USA CUN13 SOIL Peppers Open Field Page 1 of 16

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN13 SOIL PEPPERS Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Peppers Grown in Open 

Fields (Submitted in 2011 for 2013 Use Season)

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

QUANTITY OF METHYL BROMIDE REQUESTED:

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

Year NOMINATION AMOUNT (KILOGRAMS)

2013 5,673 kg

NOMINATING PARTY CONTACT DETAILS:

Contact Person: John Thompson

Title: Division Director

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) 647-9799

Fax: (202) 647-5947

E-mail: thompsonje2@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the 

specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for 

this use would result in a significant market disruption. . ■ Yes  No

Signature Name Date

Title: 

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

Decision Ex. I/4(8).) 

This form is to be used by holders of single-year exemptions to reapply for a subsequent year’s exemption (for 

example, a Party holding a single-year exemption for 2005 and/or 2006 seeking further exemptions for 2007). It 

does not replace the format for requesting a critical-use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on 

which the Party’s first-year exemption was approved, as well as any supplementary information provided by the 

Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not 

re-submit that earlier information. 
USA CUN13 SOIL Peppers Open Field Page 2 of 16

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger

Title: Director

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 CUN13 SOIL PEPPERS Open Field 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 CUN13 SOIL PEPPERS OPEN FIELD

* Identical to paper documents
USA CUN13 SOIL Peppers Open Field Page 3 of 16

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT)

PEPPERS

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

This renomination covers only peppers grown in the southeastern US, Georgia, Florida,. These 

crops generally are grown in open fields on plastic tarps, often followed by various other crops. 

Harvest is destined for the fresh market.

Only areas that cannot use alternative fumigants or non-fumigant options have been included in 

the calculation of nominated amounts and area to be treated. The applicants’ requests have also 

been adjusted downward to account for the lower methyl bromide dose rates (see BUNNIE in 

Appendix A) for the southern regions of US pepper production, since increased use of high 

barrier films in conjunction with lower rates has been reported there. 

The USG has reviewed all factors affecting transition rates in this sector. Based on this 

assessment the transition rate has been greatly increased for most portions of this sector. For the 

area covered in this nomination, the USG believes that the narrative discussion included in this 

document is technically valid. The USG has nominated amounts of methyl bromide based only 

on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate.

In developing this renomination the USG examined several recent studies to determine whether 

yield losses and market window losses associated with the best available fumigant alternative 

could be altered from previous nominations. Unfortunately none of the studies located by the 

USG met the criteria that earlier cited studies did. These criteria include: the use of fumigant 

alternatives registered for the crop nominated, the presence of both a methyl bromide standard 

and an untreated control as treatments as well as the monitoring of yields under each treatment. 

Several such studies included a methyl bromide treatment or an untreated control but not both, or 

included both but did not monitor yield, or included unregistered alternatives. However, research 

conducted at the University of Georgia that examined use of a three way combination of 

alternative fumigants (1,3 D followed by chloropicrin followed by metam-sodium) did meet 

these criteria, Therefore, nominations for the southern US areas were adjusted to reflect the 

apparent technical feasibility of this three way combination of alternative fumigants under VIF 

or metallized films, as a replacement for spring-time applications of methyl 

bromide+chloropicrin, after accounting for areas in the south that face prohibition of 1,3-D due 

to the presence of karst topographical features.

The recent renewal of the federal registration of iodomethane, along with its registration at the 

state level in all the pepper producing regions covered by this nomination, will be factored into 

calculations of the total amount of methyl bromide being requested for peppers. This calculation 

takes into account the issue that time will be needed for the industry to transition to the use of 

this material in areas where it is feasible. This transition is part of the BUNNIE included in 

Appendix A.
USA CUN13 SOIL Peppers Open Field Page 4 of 16

U.S. reliance on methyl bromide has dramatically and rapidly been reduced over the last eight 

years. Critical use exemption (CUE) requests have decreased every year since the U.S. phaseout process began. The development, registration, and use of new pest control products and 

production methods have been key to the progress and reductions made to-date. As alternatives 

have demonstrated their suitability, as thorough reviews of research results and applicant 

information have been conducted, and contacts have been made with regional crop experts to 

assess the technical and economic feasibility of alternatives, U.S. Government (USG) requests 

have reduced by 99%, for the fruiting vegetables, over the last 9 years. However, as the amount 

of methyl bromide available for use decreases each year, substantial challenges exist in the 

collection of needed data to substantiate on-going critical needs through the CUE process. 

There are now several alternatives for soil fumigation, including 1,3-dichloropropene plus 

chloropicrin, the “UGA 3 Way” combination (1,3-dichloropropene plus chloropicrin followed by 

metam sodium), iodomethane plus chloropicrin, and dimethyl disulfide (DMDS) which have 

demonstrated some technical and economic feasibility for pest control in a number of vegetable 

crops in the U.S. Southeast. However, CUE applicants in this nominated sector have indicated 

that they are not always suitable for all situations. While DMDS has a Federal registration and 

has demonstrated effectiveness, it is not currently registered in all the relevant states. Given the 

timing of state registrations, lack of experience using this alternative, and application methods 

still under development to minimize odor in communities surrounding treated fields there is 

uncertainty in predicting when this alternative can be reasonably expected to adequately replace 

methyl bromide in specific application scenarios. While the DMDS registrant has been working 

with the product to reduce the odor, and growers are gaining experience in its use, work is still 

needed on application approaches for the alternative to be fully available for use in U.S. 

southeast vegetable crops. For example individual operators and small farms, which account for 

up to eighty percent of the growers in this nominated sector are especially hard-pressed to make 

this transition, because one of the most promising alternatives requires additional money to 

convert their fumigation equipment and custom fumigation applicators are not available in all 

areas. In addition to the expense to convert to the alternatives, there have been reports that the 

alternatives do not perform as well as the MeBr:pic combination. 

These concerns about the alternatives have only recently been brought to the USG attention and 

insufficient supporting information was provided. Because of the uncertainties and challenges 

associated with the use of the available alternatives, the USG believes it most prudent and the 

best public policy to collect additional information so that the technical and economic impacts of 

these reported problems can be evaluated. The USG will request the applicants provide 

additional information to us no later than June 1, 2011 so that the information can be analyzed 

and provided to MBTOC by July 15, prior to the Open Ended Work Group (OEWG) meeting in 

early August. The quality of any additional information received will first be evaluated in terms 

of whether or not it supports a compelling case and confirms problems with the feasibility of

alternatives. Then, on that basis, the USG will either support or withdraw this nominated sector 

at that meeting. 

The nomination attached specifies the correct year (2013) and amount of methyl bromide that is 

being requested for the individual crops within this sector. However, there has been no attempt 
USA CUN13 SOIL Peppers Open Field Page 5 of 16

to update the information in this document regarding the new research, availability of 

alternatives, etc. Since the USG learned of the issues facing the growers within this sector, after 

speaking directly with researchers familiar with the specific problems only very recently, this 

information was not available at the time the USG recommendation was developed. 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

The U.S. nomination is only for those areas where the alternatives are not suitable. In U.S. 

pepper production there are several factors that make the potential alternatives to methyl bromide 

unsuitable. These include:

- Pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to 

methyl bromide in some areas, making these alternatives technically and/or economically 

infeasible for use in pepper production.

- Geographic distribution of key target pests: i.e., some alternatives may be comparable to 

methyl bromide as long as key pests occur at low pressure, and in such cases the U.S. is 

only nominating a CUE for peppers where the key pest pressure is moderate to high such 

as nutsedge in the Southeastern U.S.

- Regulatory constraints: e.g., 1,3 D use is limited in Georgia and Florida due to the 

presence of karst topography.

- Infeasibility of fall-season fumigation in the southeastern US, even with the best available 

combination of alternatives (1,3 D followed by chloropicrin followed by metam-sodium).

- There are significant restrictions on which crops can be rotated through after use of a 

given alternative (e.g., halosulfuron has rotational restrictions that prevent its use in 

southeastern US tomatoes).

- Resistance management prevents use of the alternative (e.g., glyphosate resistant weeds, 

such as Amaranth, in the southern US, prevent use of this alternative as a post-emergent 

weed control in those regions). 

Florida, Georgia, and the Southeastern U.S. (outside Florida and Georgia) are each presented as 

separate regions in this nomination to reflect the separate applications from growers in these 

areas. In this nomination, the Southeastern U.S. includes the following states: Alabama, 

Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, and 

Virginia. A brief description of their need for methyl bromide follows, also presented on a 

regional basis. 

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a certification standard for pepper vegetable production.

4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, 

INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER 

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE.
USA CUN13 SOIL Peppers Open Field Page 6 of 16

In southeastern U.S., Florida, and Georgia, areas not treated have low levels of nutsedge or 

nematodes in pepper fields

5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO 

COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF 

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE 

THIS?

Better, more consistent pest control efficacy from the alternatives would be required.

The USG has reviewed all factors affecting transition rates in this sector. Based on this 

assessment the transition rate has been greatly increased for most portions of this sector. For the 

area covered in this nomination, the USG believes that the narrative discussion included in this 

document is technically valid. The USG has nominated amounts of methyl bromide based only 

on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate.

6. SUMMARY OF RECENT RESEARCH

As mentioned earlier in this document, iodomethane formulated with chloropicrin has shown 

good efficacy against key pepper pests, including nutsedge, in a number of trials with peppers 

and related vegetables such as tomatoes (e.g., Louws et al. 2006, Culpepper 2006, 2007, 2008, 

Culpepper et al. 2008, Olsen 2008). Iodomethane had time limitations removed from its federal 

label in October, 2008, and has received state-level approval in 47 US states (California, 

Washington, and New York are the exceptions at this time). However, other important 

constraints must be considered when assessing the feasibility of iodomethane as a methyl

bromide alternative. These include: (1) the cost of iodomethane formulations is higher than 

methyl bromide, and will probably remain so for the next several years, (2) growers and 

researchers will need time to evaluate iodomethane use in the various local production conditions 

covered by this nominations, and (3) growers and applicators will need to make some equipment 

modifications to adapt to the lower flow rates typical with less expensive iodomethane 

application rates and to avoid the corrosion of some metals that can occur with iodomethane

(Sumner 2005, Noling et al. 2006). The economic impact of using iodomethane is further 

described in Part E of this document (below). A consideration of these aspects has led the USG 

to conclude that while iodomethane appears to be technically feasible to manage key pepper 

pests in all parts of the US where it has been registered, time will be needed for growers and 

extension service experts to adapt its use successfully. Therefore, the amount of methyl bromide 

nominated for peppers has been adjusted downward while also considering the time needed to

transition to iodomethane. 

In the short term, and in situations where pepper producers cannot use iodomethane, the USG 

concludes that other fumigant alternatives to methyl bromide would have to be used. The details 

of this conclusion are similar to the previous year’s pepper CUN, and are further discussed 

below.

Narrative description of studies relevant to key weeds and nematodes
USA CUN13 SOIL Peppers Open Field Page 7 of 16

For nutsedge pests, which are widespread in all requesting regions, pepper growers do not 

currently have technically feasible alternatives to methyl bromide use at planting. Metamsodium and 1,3 D + chloropicrin have shown some efficacy in small-plot trials in other vegetable 

crops (e.g, tomato). However, at best, metam sodium may allow at least 44 % yield loss, while 

1,3 D may allow at least 29 % loss. Both often show less control than methyl bromide (in terms 

of population suppression) of nutsedges. These factors suggest that even this alternative will not 

be economically feasible even in the best-case technical scenario. It should be noted also that 

there is evidence that both 1,3 D and methyl isothiocyanate levels decline more rapidly, thus 

further compromising efficacy, in areas where these are repeatedly applied (Smelt et al., 1989; 

Ou et al., 1995; Gamliel et al., 2003). This is probably due to enhanced degradation of these 

chemicals by soil microbes (Dungan and Yates, 2003). 

Other chemical alternatives to methyl bromide that have shown promise against nutsedges and 

nematodes (e.g., pebulate and dimethyl disulfide) are currently unregistered for peppers,

In one recent study, Culpepper and Langston (2004) conducted studies at 2 sites in spring 2003 

and one site in the fall season of 2004. Plot sizes were 20 feet X 32 inches (4.94 m2). 

Treatments were: Methyl bromide standard (67:33 formulation), untreated control, 2 

formulations of Telone (1,3 D + chloropicrin) at various doses, followed by an additional 

application of either chloropicrin or metam-sodium, a third formulation of 1,3 D + chloropicrin 

(“Inline”), and iodomethane. An additional set of plots received the same fumigant treatments 

but also received an herbicide treatment (clomazone + halosulfuron) later in the season. 

Some important caveats must be mentioned when considering these results:

(1) Plots used were quite small, and it is not at all clear if the promising results will hold 

reliably in larger commercial fields. This is particularly worrisome given the highly 

variable results reported by other researchers for the same methyl bromide alternatives.

(2) The nutsedge populations in this study were dominated by yellow nutsedge (90 % of the 

total number). It is not clear if populations where purple nutsedge is dominant will be 

controlled as effectively. A number of other studies have indicated that purple nutsedge 

is a hardier species, and even in Culpepper and Langston’s study, it appeared more 

resistant to the methyl bromide alternatives. For example, iodomethane gave “77 % 

control” of yellow nutsedge, but only “37 % control” of purple nutsedge. Control in this 

case was apparently defined as the reduction in nutsedge populations as compared to 

populations in the untreated control. 

Another recent study of methyl bromide alternatives involving key weed pests was done by

Gilreath et al. 2005 (Crop Prot (24): 903-908). One of 3 trials in that study showed an average of 

30 % lower bell pepper yields with nutsedge and nematodes as the key pests present. In the other 

2 trials yields were not significantly different across different fumigant treatments, but nutsedge 

pressure was lower in those trials as compared to the third. Other important caveats to these 

results are - this was a small-plot study and was done in Florida. Thus it is not clear how 

applicable the results are to the more northern regions requesting methyl bromide for vegetable 

crops (e.g., Delaware, Maryland, and Virginia).
USA CUN13 SOIL Peppers Open Field Page 8 of 16

In addition to the studies described above, several other recent studies conducted in the 

production circumstances of the southeastern US have examined several fumigant alternatives to 

methyl bromide, most done in crops other than peppers (e.g., Santos et al. 2006, Candole et al. 

2007, Santos and Gilreath 2007, Gilreath and Santos 2005, 2007). These studies either focused 

solely on nutsedge weeds or a combination of nutsedges, diseases, and nematodes. However, 

USG has examined these papers and concludes that for peppers, these studies do not meet all the 

criteria that allowed the use of earlier studies in estimating yield and quality losses that may 

occur if such methyl bromide alternatives are used as direct replacements for methyl bromide. 

These criteria are: the use of fumigant alternatives registered for the crop nominated, the 

presence of both a methyl bromide standard and an untreated control as treatments as well as the 

monitoring of yields under each treatment. Several such studies included a methyl bromide 

treatment or an untreated control but not both (Santos and Gilreath 2007, Johnson and Mullinix 

2007), or included both but did not monitor yield (Candole et al. 2007), or included unregistered 

alternatives (e.g., Gilreath and Santos 2005, 2007, Santos et al. 2006). While these studies (the 

majority of which were small-plot trials) indicate continued promise of methyl bromide 

alternatives such as 1,3-D, metam-sodium, chloropicrin, herbicides, or combinations thereof, 

they cannot yet be used to alter yield estimates.

Therefore, for this nomination, the USG concludes that, for pepper growers who can only use 

either 1,3-D + chloropicrin or metam-sodium+chloropicrin in fall-season fumigations to control 

nutsedge and nematode pests, the yield loss estimates used in last year’s nomination continue to 

be applicable. These loss estimates are illustrated in Table 2 below, and are used as the basis of 

part of the economic assessment in the following section.

TABLE 2. DATA ON YIELD LOSSES WITH LIKELY METHYL BROMIDE ALTERNATIVES AND NUTSEDGE 

PRESENT AS A CROP PEST.

Chemicals Rate (kg/ha)

Average 

Nutsedge 

Density

(#/m2)

Average 

Marketable 

Yield

(ton/ha)

% Yield Loss 

(compared to 

MB)

Untreated (control) - 300 ab 20.1 a

59.1

methyl bromide + Pic 

(67-33), chiselinjected

390 kg 90 c49.1 b---

1,3 D + Pic (83-17), 

chisel-injected 327 l 340 a

34.6 c29.5

Metam Na, Flat 

Fumigation 300 l 320 a

22.6 a54.0

Metam Na, drip 

irrigated 300 l 220 b

32.3 c34.2

Locascio et al. 1997. 

Recent studies that are useful (within the context of this nomination) in assessing technical 

feasibility of a combination of methyl bromide alternatives include the series of trials being 

conducted by Culpepper et al. at the University of Georgia (e.g., Culpepper 2006, Culpepper et 

al. 2007a,b, Culpepper 2008). These studies indicate that a 3-way, sequential combination of 
USA CUN13 SOIL Peppers Open Field Page 9 of 16

several fumigant alternatives is technically feasible for spring-time fumigation of most vegetable 

crops. The 3-way combination consists of 1,3 D followed by chloropicrin at about 168 kg/ha, 

followed by metam-sodium, all under VIF or metallized (high barrier) tarps, and will henceforth 

be referred to as the ‘UGA 3 way’, as Culpepper et al. have. An example of the results obtained 

in spring fumigation with this combination in peppers is presented in the table below. Also see 

several research reports available from the University of Georgia at www.gaweed.com).

TABLE 3. NUMBER OF PEPPER FRUIT - METHYL BROMIDE: CHLOROPICRIN VERSUS THREE WAY 

COMBINATION. SPRING 2006 

Fruit Size Methyl Bromide : 

Chloropicrin

(# of Fruit)

UGA 3 way

1,3-D fb chloropicrin fb 

metam Na

Jumbo 30 b 125 a

X-Large 219 a 237 a

Large 153 a 143 a

Chopper 217 a 252 a

Cull 11 a 9 a

Jumbo + X-Large + Large 402 b 505 a

Footnote: Culpepper 2006. fb means followed by or a sequential treatment. Plots were 3 rows 

by 100 feet long. 

Since Georgia is similar to other areas of the southeastern US, except Maryland/Delaware 

peppers which face a different key pest (F. oxysporum niveum), these results should be 

applicable to spring usage of methyl bromide in these regions. However, other results thus far 

indicate that summer/fall fumigation is not similarly effective with this combination of 

alternatives (Culpepper, personal communication, Culpepper 2006, 2008). 

Results of one of several experiments conducted by Culpepper et al. at the University of Georgia 

illustrate the infeasibility of the use of the ‘UGA 3 way’ method in place of methyl bromide for 

fall-season fumigations in vegetable production. In this experiment, fields were fumigated during 

for fall-season crop production on July 17 2007. Soil temperature was 84 degrees at 8 inches. 

The experiment consisted of 4 fumigant treatments (Table 4) that were replicated three times.

Even under high-barrier film (“Blockade”), the ‘UGA 3 way’ gave less control of purple 

nutsedge as compared to the methyl bromide standard under the same type of film. Yields were 

consistently lower with the ‘UGA 3 way’ as well, with a roughly 50 % reduction in both number 

and weight of harvested vegetables (Table 4). The economic implications of this level of yield 

loss for Georgia pepper growers are further described in section 7, below.

Table 4. Comparing methyl bromide and the 3-Way for the control of nutsedge and pepper

yield.

Fumigant Mulch Late-season 

purple 

nutsedge 

control

Harvests 1-2

(Jumbo pepper)

Harvests 1-4

(Jumbo pepper)

% # 

fruit/plot

lbs/plot # 

fruit/plot

lbs/plot
USA CUN13 SOIL Peppers Open Field Page 10 of 16

UGA-3 

Way

LDPE 48 d 34 c 16 c 44 c 19 c

UGA-3 

Way

Blockade 60 c 50 b 24 b 71b 32 b

Methyl 

Bromide + 

chloropicrin

Blockade 85 b 106 a 48 a 136 a 61 a

None LDPE 0 f 13 d 6 d 19 d 8 d

Notes: (1) The UGA 3 Way consisted of 1,3 D at approximately 192 kg/ha, followed by chloropicrin at 168 kg/ha, 

followed by metam-sodium at approximately 358 kg/ha. Methyl bromide + chloropicrin was applied in a 50:50 mix 

at approximately 160 kg/ha of each. Rates as shown are not planting bed-strip adjusted. (2) “Mulch” refers to the 

tarp type. LDPE = traditional high permeability tarp; Blockade = low permeability tarp manufactured by Pliant 

Corp.

It is important to note that caveats accompany even the technical feasibility of the ‘UGA 3 way’

use in spring fumigations. Growers must make several application modifications to properly use 

the approach, and this may incur significant capital expenditure. Culpepper et al. estimate their 

costs to do this for their research trials at about $ 15,000 (Culpepper et al. 2007b). Application 

costs will also increase as more chemicals and runs of tractor equipment are required to conduct 

the ‘UGA 3 way’, and the cost of VIF or metallized film is between 1.75 and two times greater 

than standard LBPF (Culpepper, personal communication). 

Time and further research and extension education will also be needed to implement the ‘UGA 

3-way’ method in areas outside Georgia where the method has been less-studied, and where 

different problems may need to be resolved. An example of this issue is illustrated in recent work 

by Chellemi et al. (2008). These researchers evaluated the ‘UGA 3 way’ in on-farm tests in 

Florida peppers. Results of four trials were highly variable, with two showing better yields than 

the methyl bromide standard, and two showing worse results. All four trials showed a reduction 

in larger (more profitable) peppers in the ‘UGA 3 way’ as compared to the methyl bromide 

standard. The cause appeared to be an overload of potassium in the soil, created by the combined 

use of the metam-potassium in the ‘UGA 3 way’ and the growers’ standard practice of applying 

a high-potassium fertilizer. 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

The following economic analysis is organized by methyl bromide critical use application 

regions. 

Reader, please note that in this study net revenue is calculated as gross revenue minus operating 

costs. This is a good measure as to the direct losses of income that may be experienced 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 these costs are often difficult to measure 

and verify. 
USA CUN13 SOIL Peppers Open Field Page 11 of 16

Summary of Economic Feasibility

The economic analysis of pepper 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 pepper growers with the decreasing availability of methyl bromide. The 

alternatives identified as technically feasible (in cases of low pest infestation1) for Georgia, 

Florida, and the Southeaster U.S. for peppers are: (a) Iodomethane and (b) the Georgia 3-Way

Method, which includes 1,3-dichloropicrin with chloropicrin followed by metam sodium. 

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 

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 pepper 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.

GEORGIA, FLORIDA, AND THE SOUTHEASTERN U.S. 

 

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 CUN13 SOIL Peppers Open Field Page 12 of 16

In Georgia, Florida, and the Southeastern U.S., the Georgia 3-Way on spring plantings and 

iodomethane are considered technically and economically feasible alternatives to methyl 

bromide, although some limitations exist. Referring to Table 5, 6, and 7, the loss of net revenue 

using the Georgia 3-Way is negligible in Florida and the Southeastern U.S. in comparison to 

methyl bromide, while gains in net revenue are expected in Georgia. Although no gains in gross 

revenue are expected when using iodomethane, losses in net revenue are negligible. One 

drawback to the Georgia 3-Way is that yield losses are expected in fall plantings, with studies in 

Georgia’s application show a 50% yield loss. These losses are not expected when iodomethane is 

used. The Georgia 3-Way also cannot be used on peppers that are grown in karst soils since it 

contains 1,3-D; however, iodomethane can be, making methyl bromide unnecessary for pepper 

production in areas with karst topography. Note that data describing Georgia and Florida pepper 

production are based on double cropping production practices. 

TABLE 5. GEORGIA : ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

GEORGIA PEPPER METHYL 

BROMIDE

GEORGIA 3-

WAY: SPRING 

APPLICATION 

GEORGIA 3-

WAY: FALL 

APPLICATION 

IODOMETHANE

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

 PRODUCTION PER 

HECTARE 5,797 5,797 2,899 5,797

* PRICE PER UNIT (US$) $12 $12 $12 $12

= GROSS REVENUE PER 

HECTARE (US$) $67,907 $67,907 $33,954 $67,907

- OPERATING COST PER 

HECTARE (US$) $55,279 $41,211 $41,211 $56,433

= NET REVENUE PER 

HECTARE (US$) $12,629 $26,696 -$7,258 $11,475

LOSS MEASURES *

1. LOSS PER HECTARE (US$) $0 -$14,067 $19,886 $1,154

2. LOSS PER KILOGRAM OF 

METHYL BROMIDE (US$) $0 -$151 $214 $12

3. LOSS AS A PERCENTAGE OF 

GROSS REVENUE (%) 0% -21% 29% 2%

4. LOSS AS A PERCENTAGE OF 

NET OPERATING REVENUE 

(%) 0% -111% 157% 9%

5. OPERATING PROFIT 

MARGIN (%) 19% 39% -21% 17%

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

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

TABLE 6. FLORIDA: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES 

FLORIDA PEPPER-DOUBLE CROP METHYL 

BROMIDE

GEORGIA 3-

WAY IODOMETHANE

PRODUCTION LOSS (%) 0% 0% 0%

 PRODUCTION PER HECTARE 4,379 4,379 4,379

* PRICE PER UNIT (US$) $12 $12 $12
USA CUN13 SOIL Peppers Open Field Page 13 of 16

= GROSS REVENUE PER HECTARE (US$) $51,756 $51,756 $51,756

- OPERATING COST PER HECTARE (US$) $48,934 $49,030 $49,522

= NET REVENUE PER HECTARE (US$) $2,822 $2,726 $2,234

LOSS MEASURES *

1. LOSS PER HECTARE (US$) $0 $96 $588

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 $1 $6

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 0% 1%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 3% 21%

5. OPERATING PROFIT MARGIN (%) 5% 5% 4%

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

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

TABLE 7. SOUTHEASTERN USA (EXCEPT GEORGIA): ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES

SOUTHEASTERN USA (EXCEPT GEORGIA) 

PEPPER

METHYL 

BROMIDE

GEORGIA 3-

WAY IODOMETHANE

PRODUCTION LOSS (%) 0% 0% 0%

 PRODUCTION PER HECTARE 2,965 2,965 2,965

* PRICE PER UNIT (US$) $8 $8 $8

= GROSS REVENUE PER HECTARE (US$) $24,463 $24,463 $24,463

- OPERATING COST PER HECTARE (US$) $21,955 $22,051 $22,543

= NET REVENUE PER HECTARE (US$) $2,508 $2,412 $1,920

LOSS MEASURES *

1. LOSS PER HECTARE (US$) $0 $96 $588 

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 $1 $6 

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 0% 2%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 4% 23%

5. OPERATING PROFIT MARGIN (%) 10% 10% 8%

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

interpreted as a “gain”. Positive numbers can be interpreted as losses. 
USA CUN13 SOIL Peppers Open Field Page 14 of 16

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 8.

TABLE 8. NOMINATION AMOUNT: 

 Southeast Pepper Georgia Pepper Florida Pepper 

 Sector Total / 

Average 

Quantity Requested for 2012: Amount (kgs) 341 947 27,077 28,366

Quantity Recommended by

MBTOC/TEAP for 2012 :

Amount (kgs) 341 947 27,077 28,365

Amount (kgs) 341 947 27,077 28,365

Area (ha) 61 220 1,094 1,375

Rate 6 4 25 21

Transition from 2012 Baseline

Adjusted Value

Percentage (%) -80% -80% -80% -80%

Amount (kgs) 68 189 5,415 5,673

Area (ha) 0.5 1 36 38

Rate 150 150 150 150

SECTOR

Quantity Approved by Parties for

2012:

Quantity Required for

2013 Nomination:

PEPPER

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