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 Grown 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 OF 

NOMINATION: 

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

YEAR NOMINATION AMOUNT 

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 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 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 convention 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 ENVIRONMENT) 

EGGPLANT 

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

This nomination covers eggplant grown for fresh market in the States of Florida and Georgia. 

The crop is generally grown in open fields and followed by various other crops. Harvest is 

mainly for fresh market. 

Georgia 

Continued efforts are underway in Georgia to implement effective and economical alternatives to 

methyl bromide. Three-way fumigation system developed 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 which 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 2008. Dimethyl disulfide (DMDS) plus 

chloropicrin also proven to be effective in managing 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 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 does not adequately control grasses or 

Amaranthus species. Until a program using fumigants and herbicides is developed, having 

methyl bromide available is essential. 

The two aforementioned fumigant systems also pose significant challenges when determining the 

time interval needed between fumigating and planting. Initial research results suggest the plant 

back interval for the 3-WAY will be at least 3 times longer than that noted with methyl bromide. 

Early indications suggest that the plant back interval for DMDS plus chloropicrin applied under a 

high barrier mulch will be similar to the 3-WAY fumigation system. 

The latest research information indicates that 3-way system continues to perform well in the 

spring, but perform poorly on nutsedge control in the fall. Applications of mixture of DMDS 

chloropicrin (79:21), 45 to 50 gallons/acre in spring and 50 to 60 gallons/acre in fall seems 

effective in controlling the nutsedge. Future research will focus on developing and implementing 

a herbicide program to compliment both the 3-WAY and DMDS fumigant systems as well as 

determining the amount of time that must pass between 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 diseases like phytopthora blight, and southern 

blights are continued to be major problems in eggplant production in Florida. In this State, 

eggplant is grown year-round, and often double cropped 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 after 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 soils 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 weeks. Cold temperatures below 5oC injure 

this crop. The best temperatures are 27-32oC during the day and 21-32oC during the night. Plant 

growth is curtailed at temperatures below 16oC. Additionally, soil temperature below 16oC 

restricts germination. However, most of the eggplant 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 shifted to formulations with lower concentrations 

of methyl bromide and higher amounts of chloropicrin due to the phase-out schedule of methyl 

bromide. At present, the standard formulation contains 50% methyl bromide in Florida. 

The best alternative, 1,3-D (Telone), may not be applied in Florida in the areas overlying karst 

geology, which is common throughout the Southeastern States. There is also a 21-day planting 

delay (vs. 14 days for MB) due to regulatory restrictions for 1,3-D + chloropicrin. 

Currently, the best alternatives to use of methyl bromide in Florida seems to be applying Telone 

C-35 (1,3-Dichloropropene + 35% Chloropicrin), applied 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 lbs 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 substitute for eggplant at this time. The U.S. 

nomination is only for those areas in Georgia and Florida where the alternatives are not feasible. 

If methyl bromide were to be unavailable for U.S. eggplant, growers in the regions cited in this 

nomination would have to discontinue growing this crop or suffer substantial losses. Growers 

would either leave agriculture entirely or switch to other crops that do not rely on pre-plant 

fumigation to control soil pests. The extent of this 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 
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Although both the 3-WAY and DMDS (Dimethyl disulfide (DMDS) plus chloropicrin) appear 

promising, neither fumigant system will stand alone in managing pests. An effective herbicide 

program must be developed to compliment these fumigant systems. Current review of available 

research indicate that the 3-WAY does not provide adequate 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 chemicals (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 adequately control this weed. In karst 

topographical feature areas, which include 31 counties in Florida, Telone is highly restricted and 

metam sodium or metam potassium is the best alternatives 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 require 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 is applied repeatedly due to enhanced 

degradation of its active ingredient, methyl isothiocyanate, 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 substitute 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 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. 

Three-way fumigation system developed 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 which 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 2008. Dimethyl disulfide (DMDS) plus chloropicrin also 

proven to be effective in managing 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 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 does 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 herbicides 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 the best alternatives 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 require 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 is applied repeatedly due to 

enhanced degradation of its active ingredient, methyl 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 ALTERNATIVES 

COMPARED TO methyl bromide FOR THE SPECIFIC KEY TARGET 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 Cortright (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 bromide 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 can be assumed to be equivalent to metampotassium since the active ingredient is the same. Even large differences in average yields across 

various treatments were often not statistically significant. 

In studies with other vegetable crops, fumigation with 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 bell pepper - squash rotation in small plots, 

Webster et al. (2001) found significantly lower fungal 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 weight 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 tomatoes, Gilreath et al. (1994) found that metamsodium treatments did not match methyl bromide in terms 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 for metam-sodium/potassium + chloropicrin, 

there is inconsistency in efficacy and protection from 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 large 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 effectiveness of several soil fumigants on 

nematodes affecting peppers in Tifton, Georgia. Since 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 prophylactically 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 impractical because of the long waiting periods 

for planting following application under plastic mulch. 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 the higher market windows. Thus, since the fall 

crop is dependent upon timely planting, the required waiting period would cost growers at least 

half of the harvest season, thereby missing the higher market windows (Kelley, 2003). 
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B: KEY WEEDs: Nutsedges 

TABLE 2: DATA ON TRIALS OF FUMIGANT ALTERNATIVES TO METHYL BROMIDE FOR POLYETHYLENE-MULCHED 

TOMATO (LOCASCIO ET AL. 1997)

Chemicals Rate 

(kg/ha) 

Average 

Nutsedge Density 

(#/m2) 

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 planting. Metam-sodium and 1,3 D + chloropicrin 

have shown some efficacy in small-plot trials in other vegetable crops (e.g, tomato). However, 

metam sodium use may result in a 44% yield loss, while use of 1,3 D may result in a 29% loss. 

These fumigants often provide less control of nutsedges than methyl bromide. Furthermore, 

there is evidence that both 1,3 D and methyl isothiocynate levels decline more rapidly due to 

enhanced degradation of these chemicals by soil microorganisms, thus further compromising 

efficacy, in areas where these are repeatedly applied (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 significantly less effective than methyl bromide 

against both purple and yellow nutsedge, although this 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 nutsedge control, but as effective as methyl 

bromide against yellow nutsedge. However, test plots 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 this 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 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 chemicals 

(Culpepper et al., 2008). Future research will focus on developing and implementing a herbicide 

program to compliment both the 3-WAY and DMDS fumigant systems as well as determining 

the amount of time that must pass between fumigating with these alternatives and planting. 

 
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In Florida, the best currently available alternative for eggplant production (which cannot be used 

in areas containing karst topographical features) is an application of Telone C-35 (1,3-D + 35% 

chloropicrin), at 35 gallons per acre, 3-5 weeks before transplanting, followed by an application 

of a herbicide mix of napropamide and trifluralin to the top of the raised bed at the time of tarp 

laying (Noling and Botts, 2007). 

A soil treatment recently developed by the University of Georgia appears to be promising as a 

methyl bromide replacement for Georgia’s eggplant spring crop, although not for the summer or 

fall crops. This treatment, known as the “UGA 3-WAY”, consists of three successive soil 

fumigations, beginning with 1,3-D + chloropicrin application, followed by a chloropicrin 

application, followed by a metam-sodium or metam-potassium application (Culpepper, 2007a). 

In 2006, Culpepper et al. (2007a) tested the effectiveness of fall applications 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 methyl bromide application. Similarly, reducing 

the standard rates of methyl bromide by 50%, from 392 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 Culpepper (2007b) in Echols County, Georgia, during 

the spring of 2006, excellent purple nutsedge control 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 by 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 three 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 unsustainable 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 the efficacy of alternatives on other weed 

species, such as morning glory and pigweed. Finally, the economics of transitioning to 

alternatives has not been fully worked out, including the cost and durability of films and the 

modification of fumigation equipment. 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

The following economic analysis is organized by methyl 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 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. 
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Summary of Economic Feasibility 

The economic analysis of eggplant applications compared data on the yields, crop prices, 

revenues and costs of using methyl bromide or alternative pest control regimens. This was done 

in order to estimate impacts on eggplant growers with the decreasing availability of methyl 

bromide. The Georgia 3-Way (1,3-Dichloropicrin with Chloropicrin followed by metam sodium 

) was identified as being a technically feasible alternative (in cases of low pest infestation1) to 

methyl bromide in Georgia and Florida eggplant production. 1,3-D + chloropicrin is also being 

recognized as an alternative to methyl bromide; however, it is not considered technically feasible 

as yield losses are expected. 

The economic reviewers analyzed crop budgets for pre-plant sectors to determine the likely 

economic impact if methyl bromide were unavailable. Various measures were used to quantify 

the impacts, including the following: 

(1) Loss per Hectare. For crops, this measure is closely tied to income. It is relatively easy to 

measure, but may be difficult to interpret in isolation. 

(2) Loss per Kilogram of Methyl Bromide. This measure indicates the value of methyl 

bromide to crop production. 

(3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross 

revenues are usually easy to measure, at least over some unit, e.g., a hectare of land or a storage 

operation. However, high value commodities or crops may provide high revenues but may also 

entail high costs. Losses of even a small percentage of gross revenues could have important 

impacts on the profitability of the activity. 

(4) Loss as a Percentage of Net Operating Revenue. We define net cash revenues as gross 

revenues minus operating costs. This is a very good indicator as to the direct losses of income 

that may be suffered by the owners or operators of an enterprise. However, operating costs can 

often be difficult to measure and verify. 

(5) Operating Profit Margin. We define operating profit margin to be net operating revenue 

divided by gross revenue per hectare. This measure would provide the best indication of the 

total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be 

difficult to measure and fixed costs even more difficult, therefore fixed costs were not included 

in the analysis. 

These measures represent different ways to assess the economic feasibility of methyl bromide 

alternatives for methyl bromide users, who are eggplant 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 

 

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 Eggplant Grown in Open Fields Page 11 of 15

suppliers using methyl bromide. The economic measures 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 alternative 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 bromide, while gains in gross revenue are 

expected in Georgia. Unlike spring plantings, however, yield losses are expected in fall 

plantings, with studies in Georgia’s application show 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 describing Georgia eggplant production is based on 

double cropping production practices. 

 

Florida Analytical Notes:

Florida’s application for methyl bromide critical use indicated that more than one crop is 

typically grown per growing season but did not provide specific production and sales data for 

this crop. As a result of this gap in data, economic 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 bromide appearing smaller than it actually is, because 

the value the second crop derives from methyl bromide is not included in the analysis. 

TABLE 3: GEORGIA - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

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% 
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Note: Georgia eggplant revenue and cost measures were calculated using data from a two crop per growing season 

production system. 

• Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be 

interpreted as a “gain”. Positive numbers can be interpreted as losses. 

TABLE 4: FLORIDA - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

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. Negative numbers presented in rows indicating a “loss” should be 

interpreted as a “gain”. Positive numbers can be interpreted as losses. 

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

The USG has applied an aggressive transition rate which is reflected in the nomination amount 

and detailed in Table 5. 

TABLE 5. NOMINATION AMOUNT: 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) 13,147 18,843 31,990 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 11,235 18,843 30,078 

Amount (kgs) 11,235 18,843 30,078 

Area (ha) 68 114 182 

Rate 165 165 165 

Transition from 2010 

Baseline Adjusted Value Percentage (%) -47% -50% -48%

Amount (kgs) 8,748 12,813 21,561 

Area (ha) 78 53 131

Rate 165 164 165 

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

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