**USA CUN11 SOIL Eggplant Grown in Open Fields**  **Page 1 of 15** NOMINATING PARTY: **The United States of America**

FILE NAME: **USA CUN 11 SOIL** EGGPLANT **GROWN IN OPEN FIELDS**

BRIEF DESCRIPTIVE TITLE OF NOMINATION: **Methyl Bromide Critical Use Nomination for Pre-plant Soil Use for Eggplants Gro**  **wn in Open Fields (Submitted in 2009 for 2011 Use Season)** 

CROP NAME (OPEN FIELD OR PROTECTED): **Pre-plant Soil Use for Eggplant Grown in Open Fields** 

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR O F

NOMINATION:

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

Y EAR N OMINATION A MOUNT

2011 21,561 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 we bsite under Decision Ex. I/4(8).)

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 Eggplant Grown in Open Fields**  **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 EGG PLANT GROWN IN OPEN FIELDS 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 Eggplant Open Field**

*** Identical to paper documents USA CUN11 SOIL Eggplant**  **Grown in Open Fields Page 3 of 15**  

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

EGGPLANT

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

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

Georgia

**Continued efforts are underway in Georgia to implem ent effective and economical alternatives to**  **methyl bromide. Three-way fumigation system develo ped by University of Georgia and**  **Dimethyl disulfide (DMDS) are the two alternatives appeared as potential replacements for**  **methyl bromide During the spring of 2008, at least 40% of the land fumigated for vegetable**  **crops in the spring was treated with the 3-WAY whic h includes a systems approach of 1,3-**  **dichloropropene, chloropicrin, and metam sodium. It is likely that 30 to 40% of Georgia’s total**  **crop will be treated with this alternative during 2 008. Dimethyl disulfide (DMDS) plus**  **chloropicrin also proven to be effective in managin g many pests and has the potential to be**  **adopted once the price structure is known.**

**Although both the 3-WAY and DMDS appear promising, neither fumigant system will stand**  **alone in managing pests. An effective herbicide pr ogram must be developed to compliment**  **these fumigant systems. The 3-WAY does not provide adequate nutsedge control with**  **summer/fall fumigations and the DMDS system does no t adequately control grasses or** 

Amaranthus **species. Until a program using fumigants and herb icides is developed, having**  **methyl bromide available is essential.**

**The two aforementioned fumigant systems also pose s ignificant challenges when determining the**  **time interval needed between fumigating and plantin g. Initial research results suggest the plant** 

**back interval for the 3-WAY will be at least 3 time s longer than that noted with methyl bromide.**  **Early indications suggest that the plant back inter val for DMDS plus chloropicrin applied under a**  **high barrier mulch will be similar to the 3-WAY fum igation system.** 

**The latest research information indicates that 3-wa y system continues to perform well in the**  **spring, but perform poorly on nutsedge control in t he fall. Applications of mixture of DMDS**  **chloropicrin (79:21), 45 to 50 gallons/acre in spr ing and 50 to 60 gallons/acre in fall seems**  **effective in controlling the nutsedge. Future resea rch will focus on developing and implementing**  **a herbicide program to compliment both the 3-WAY an d DMDS fumigant systems as well as**  **determining the amount of time that must pass betwe en fumigating with these alternatives and**  **planting. USA CUN11 SOIL Eggplant**  **Grown in Open Fields Page 4 of 15**  Florida

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

**Until 1999, the chemical formulation primarily used was 98 percent methyl bromide and two**  **percent chloropicrin. Since then, growers have shif ted to formulations with lower concentrations**  **of methyl bromide and higher amounts of chloropicri n due to the phase-out schedule of methyl**  **bromide. At present, the standard formulation cont ains 50% methyl bromide in Florida.**  **The best alternative, 1,3-D (Telone), may not be ap plied in Florida in the areas overlying karst**  **geology, which is common throughout the Southeaster n States. There is also a 21-day planting**  **delay (vs. 14 days for MB) due to regulatory restri ctions for 1,3-D + chloropicrin.** 

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

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

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

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE**USA CUN11 SOIL Eggplant Grown in Open Fields**  **Page 5 of 15 Although both the 3-WAY and DMDS (Dimethyl disulfid**  **e (DMDS) plus chloropicrin) appear promising, neither fumigant system will stand alone**  **in managing pests. An effective herbicide program must be developed to compliment these fumig**  **ant systems. Current review of available research indicate that the 3-WAY does not provide a**  **dequate nutsedge control with summer/fall fumigations and the DMDS system does not adequately**  **control grasses or** Amaranthus **species. The most recent studies have reported that a 79:21**  **mixture of DMDS and chloropicrin is**

**effective than the other mixtures of these 2 chemic als (Culpepper et al., 2008). In the Southern**  **U.S., mainly in Florida and Georgia, where nutsedge is a main methyl bromide target pest, 1,3-D**  **or metam sodium, alone or in combination, may not a dequately control this weed. In karst**  **topographical feature areas, which include 31 count ies in Florida, Telone is highly restricted and**  **metam sodium or metam potassium is the best alterna tives available. However, further testing of**  **these chemicals in large scale commercial fields is needed. In Florida and Georgia, farmers**  **using 1,3-D and metam sodium in the fall would requ ire longer waiting periods for planting.**  **Metam sodium or 1,3-D requires waiting periods of 28 and 21 days, respectively, whereas only**  **14 days are needed for methyl bromide. Such delays could result in missed market windows.**  **Metam sodium efficacy appears to decline where it i s applied repeatedly due to enhanced**  **degradation of its active ingredient, methyl isothi ocyanate, by soil microorganisms (Ashley, et**  **al., 1963; Ou et al., 1995; Verhagen et al., 1996; Gamlied et al., 2003).** 

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

3 IS THE USE COVERED BY A CERTIFICATION STANDARD?

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

4 IF PART OF THE CROP AREA IS TREATED WITH METHYL BRO MIDE,

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 METH YL

BROMIDE.

**Three-way fumigation system developed by University of Georgia and Dimethyl disulfide**  **(DMDS) are the two alternatives appeared as potenti al replacements for methyl bromide During**  **the spring of 2008, at least 40% of the land fumiga ted for vegetable crops in the spring was**  **treated with the 3-WAY which includes a systems app roach of 1,3-dichloropropene,**  **chloropicrin, and metam sodium. It is likely that 30 to 40% of Georgia’s total crop will be**  **treated with this alternative during 2008. Dimethy l disulfide (DMDS) plus chloropicrin also**  **proven to be effective in managing many pests and h as the potential to be adopted once the price**  **structure is known. Although both the 3-WAY and DMD S appear promising, neither fumigant**  **system will stand alone in managing pests. An effe ctive herbicide program must be developed to**  **compliment these fumigant systems. The 3-WAY does not provide adequate nutsedge control**  **with summer/fall fumigations and the DMDS system do es not adequately control grasses or** **USA CUN11 SOIL Eggplant Grown in Open Fields**  **Page 6 of 15** Amaranthus **species. Until a program using fumigants and herb icides is developed, having**  **methyl bromide available is essential.**

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

5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE

THIS?

**As described under item number 5, development of a suitable fumigant herbicide program is**  **essential for expansion of methods to other areas.**

6. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERN ATIVES COMPARED TO methyl bromide FOR THE SPECIFIC KEY TAR GET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED

A: KEY PATHOGENS: Phytophthora capsici

, Pythium spp. and nematodes ( Meloidogyne spp.)

Summary of studies relevant to key pathogens

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

**In studies with other vegetable crops, fumigation w ith 1, 3 D + chloropicrin has generally**  **provided better control of fungi than metam-sodium , though still not as good as control with**  **methyl bromide. For example, in a study using a be ll pepper - squash rotation in small plots,**  **Webster et al. (2001) found significantly lower fun gal populations with 1,3 D + 35 %** **USA CUN11 SOIL Eggplant Grown in Open Fields**  **Page 7 of 15 chloropicrin (drip applied, 146 kg/ha of 1,3 D), as**  **compared to the untreated control. However, methyl bromide (440 kg/ha, shank-injected) reduced**  **fungal populations even more.** P. capsici **was not present in test plots, though** Fusarium **spp. were. However, as compared to the methyl bromide standard treatment plots, squash fruit weig**  **ht was 63 % lower in the 1,3 D plots. The proportion of marketable squash fruit in the 1,3 D**  **plots was 30 % lower than that in the methyl bromide plots. In another study, conducted on tomat**  **oes, Gilreath et al. (1994) found that metam sodium treatments did not match methyl bromide in t**  **erms of plant vigor at the end of the season.**

Fusarium **(but not** P. capsici **) was one of several pests present.**

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

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

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

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

**The use of 1,3-D and metam sodium in the fall is im practical because of the long waiting periods**  **for planting following application under plastic mu lch. For 1,3-D there is a 28 day waiting**  **period; for metam sodium, there is a 21-day waiting period. Such delays would cost growers at**  **least half of the harvest season, thereby missing t he higher market windows. Thus, since the fall**  **crop is dependent upon timely planting, the require d waiting period would cost growers at least**  **half of the harvest season, thereby missing the hig her market windows (Kelley, 2003).** **USA CUN11 SOIL Eggplant Grown in Open Fields**  **Page 8 of 15** B: KEY WEEDs: Nutsedges

T ABLE 2: DATA ON TRIALS OF F UMIGANT A LTERNATIVES TO M ETHYL B ROMIDE FOR P OLYETHYLENE -M ULCHED

T OMATO (L OCASCIO ET AL

. 1997)

Chemicals Rate (kg/ha) Average

Nutsedge Density (#/m 2 ) Average

Marketable Yield (ton/ha) % Yield Loss

(compared to methyl bromide)

Untreated (control) **- 300 ab**  **20.1 a**  **59.1**

methyl bromide + Pic (67-33), chisel-injected **390 kg 90 c**  **49.1 b** 

**---**

1,3 D + Pic (83-17), chisel-injected **327 l 340 a**  **34.6 c**  **29.5**

Metam Na, Flat Fumigation **300 l 320 a**  **22.6 a**  **54.0**

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

Narrative description of studies relevant to target weeds

**For nutsedge, which is widespread in all requesting regions, growers do not have technically**  **feasible alternatives to methyl bromide use at plan ting. Metam-sodium and 1,3 D + chloropicrin**  **have shown some efficacy in small-plot trials in ot her vegetable crops (e.g, tomato). However,**  **metam sodium use may result in a 44% yield loss, wh ile use of 1,3 D may result in a 29% loss.**  **These fumigants often provide less control of nutse dges than methyl bromide. Furthermore,**  **there is evidence that both 1,3 D and methyl isothi ocynate levels decline more rapidly due to**  **enhanced degradation of these chemicals by soil mic roorganisms, thus further compromising**  **efficacy, in areas where these are repeatedly appli ed (Smelt et al., 1989; Ou et al., 1995; Gamliel**  **et al., 2003; Dungan and Yates, 2003).**

**Results from small plot studies conducted in Tifton , Georgia, by Culpepper and Langston (2004)**  **show that 1,3-D followed by chloropicrin was signif icantly less effective than methyl bromide**  **against both purple and yellow nutsedge, although t his treatment performed as well as methyl**  **bromide relative to spring and fall crop yield. 1, 3-D + chloropicrin, followed by more**  **chloropicrin was more effective than methyl bromide against yellow nutsedge, but less effective**  **against purple nutsedge. This treatment performed as well as methyl bromide in terms of spring**  **yield, but poorly in terms of fall yield. 1,3-D + chloropicrin, followed by metam sodium was**  **36% less effective than methyl bromide for purple n utsedge control, but as effective as methyl**  **bromide against yellow nutsedge. However, test plo ts were small, and it is unclear if these**  **results will hold in commercial fields, considering the variable results reported elsewhere for**  **these alternatives. The nutsedge populations in th is study were dominated by yellow nutsedge**  **(90% of the total). It is not clear if populations where purple nutsedge is dominant would be**  **controlled as effectively, since other studies have shown that purple nutsedge is a hardier species.** 

**Current review of available research indicate that the 3-WAY does not provide adequate**  **nutsedge control with summer/fall fumigations and t he DMDS system does not adequately**  **control grasses or** Amaranthus **species. The most recent studies have reported tha t a 79:21**  **mixture of DMDS and chloropicrin is effective than the other mixtures of these 2 chemicals**  **(Culpepper et al., 2008). Future research will foc us on developing and implementing a herbicide**  **program to compliment both the 3-WAY and DMDS fumig ant systems as well as determining**  **the amount of time that must pass between fumigatin g with these alternatives and planting.** **USA CUN11 SOIL Eggplant Grown in Open Fields**  **Page 9 of 15 In Florida, the best currently available alternativ**  **e for eggplant production (which cannot be used in areas containing karst topographical features) i**  **s an application of Telone C-35 (1,3-D + 35% chloropicrin), at 35 gallons per acre, 3-5 weeks be**  **fore transplanting, followed by an application of a herbicide mix of napropamide and trifluralin t**  **o the top of the raised bed at the time of tarp laying (Noling and Botts, 2007).** 

**A soil treatment recently developed by the Universi ty of Georgia appears to be promising as a**  **methyl bromide replacement for Georgia’s eggplant s pring crop, although not for the summer or**  **fall crops. This treatment, known as the “UGA 3-WA Y”, consists of three successive soil**  **fumigations, beginning with 1,3-D + chloropicrin ap plication, followed by a chloropicrin**  **application, followed by a metam-sodium or metam-po tassium application (Culpepper, 2007a).**  **In 2006, Culpepper** et al **. (2007a) tested the effectiveness of fall applicat ions of methyl bromide**  **alternatives, including the UGA 3 WAY treatment, on nutsedges infesting the spring bell pepper**  **crop in TyTy, Georgia. Results of this small-plot study show that the UGA 3-WAY alternative**  **(see above) performed as well as the standard methy l bromide application. Similarly, reducing**  **the standard rates of methyl bromide by 50%, from 3 92 kg/ha under standard LDPE film to 196**  **kg/ha under metalized film, also provided excellent purple nutsedge control. Pepper yields were**  **comparable in all treated plots.**

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

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

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

**The following economic analysis is organized by met hyl bromide critical use application**  **regions.**

**Readers please note that in this study net revenue is calculated as gross revenue minus operating**  **costs. This is a good measure as to the direct los ses of income that may be suffered by the users.**  **It should be noted that net revenue does not repres ent net income to the users. Net income, which**  **indicates profitability of an operation of an enter prise, is gross revenue minus the sum of**  **operating and fixed costs. Net income should be sm aller than the net revenue measured in this**  **study. We did not include fixed costs because it i s often difficult to measure and verify.** **USA CUN11 SOIL Eggplant Grown in Open Fields Page 10 of 15**  Summary of Economic Feasibility

**The economic analysis of eggplant applications comp ared data on the yields, crop prices,**  **revenues and costs of using methyl bromide or alter native pest control regimens. This was done**  **in order to estimate impacts on eggplant growers wi th the decreasing availability of methyl**  **bromide. The Georgia 3-Way (1,3-Dichloropicrin wit h Chloropicrin followed by metam sodium**  **) was identified as being a technically feasible al ternative (in cases of low pest infestation**  **1 ) to**  **methyl bromide in Georgia and Florida eggplant prod uction. 1,3-D + chloropicrin is also being**  **recognized as an alternative to methyl bromide; how ever, it is not considered technically feasible**  **as yield losses are expected.**

**The economic reviewers analyzed crop budgets for pr e-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 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 eggp lant 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 me t if there is a significant impact on commodity** 

**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 Eggplant Grown in Open Fields Page 11 of 15**  **suppliers using methyl bromide. The economic measu res provide the basis for making that** 

**determination.**

Georgia and Florida

**In Georgia and Florida, using the Georgia 3-Way on spring plantings is believed to be a**  **technically (and thus economically) feasible altern ative to methyl bromide, although some**  **limitations exist. Referring to Table 4 and 5, the loss of gross revenue using the Georgia 3-Way**  **is negligible for Florida in comparison to methyl b romide, while gains in gross revenue are**  **expected in Georgia. Unlike spring plantings, howev er, yield losses are expected in fall**  **plantings, with studies in Georgia’s application sh ow a 50% yield loss. The Georgia 3-Way also**  **cannot be used on eggplants that are grown in karst soils since it contains 1,3-D. Therefore, for**  **fall plantings and areas with karst soils, the use of methyl bromide is critical to Georgia’s and**  **Florida’s eggplant production. Note that data descr ibing Georgia eggplant production is based on**  **double cropping production practices.**

**Florida Analytical Notes:**

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

T ABLE 3: G EORGIA

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA EGGPLANT METHYL

BROMIDE GEORGIA 3-

WAY: SPRING

APPLICATION GEORGIA 3-

WAY: FALL

APPLICATION

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

PRODUCTION PER HECTARE **7,070 7,070 3,535**
* PRICE PER UNIT (US$) **$8 $8 $8**

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

- OPERATING COST PER HECTARE (US$) **$45,271 $34,610 $34,610**
= NET REVENUE PER HECTARE (US$) **$12,277 $22,938 -$5,836**

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

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

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) **0% -87% 148%**
5. OPERATING PROFIT MARGIN (%) **21% 40% -20% USA CUN11 SOIL Eggplant**  **Grown in Open Fields Page 12 of 15 Note: Georgia eggplant revenue and cost measures we**  **re calculated using data from a two crop per growin g season**  **production system.**

• **Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” shoul**  **d be interpreted as a “gain”. Positive numbers can be i**  **nterpreted as losses.**

T ABLE 4: F LORIDA

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA EGGPLANT METHYL

BROMIDE GEORGIA 3-

WAY: SPRING

APPLICATION 1,3-D +

CHLOROPICRIN

PRODUCTION LOSS (%) **0% 0% 29%**

PRODUCTION PER HECTARE **1,764 1,764 1,252**
* PRICE PER UNIT (US$) **$11 $11 $11**
= GROSS REVENUE PER HECTARE (US$) **$19,983 $19,983 $14,188**
- OPERATING COST PER HECTARE (US$) **$17,891 $17,976 $17,303**
= NET REVENUE PER HECTARE (US$) **$2,092 $2,007 -$3,116**

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

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

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) **0% 4% 249%**
5. OPERATING PROFIT MARGIN (%) **10% 10% -22%** *** Interpret the loss measures with caution. 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 w hich is reflected in the nomination amount** 

**and detailed in Table 5.**

TABLE 5. N OMINATION A MOUNT : **2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) – Transition Use Reduction**  **Description Spreadsheet**

.

Florida Eggplant Georgia Eggplant Sector Total /
Average

Quantity Requested for 2010: Amount (kgs) 18,843 13,147

31,990

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 18,843 11,235

30,078

Amount (kgs) 18,843

11,235

30,078

Area (ha) 114

68

182

Rate 165

165

165

Transition from 2010 Baseline Adjusted Value Percentage (%) -47% -50% -48%

Amount (kgs) 

### 12,813

8,748

21,561

Area (ha) 78 53 131

Rate 164 165

165 SECTOR EGGPLANT

Quantity Approved by Parties

for 2010:

Quantity Required for

2011 Nomination:**USA CUN11 SOIL Eggplant Grown in Open Fields Page 13 of 15**  

### CITATIONS

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

**Banks, H. J. 2002. 2002 Report of the Methyl Brom ide Technical Options Committee, 2002** 

**Assessment. Pg 46.** 

**Chellemi, D.O., R. C. Hochmuth, T. Winsberg, W. Gue tler, K. D. Shuler, L. E. Datnoff, D. T.**  **Kaplan, R. McSorley, R. A. Dunn, and S. M. Olson. 1 997. Application of soil solarization**  **to fall production of cucurbits and pepper. Proc. F la. State Hort. Soc. 10:333- 336.** 

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

**Cortright, B.D. and M.K. Hausbeck. 2004. Evaluation of fumigants for managing Phytophthora** 

**crown and fruit rot of solanaceous and cucurbit cro ps, plot two, 2003. Unpublished study**  **(MI CUE # 03-0061).**

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

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

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

**Culpepper, A.S., A.L. Davis, T.M. Webster, A.W. Mac Rae, and D.L. Langston. 2007a. Bell**  **pepper and nutsedge response to fall applied methy l bromide alternative fumigants in**  **Georgia. UGA Weed Science. At: www.gaweed.com** 

**Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. Mayfied, T. Webster, and W.**  **Upchurch. 2007b. Can Georgia growers replace meth yl bromide? MBAO Conference,**  **San Diego, Caifornia, 2007. http://mbao.org/2007/PDF/Preplant/PP4/Culpepper(20)**  **.pdf**

**Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. Mayfied, T. Webster, and W.**  **Upchurch. 2008. DMDS or the 3-Way: Which is more e ffective in Georgia. Orlando,**  **Florida, 2008. http://mbao.org/2008/007Culpepper.pdf** **USA CUN11 SOIL Eggplant Grown in Open Fields Page 14 of 15**  **Duncan, R. S. and S. R. Yates. 2003. Degradation of fumigant pesticides: 1,3-Dichloropropene,**  **Methyl isothiocyanate, chloropicrin, and methyl bro mide. Vadose Zone Journal 2:279-286.** 

**Florida Fruit and Vegetable Association (FFVA). 20 02. Application for the Methyl Bromide**  **Critical Use Exemption on Solanaceous Crops (other than tomato). September 9, 2002.** 

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

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

**Gilreath, J. P. B. M. Santos, T. N. Motis, J. W. No lling, and J. M. Mirusso. 2005. Methyl** 

**Bromide alternatives for nematode and** Cyperus **control in bell pepper (** Capsicum annum **). Crop Protection 24:903-908.** 

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

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

**Lewis, C. 2003 (President, Hy-Yield Bromine). Pers onal communication through S.A. Toth**  **( steve_toth@ncsu.edu**  **) , Extension Entomologist & Pest Management Inform ation**  **Specialist, North Carolina State University; messag e forwarded electronically to G.**  **Tomimatsu, December 29, 2003.**

**Melban, K. 2003. California Pepper Commission. Pers onal Communication with G. Tomimatsu.**  **Kenny@tabcomp.com . 11/26/2003.** 

**Noling, J. W. 2003. University of Florida-Lake Alfr ed. Personal Communication with G.** 

**Tomimatsu. Jwn@lal.ufl.edu**  **. 11/25/2003.**

**Noling, J.W., E. Rosskopf, and D.L. Chellemi. 2000. Impacts of alternative fumigants on soil**  **pest control and tomato yield. Proc. Annual Int. Re s. Conf. on Methyl Bromide Alternatives** 

**and Emissions Reductions. Available on the web at** http://www.mbao.org/mbrpro00.html

**.**

**Noling, J.W. and D.A. Botts. 2007. Alternatives t o methyl bromide soil fumigation for Florida**  **vegetable production. University of Florida IFAS Publication. At:**  **http://edis.ifas.ufl.edu/CV290 and:**  **http://edis.ifas.ufl.edu/pdffiles/CV/CV29000.pdf**

**Stall, W.M. and J. Morales-Payan. 2000. The critica l period of nutsedge interference in tomato.** 

**S.W. Florida Research & Education Center. www.imok.ufl.edu/liv/groups/IPM/weed_con/nutsedge.h**  **tm USA CUN11 SOIL Eggplant**  **Grown in Open Fields Page 15 of 15 USDA. 2002. Crop Profiles: Florida Eggplant.**  **http://pestdata.ncsu.edu/cropprofiles/docs/FLeggpla nt_.html** 

**U.S. EPA. 2002. Peppers-Field. Peppers Grown Outdoo rs on Plastic Mulch. CUN2003/058** 

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