOREST SEEDLING NURSERIES 

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

Forests are increasingly important as challenges to the environment have global implications. 

The first step in forest establishment is the production of tree seedlings by forest tree nurseries. 

These nurseries provide healthy starting material for newly planted forests. The U.S. nomination 

is for those nurseries where registered alternatives are not effective or sufficiently tested to 

enable commercial use. This comprises much of forest seedling nursery production land. The 

use of methyl bromide is considered critical where alternatives are not suitable because of 

regulatory, economic, or technical constraints. 

Of the registered alternatives, iodomethane may offer forest seedling nurseries (except in 

Washington where it is not registered) the most immediate hope as a replacement of methyl 

bromide. The main concern regarding adopting this newly registered product is the lack of 

testing that has been done for this sector. Uncertain use rates, formulation type, application 

techniques, certification questions, and only now, the beginning of technology to allow gluing 

high barrier films has impeded a wholesale move to iodomethane for the short-term. The U.S. 

believes a transition period is necessary to resolve these issues. 

Inconsistency in overall pest management performance by some alternatives (e.g. metam-sodium 

and dazomet) has been the primary concern for this sector, and the reason that methyl bromide 

continues to have some critical use. While direct yield losses, in terms of seedlings/hectare, may 

not be large on average, intensive seedling production relies on the ability of nursery managers to 

meet quality and yield goals as well as certification that plants are essentially pest-free. 

Effective fumigation can manage fungal pathogens (e.g., Fusarium, Alternaria, Phytophthora, 

Pythium, Rhizoctonia, Cylindrocladium spp., Cylindrocarpon, and Macrophomina), nematodes 

(e.g., Circonemoides, Helicotylenchus), and yellow and purple nutsedges (species of Cyperus). 

Nutsedge species are generally considered among the major pests of forest seedling nurseries in 

the eastern U.S. and the pests most difficult to manage. 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

For the 2011 use season, methyl bromide remains a critical need for forest seedling nurseries to 

produce plants free of pests in order to meet state certification standards, as well as customer 

expectations. The use protocols for the effective alternatives have not been developed 

sufficiently to provide effective control of the key pests to depths of 1 m. In addition, there are 

few, if any, markets for plants that do not meet the certification standards, which mean that 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 4 of 17 

losses up to 100% are possible when inadequate pest control occurs. Failure to adequately 

manage pests in transplants will jeopardize the viability of the planted forests. 

A new registration for iodomethane presents an additional alternative (it is currently registered in 

all states except California, New York, and Washington). Before iodomethane replaces methyl 

bromide for forest seedling production it will have to be accepted as an appropriate treatment for 

pest-free certification. Iodomethane use rates and formulations (98:2 or 50:50) are being tested 

by seedling nurseries to determine what rates are the most effective and cost-feasible. 

Chloropicrin appears to be a possible alternative, but strict regulations make its future uncertain 

when used at the high rates that have been shown to be effective (South, 2007; Enebak, 2007). 

According to nursery specialists from requesting consortia (Enebak, 2008; Lowerts, 2008; 

Talbert, 2008; Overton, 2008), iodomethane holds promise as an effective alternative to methyl 

bromide. However, the following comments highlight concerns by nursery experts of potential 

problems with a transition to iodomethane for the forest seedling nursery industry: 

• Research has been scant for testing the efficacy of iodomethane in forest seedling 

nurseries. One two-year study conducted in the southeast U.S. (Starkey et al., 2007) 

indicated that the size of pine seedlings with iodomethane were similar to that with 

methyl bromide for both years. Weed populations were significantly greater in one of 

the two years of the study. There is a need to validate the studies to determine if 

iodomethane manages weed populations sufficiently for commercial production. 

• The limited number of field studies that have been conducted is not sufficient to 

confirm that iodomethane is a suitable alternative to methyl bromide; the industry 

cannot afford to risk production until the new product is rigorously tested. One 

consortium stated that “most researchers consider 3 years of trials over several 

locations are needed to develop reliable data for pesticide guidelines.” Trials for this 

sector have not been completed or reported. Trials conducted in the northeast are 

limited to a few vegetable crops with custom applicators from outside the region. 

• Research trials with iodomethane conducted in Washington (where iodomethane is 

not currently registered for commercial use) have found encouraging results. 

• Cost estimates for the southeast for application and tarp removal of 350 lb/acre [392 

kg/ha] of 98:2 methyl bromide was approximately $4,450 per hectare. The cost of 

175 lb/acre [196 kg/ha] of 98:2 iodomethane was approximately $6,280 per hectare. 

Cost in the northeast for iodomethane products range from $15 per kg (50:50) to $20 

per kg (98:2). This compares to $7 per kg for methyl bromide (98:2). Estimated 

costs of fumigation per hectare for northeastern nurseries average $8,300 for 

iodomethane (98:2), $10,500 for iodomethane (50:50), and $4,820 for methyl 

bromide (98:2). If these cost differences are maintained the industry would find 

iodomethane to be economically infeasible. 

• Regional fumigation contractors do not currently have the equipment to broadcast 

iodomethane. According to the iodomethane label, “The treated ground must be 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 5 of 17 

sealed using closing shoes, roller, compaction roller, cultipacker or other equivalent 

equipment that will sufficiently cover chisel marks left after soil injection. The 

equipment shall cover the chisel marks with soil immediately prior to the placement 

of the tarpaulin being laid down (with fumigant injection) by tarpaulin-laying 

equipment mounted on the application tractor.” Demand for the product may change 

this situation, but the industry is not able currently to broadcast iodomethane. 

• Use of iodomethane resulted in a reduction of beneficial Trichoderma fungi 

populations in soil 12 and 18 months following treatment in both years of a two-year 

study (Starkey et al., 2007). This effect will have to be confirmed by additional 

studies, but would result in long-term reduced production quality. 

• Methyl bromide is accepted by state control boards as meeting phytosanitary 

requirements for nursery shipments. Iodomethane will require the same acceptance, 

but as yet, this certification standard has not been addressed by the registrant of 

iodomethane or state regulators. 

• According to the consortium representing northeast nurseries, Arysta (manufacturer 

of MIDAS iodomethane) has no representatives or dealers of the iodomethane 

product in northeastern states. 

• The iodomethane label (MIDAS) does not make clear if use is allowed for production 

of deciduous tree seedlings (“strawberries, stone fruits, tree nuts, and conifer trees”). 

Deciduous seedlings are generally more valuable than conifer seedlings and have 

greater pest management requirements. 

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

STANDARD?

This sector is covered by certification requirements. All states have certification standards and 

all nurseries have additional internal quality control standards as well (NPB, 2008 for summaries 

of nursery plant regulations for all states). USDA-APHIS has guidelines for containment of 

sudden oak death through movement of nursery material (USDA-APHIS, 2004). An example 

from Mississippi, “All nursery stock shipped into Mississippi must carry on each container or 

bundle a valid nursery inspection tag (inspection certificate) of the State of origin. Containers 

should also be plainly marked with the names and addresses of shipper and consignee” (MDAC, 

2003). Similarly from Alabama, “Nursery stock entering the State of Alabama must be certified 

as being apparently free from plant pests. Certificate tags issued by the official certifying agency 

of the state of origin stating such must be firmly attached to each box, bundle or package of 

nursery stock moved into the state” (ADAI, 2004). In addition, “No inspection certificate shall 

be issued for the sale, offering for sale, or movement of any nursery stock until the stock in 

question shall have been inspected by the Commissioner and found to be apparently free from 

seriously injurious plant pests” (ADAI, 2004). Other states have similar regulations (NPB, 

2008). 
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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. 

All nurseries currently treat production beds with methyl bromide due to certification and 

production requirements. Where weeds are of primary pests, methyl bromide has been the most 

effective treatment and accepted by state inspectors. Methyl bromide allows conifer seedling 

beds to be fumigated after two or three crops (as opposed to after every crop) because of the 

effectiveness of methyl bromide, which usually makes a second-year treatment unnecessary. 

Iodomethane is a new fumigant and may be an effective alternative, but multi-season information 

on its use for forest nurseries is lacking. 

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? 

Preliminary results of research suggest iodomethane has value as a replacement for methyl 

bromide, but it first must be tested to prove efficacy and acceptability for certification. In 

addition, as with all new products, adjustment of use rates and application experience with 

iodomethane will require a few seasons where nurseries can transition from methyl bromide, 

assuming costs do not limit the use of iodomethane.

6. SUMMARY OF RECENT RESEARCH 

The amount of methyl bromide nominated for 2011 has been reduced from the previous 

nomination. This is due to a reduction in rates or a change in the proportion of methyl bromide 

in the formulation by some nurseries. Impacts for nurseries that have a critical need for methyl 

bromide would be significant without the fumigant for 2011. Research is ongoing to develop 

commercially feasible protocols for likely alternatives, such as iodomethane, 1,3-D and 

chloropicrin, chloropicrin, and/or metam-sodium. 

Research with low permeability films and methods to glue them for broadcast fumigation 

appears to be progressing towards resolving technical problems. The feasibility for commercial 

broadcast with high barrier films is still questionable. The standard width of film used in the 

nursery industry (400 cm) is not available for the film that currently can be glued, which may 

slow adoption, according to a representative of Pliant Corporation, a major manufacturer of high 

barrier films in the U.S. Research trials with VIF have primarily been conducted with bed, rather 

than the standard broadcast fumigation due to problems gluing film. Glues are apparently 

proprietary and manufacturing information is difficult to attain. Ajwa (2008) reported some 

preliminary successes in strawberry research trials gluing VIF and totally impermeable film 

(TIF). He cited reports that researchers in Florida had had difficulty gluing TIF. 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 7 of 17 

In 2008, iodomethane was registered in all states requesting a critical use of methyl bromide, 

except Washington, for use in forest seedling nurseries. Unfortunately, research on iodomethane 

use for this industry is minimal and rates, formulation, and application techniques will have to be 

optimized for commercial applications. The registrant, Arysta, has not yet completed work to 

support pest-free certification with the product. Fumigant trials have been conducted with 

conifers, not hardwoods, which constitute a valuable portion of many nurseries. 

• In a two-year study conducted in Georgia, Starkey et al. (2007) found that 

iodomethane:chloropicrin (168 kg/ha of 98:2) produced seedlings with characteristics 

(density, diameter, height, root and shoot biomass) comparable to methyl bromide-treated 

beds. Methyl bromide and chloropicrin (168 kg/ha of 98:2) with VIF produced seedlings 

comparable to methyl bromide:chloropicrin (336 kg/ha of 98:2) with standard films. 

Weeds in iodomethane-treated beds were comparable to methyl bromide in a 2006 trial 

and more than in methyl-bromide-treated beds in a 2005 trial. This was attributed to the 

rate of iodomethane that was used. The regeneration of the beneficial fungus 

Trichoderma was reduced under VIF and with iodomethane treatments compared to 

methyl bromide. 

• Quicke et al. (2008) studied two nursery sites in South Carolina. Randomized blocks 

were treated with one of seven fumigants (98:2 methyl bromide at both 450 kg/ha and 

264 kg/ha; 70:30 methyl bromide at 450 kg/ha; Pic+ at 336 kg/ha; chloropicrin at 336 

kg/ha; Chlor60 at 450 kg/ha; DMDS/Pic at ~820 kg/ha). At both sites, all treatments 

provided comparable seedling densities. No nematodes were detected in any fumigated 

soil. Trichoderma populations were greatest in soil that had been treated with a high rate 

of chloropicrin. 

• Results from experiment-sized plots conducted in Mt. Vernon Research Center, 

Washington (Talbert, 2008) in 2007 in cooperation with USDA, found that iodomethane 

treatments generally provided acceptable weed and pathogen control. Concerns were 

raised about the effectiveness of spring fumigation with iodomethane and consistency 

throughout different locations. Additional testing is planned for western nurseries and 

two to three seasons is considered necessary to gauge efficacy and feasibility. 

• Research (Weiland et al., 2008) to study the efficacy of reduced doses of fumigants 

(methyl bromide, iodomethane, and DMDS) under VIF and their effects on soil 

pathogens and weeds is underway in Oregon and Washington. Trials will be analyzed in 

the fall of 2009. 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

Please note that in this study net revenue is calculated as gross revenue minus operating costs. 

This is a good measure as to the direct losses of income that may be suffered by the users. It 

should be noted that net revenue does not represent net income to the users. Net income, which 

indicates profitability of an operation for an enterprise, is gross revenue minus the sum of 
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operating and fixed costs. Net income is smaller than the net revenue measured in this study, 

often substantially so. We did not include fixed costs because they are difficult to measure and 

verify. 

The economic analysis of the tomato application compared data on yields, crop prices, revenues 

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

the loss of methyl bromide availability. The alternatives identified as technically feasible - in 

cases of low pest infestation1 – for different regions by the U.S. are: (a) Iodomethane and (b) 1,3-

Dichloropropene and Chloropicrin followed by Metam sodium (otherwise referred to as the 

Georgia 3-Way). 

The economic factors that really drives the feasibility analysis for nursery stock production uses 

of methyl bromide are: (1) yield losses, referring to reductions in the quantity produced, (2) 

increased production costs, which may be due to the higher-cost of using an alternative, 

additional pest control requirements, and/or resulting shifts in other production or harvesting 

practices (3) quality losses, which generally affect the quantity and price received for the goods, 

and (4) missed market windows due to plant back time restrictions, which also affect the quantity 

and price received for the goods. 

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 

 

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 Forest Seedling Nurseries Open Field Page 9 of 17 

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 tomato 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. 

The economic analysis of the forest seedling application compared data on costs using methyl 

bromide and using the next best alternative pest control regimen, iodomethane, in order to 

estimate the loss of methyl bromide availability. 

The economic reviewers then analyzed crop budgets for forest seedlings 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 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 forest seedling 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. 
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The results of the analysis of methyl bromide compared to iodomethane are shown in Tables 2 - 

6 below. Iodomethane, is assumed to provide the same yields as methyl bromide. Therefore, the 

only losses shown in the tables below as a result of methyl bromide not being available are 

increased fumigation and hand weeding costs. Since one study (Starkey et al., 2007) indicated 

increased weed pressure with iodomethane compared to methyl bromide, almost $800 per 

hectare per year was added for hand weeding costs with the use of iodomethane. 

Please note, that the yields, revenues, and costs in Tables 2-6 below are averages per year over 

fumigation cycles of 2 – 4 years. Most of the yields, revenues, and costs occur 1 – 2 years out of 

2 – 4 fumigation cycles, while fumigations are usually done once during the fumigation cycle 

and sometimes twice for certain species. Since the costs are average annual costs, the increased 

costs will be less than the full increased cost of a single iodomethane fumigation compared to 

methyl bromide. 

Also, revenues and costs will vary between regions due to different yields, species, and cultural 

and fumigation practices. 

Furthermore, these tables do not show other possible losses discussed earlier in this nomination 

and summarized below, which include: 

• Efficacy. While the analysis of economic feasibility assumed equal yields, the limited 

number of field studies that have been conducted is not sufficient to confirm that 

iodomethane has equal efficacy as methyl bromide. If efficacy is not equal there could be 

impacts on seedling quality and forest health. 

• Forest Health. Seedlings free of pathogens and other pests help establish forests with 

less pest pressure, thus resulting in faster growth and less use of pesticides. 

• Certification. Methyl bromide is accepted by state control boards as meeting 

phytosanitary requirements for nursery shipments. Iodomethane will require the same 

acceptance, but as yet, with limited efficacy studies, this certification standard has not 

been established. There are few, if any, markets for plants that do not meet the 

certification standards, which mean that losses up to 100% are possible when inadequate 

pest control occurs. 

• Equipment. Regional fumigation contractors and nurseries do not currently have the 

equipment to broadcast iodomethane. Demand for the product may change this situation, 

but the industry is not able currently to broadcast iodomethane. 

• Deciduous trees. The iodomethane label (MIDAS) does not make clear if use is allowed 

for production of deciduous tree seedlings, which are generally more valuable than 

conifer seedlings and have greater pest management requirements. 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 11 of 17 

TABLE 2 SOUTHERN FOREST NURSERY MANAGEMENT COOPERATIVE:

ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES PER YEAR

SOUTHERN FOREST NURSERY MANAGEMENT COOPERATIVE

METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0%

 Yield (seedling) per Hectare Pine 779,617 779,617 

* Price per Unit (U.S. $/seedling) $0.05 $0.05 

Gross Revenue per Proportion (88% of seedlings; 72% of acres) $25,234 $25,234 

 Yield (seedling) per Hectare Longleaf Pine 423,785 423,785 

* Price per Unit (U.S. $/seedling) $0.09 $0.09 

Gross Revenue per Proportion (3% of seedlings; 5% of acres) $1,759 $1,759 

 Yield (seedling) per Hectare Hardwood 243,399 243,399 

* Price per Unit (U.S. $/seedling) $0.25 $0.25 

Gross Revenue per Proportion (9% of seedlings; 24% of acres) $14,337 $14,337 

= GROSS REVENUE PER HECTARE (US$) $41,330 $41,330 

− OPERATING COSTS PER HECTARE (US$)** $23,401 $24,648 

= NET REVENUE PER HECTARE (US$) $17,929 $16,682 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,248 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $15 

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 7% 

5. OPERATING PROFIT MARGIN (%) 43% 40% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 12 of 17 

TABLE 3. ARBORGEN: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES PER YEAR

ARBORGEN METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0%

 YIELD (SEEDLINGS) PER HECTARE 741,315 741,315 

* PRICE PER UNIT (US$) $0 $0.05 

= GROSS REVENUE PER HECTARE (US$) $33,997 $33,997 

− OPERATING COSTS PER HECTARE (US$)** $20,946 $22,250 

= NET REVENUE PER HECTARE (US$) $13,051 $11,747 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,304 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $20 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 4% 

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 10% 

5. OPERATING PROFIT MARGIN (%) 38% 35% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 

TABLE 4. WEYERHAEUSER: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES PER YEAR

WEYERHAEUSER METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0%

 YIELD (SEEDLINGS) PER HECTARE 55,006 55,006 

* PRICE PER UNIT (US$) $0 $0 

= GROSS REVENUE PER HECTARE (US$) $17,932 $17,932 

− OPERATING COSTS PER HECTARE (US$)** $12,131 $13,155 

= NET REVENUE PER HECTARE (US$) $5,801 $4,777 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,024 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $22 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 6% 

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

5. OPERATING PROFIT MARGIN (%) 32% 27% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 13 of 17 

TABLE 5. NORTHEASTERN FOREST AND CONSERVATION: ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES PER YEAR 

NORTHEASTERN FOREST AND CONSERVATION

METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0%

 Yield (seedling) per Hectare Conifer (1-0) 247,105 247,105 

* Price per Unit (U.S. $/seedling) $0.26 $0.26 

Gross Revenue per Proportion (8% of acres) $5,140 $5,140 

 Yield (seedling) per Hectare Conifer (2-0) 185,329 185,329 

* Price per Unit (U.S. $/seedling) $0.26 $0.26 

Gross Revenue per Proportion (4% of acres) $1,927 $1,927 

 Yield (seedling) per Hectare Conifer (3-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.35 $0.35 

Gross Revenue per Proportion (14% of acres) $6,054 $6,054 

 Yield (seedling) per Hectare Deciduous Trees (1-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.32 $0.32 

Gross Revenue per Proportion (55% of acres) $21,745 $21,745 

 Yield (seedling) per Hectare Deciduous Trees (2-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.37 $0.37 

Gross Revenue per Proportion (9% of acres) $4,114 $4,114 

 Yield (seedling) per Hectare Deciduous Shrubs (1-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.29 $0.29 

Gross Revenue per Proportion (10% of acres) $3,583 $3,583 

= GROSS REVENUE PER HECTARE (US$) $42,564 $42,564 

− OPERATING COSTS PER HECTARE (US$)** $31,879 $33,418 

= NET REVENUE PER HECTARE (US$) $10,684 $9,146 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,538 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $16 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 4% 

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 14% 

5. OPERATING PROFIT MARGIN (%) 25% 21% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 14 of 17 

TABLE 6. MICHIGAN SEEDLING ASSOCIATION: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES PER 

YEAR 

MICHIGAN SEEDLING ASSOCIATION

METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0%

 Yield (seedling) per Hectare Conifer Seedlings 963,710 963,710 

* Price per Unit (U.S. $/seedling) $0.14 $0.14 

Gross Revenue per Proportion (60 % of acres) $80,952 $80,952 

 Yield (seedling) per Hectare Conifer Transplants 74,132 74,132 

* Price per Unit (U.S. $/transplant) $0.60 $0.60 

Gross Revenue per Proportion (10% of acres) $4,448 $4,448 

 Yield (seedling) per Hectare Deciduous Seedlings 296,526 296,526 

* Price per Unit (U.S. $/seedling) $0.50 $0.50 

Gross Revenue per Proportion (30% of acres) $44,479 $44,479 

= GROSS REVENUE PER HECTARE (US$) $129,878 $129,878 

− OPERATING COSTS PER HECTARE (US$)** $90,235 $91,898 

= NET REVENUE PER HECTARE (US$) $39,644 $37,980 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,663 

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

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

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

5. OPERATING PROFIT MARGIN (%) 31% 29% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 15 of 17 

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

TABLE 7. NOMINATION AMOUNT

 Southern Forest 

Nursery 

 International 

Paper 

 Weyer- haeuser 

(SE) 

 Weyer- haeuser 

(NW) 

 NE Forest & 

Conserv. 

Nursery 

 Michigan 

Seedling Assoc. 

 Sector Total / 

Average 

Quantity Requested for 2010: Amount (kgs) 5,050 66,340 13,889 15,302 13,971 6,301 120,853 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 4,940 66,300 13,780 15,190 12,096 5,520 117,826 

Amount (kgs) 4,940 66,300 13,780 15,190 12,096 5,520 117,826 

Area (ha) 19 255 53 72 47 21 467 

Rate 260 260 260 211 257 263 252 

Transition from 2010 

Baseline Adjusted Value

Percentage 

(%) -10% -12% -11% -11% -22% -21% -12%

Amount (kgs) 4,446 59,670 12,402 13,671 10,886 4,968 106,043 

Area (ha) 230 17 48 65 42 19 421

Rate 262 259 258 210 259 261 252 

2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) 

Transition Use Reduction Description Spreadsheet

Quantity Required for 

2011 Nomination:

Quantity Approved by Parties 

for 2010:

SECTOR

FOREST SEEDLINGS
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 16 of 17 

CITATIONS 

ADAI (Alabama Department of Agriculture and Industries). 2004. Chapter 80-10-1, Nursery 

and Nursery Stock. Plant Industry Administrative Code. 

http://www.msapms.org/new/newsletters/Nursery%20and%20Nursery%20Stock%20Regula

tions_New.pdf

Ajwa, H. 2008. Personal communication, original email to S. Weiss, SRRD-OPP, EPA, 

November 20, 2008. 

Enebak, S. 2008. Personal communication, email to L. Yourman, October 28, 2008. 

Enebak, S. 2007. Personal communication, email to L. Yourman, Aug. 16, 2007. 

Enebak, S., Starkey, T., and McCraw, D. 2006. Tree seedling quality and weed control with 

Basimid, MBR and methyl iodide. Annual International Research Conference on Methyl 

Bromide Alternatives. 

http://www.mbao.org/2006/06Proceedings/040StarkeyTMBAOMIMBrBasamidTES.pdf 

Lowerts, G. 2008. Personal communication (ArborGen), email to L. Yourman, October 29, 

2008. 

MDAC (Mississippi Department of Agriculture and Commerce). 2003. Summary of plant 

protection regulations.Bureau of Plant Industry, Plant Pest Division. 

http://nationalplantboard.org/docs/mississippi.doc. Moulton, R. J. and Hernandez, G. 2000. Tree 

planting in the United States, 1998. Tree Planters Notes V49(2). USDA Forest Service. pp 

1-36. 

NPB (National Plant Board). 2008. Laws and Regulations. 

http://www.nationalplantboard.org/laws/index.html 

Overton, R. 2008. Personal communication (Purdue University, NE Area Regeneration 

Specialist, email to L. Yourman, October 31, 2008. 

Quicke, M., Starkey, T., and Enebak, S. 2008. 2008 Area-wide demonstration of alternatives: 

Forest nurseries in the southern U.S. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2008). 

South, D. B. 2007. Chloropicrin as a soil fumigation treatment in southern pine nurseries. 

Southern Journal of Applied Forestry 31(1):47-51. 

Starkey, T., Enebak, S., and McCraw, D. 2007. Seedling quality and weed control with dazomet, 

methyl bromide and methyl iodide at the Glennville Regeneration Center 2005-2006. 

Research Report 06-05, Southern Forest Nursery Management Cooperative, Auburn, AL. 

also, http://www.mbao.org/2006/06Proceedings/040StarkeyTMBAOMIMBrBasamidTES.pdf; 

http://mbao.org/2006/06PowerPoints/MBAO%20PDFs/Preplant/7%20-

%20Ornamentals,%20Tree%20Crop%20and%20Forest%20tree%20Nurseries/Starkey.pdf
USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 17 of 17 

Talbert, C. B. 2008. Personal communication with Director of Forestry and Regeneration , 

Weyerhaeuser Corporation, Western Timberlands. October 31, 2008. 

USDA-APHIS (Animal and Plant Health Inspection Service), Plant Protection and Quarantine. 

2004. Sudden Oak Death. Amended order restricting movement of nursery stock from 

California nurseries.. http://www.aphis.usda.gov/ppq/ispm/pramorum/pdf_files/sodorder4-22-04signed.pdf

Weiland, J., Pinkerton, J. N., Littke, W., Browning, J., Masters, C., Rose, R., Haase, D., Miller, 

T., Edmonds, B. and Leon A. 2008. Methyl bromide alternatives in Oregon and 

Washington forest tree nurseries. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2008).