NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 SOIL ORCHARD REPLANT Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

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

Fields (Submitted in 2010 for the 2012 Use Season) 

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

QUANTITY OF METHYL BROMIDE NOMINATED: 

Year NOMINATION AMOUNT

2012 18,324 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 CUN12 SOIL Orchard Replant Open Field Page 1 of 19 
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 CUN12 SOIL ORCHARD REPLANT Open Field 

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: 

*Title of each electronic file (for naming convention see notes above) 

No. of 

kilobytes 

Date sent to Ozone 

Secretariat 

USA CUN12 SOIL ORCHARD REPLANT Open Field 

* Identical to paper documents 

USA CUN12 SOIL Orchard Replant Open Field Page 2 of 19 
METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

ORCHARD REPLANT 

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

The U.S. nomination for critical use of methyl bromide for orchard replant in 2012 is for a 

portion of replant sites in California where alternatives are not suitable, either because of 

regulatory restrictions or physical characteristics, such as unacceptable soil type or moisture or 

topography. For 2012, four requests for critical use exemptions were received—stone fruit, table 

& raisin grapes, almonds, and walnuts. These areas represent a small portion of the entire 

orchard replant in California. 

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. 

Research studies have been ongoing to identify methods and technologies to reduce reliance on 

high rates of fumigants. Research includes the use of GPS-based application equipment (e.g., 

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

have shifted heavily towards use of 1,3-dichloropropene instead of MB for soil fumigation, but 

this transition does not appear to be stable in a regulatory sense or completely effective in terms 

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

McKenry (2006) have reported on methods that can help to replant many orchard sites without 

methyl bromide. One requirement is the use of nematode-tolerant rootstocks, which may not be 

available (e.g., McKenry and Buzo, 2009). Methyl bromide continues to be a critical tool for 

sites that are not amenable to other treatments due to features such as soil type or soil moisture, 

or regulatory restrictions, or activity against certain pests, such as Armillaria root rot (e.g., UC 

Pest Management Guidelines, 2008). In addition, new regulations to reduce volatile organic 

compound emissions may cause a delay of fumigation beyond October into November and 

December in some locations (e.g. San Joaquin Valley) when soils are colder. This may result in 

reduced efficacy of the primary alternative 1,3-D. 

Fumigation prior to replanting orchards is used to optimize initial growth of young plants in 

orchard sites with minimal pest populations. Because of the perennial nature of orchards, 

fumigation occurs only once and is the most efficient system to avoid slow tree growth, early 

tree removal, added costs, and lost revenue. In addition, effective fumigation appears to reduce 

the effects of a poorly understood disease complex called orchard replant “problem”, or 

“disorder” The problem can be of varying severity depending on orchard location, crop, soil 

texture, soil moisture, or other factors. Orchards and vineyards with replant problem have 

several visible symptoms—the most apparent is poor tree growth during the early years of 

USA CUN12 SOIL Orchard Replant Open Field Page 3 of 19 
establishment (rejection component). Replant problem presents a challenge to growers when 

replanting orchards and vineyards, considering the long-term investment (typically fruit orchards 

can produce for 20-25 years, walnut orchards can produce for 40 years, and almond orchards 

produce on average 25-30 years) that is necessary for fruit and nut orchard production. For 

orchard and vineyard replant situations where other fumigants are not available, methyl bromide 

is critical.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

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

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

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

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

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

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

methyl bromide, which represents a small portion of total replant sites. There is a critical need 

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

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

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

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

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

with chloropicrin, and/or metam-sodium, especially in coarse-textured soils. Under certain soil 

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

replant problems and is currently used to replant the majority of orchard and vineyard sites. In 

addition, research is being conducted with steam to disinfest soils for replant (e.g., Fennimore 

and Goodhue, 2009), although multi-year trials must be conducted to prove efficacy. 

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

STANDARD?

Methyl bromide is not covered by a certification standard for orchard replant. 

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

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

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE. 

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

metam-sodium, especially in light soils (e.g., Caprile and McKenry, 2006; Wang et al., 2009). 

These alternatives are used effectively under optimal soil temperature and moisture conditions 

(high moisture at surface and less than 12% at depths to 1.5 meters) and methyl bromide is not 

critical. There is a critical need for methyl bromide in orchards in California where alternatives 

USA CUN12 SOIL Orchard Replant Open Field Page 4 of 19 
cannot be used, either because of legally mandated township caps for 1,3-D, local permit 

requirements for chloropicrin, buffer zone limitations, or surface moisture requirements cannot 

be met. If rain does not occur, growers without sprinkler systems have difficulty applying water 

for 1,3-D application. 

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

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

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE 

THIS? 

The replacement of methyl bromide with alternatives to treat soils is taking place as is indicated 

by results of research and extension work (see “Summary of Recent Research” below). The 

current nomination for methyl bromide is an amount that allows a reasonable transition to 

alternatives in the small portion of replant sites that cannot use alternative treatments. 

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. 

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

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

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

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

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

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

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

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

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

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

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

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

been identified as May 1 through October 31. 

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

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

almond and stone fruit land, and about one-half of the walnut land. All sources of NOx and 

VOCs are being evaluated by the California Department of Pesticide Regulation (CDPR), which 

has the authority to regulate the use of soil fumigants. CDPR has issued a rule to reduce the 

emissions, including restrictions on timing and methods of fumigation. For example, for orchard 

replant, the only method of application allowed for methyl bromide or chloropicrin is HDPEtarped, deep-shank, broadcast fumigation. Strip applications are not allowed in the May-October 

USA CUN12 SOIL Orchard Replant Open Field Page 5 of 19 
period. In the past, most orchard replant fumigations occurred during this period. Use of 1,3 D, 

however, may not be impacted as much as other soil treatments. 

6. SUMMARY OF RECENT RESEARCH 

Research in California continues to identify methods for orchard replant to improve tree survival 

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

2009 Annual International Research Conferences on Methyl Bromide Alternatives and 

Emissions Reductions (Beede et al., 2009; Browne et al., 2009; McKenry and Buzo, 2009; 

Klonsky et al., 2009; Fennimore and Goodhue, 2009; Wang et al., 2009). In addition, 

presentations to the 2007 and 2008 research conferences provided results in ongoing projects 

(Browne et al., 2008; Upadhyaya et al., 2008; Wang et al., 2008; Beede et al., 2008; Browne et 

al., 2007; Kluepfel and Beede, 2007; McKenry et al., 2007; Coates et al., 2007; Wang et al., 

2007). 

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

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

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

efficacy of this alternative. 

Stone Fruit and Almonds: Research including USDA Pacific Area-wide Pest Management 

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

almond (Browne et al., 2009; Browne et al., 2008; Fennimore and Goodhue, 2009; Klonsky et 

al., 2009; McKenry and Buzo, 2009). Objectives of the area-wide research are 1) To develop 

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

and stone fruit replant problems without MB; 2) To provide comprehensive economic 

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

demonstration day, May 2008. Stone fruit and almond replant trials continue since their 

establishment in 2006. 

Trials reported in 2009 were conducted with 1,3-D, iodomethane, and chloropicrin alone and in 

combination with 1,3-D and iodomethane. Trial results (Browne et al., 2009) indicated that 1) 

row strip treatments with several alternatives performed as well as methyl bromide, where 

untreated rows showed moderate Prunus replant disease, 2) GPS-controlled preplant spot 

fumigation (treating a 2.5 x 2.5 m area with a centered on tree site) has maintained very good 

tree growth with large savings in fumigant use and costs, compared to strip and broadcast 

treatments, 3) in two trials, strip treatments and spot treatments provided comparable tree growth 

to methyl bromide treatments. An economic evaluation of fumigation of almonds was conducted 

(Klonsky et al., 2009) that found 1) the most efficient (cost of an increase in weight of almonds) 

treatment was the Telone II (1,3-D) strip treatment at $0.32 per ~0.5 kg increased almonds, 

followed by chloropicrin strip treatment, followed by Telone C35 strip treatment and Telone II 

strip treatment with tarp, 2) the methyl bromide/chloropicrin strip treatment and Telone C35 

broadcast had the highest cost ($1 per ~0.5 kg increase in almond weight). The strip treatment 

was the most cost effective for Telone II, Telone C35, and the methyl bromide/chloropicrin 

treatments due to the significantly lower treatment costs compared to broadcast treatments 

USA CUN12 SOIL Orchard Replant Open Field Page 6 of 19 
(although the yield was lower). Chloropicrin strip treatments not only lowered costs but 

increased yields compared to broadcast treatments. The cost of tarp was not cost effective for 

any treatment. 

Fennimore and Goodhue (2009) estimated costs of steam disinfestation of soils for almond 

replant with a commercial steam applicator from Italy and steam injection. The machine can 

disinfest an 8 x 1.5 m plot per heating, which could treat up to 0.66 ha per day. In addition, 

researchers are planning to test a tractor-pulled augur and a system to inject steam into soils. If 

research supports acceptable efficacy, costs of the sterilizing machine are estimated to be $2196 

per acre ($5425 per ha) compared to $2500 per acre ($6175 per ha) for methyl bromide 

treatment. The steam augur system was estimated to cost $341 per acre ($842 per ha) for 

planting 90 trees. Experiments to measure efficacy of steam disinfestation are planned. 

McKenry and Buzo (2009) continue to study the possibilities of a “starve and switch” approach 

to almond replant and management of Prunus replant disease. Herbicides are used to kill 

remnant roots of previous plantings to destroy nematode nutrients and switch to a tolerant or 

resistant rootstock. While costs appear to be acceptable, the availability of acceptable rootstocks 

for almond replant is lacking. 

Grapes: Multi-season field trials, as part of the USDA Pacific Area-wide Pest Management 

Program, continue to identify methods to manage vineyard pests (Wang et al., 2009; Wang et al., 

2008; Wang et al., 2007). Recent treatments were mustard cover crop, methyl bromide shanked 

at 448 kg/ha under HDPE, 1,3-D + 35% chloropicrin shanked with no tarp at 610 and at 305 

kg/ha with no tarp or with VIF, and InLine drip at 305 kg/ha with no tarp or VIF. Preliminary 

results indicated that control of total Pythium spp. was successful in all fumigated plots except 

InLine without tarps. Total Fusarium was significantly reduced on by methyl bromide. Live 

citrus nematodes were only found in the untreated plots. No other species of nematodes were 

found alive in any fumigated plot. Pruning weight (a measure of plant health) was highest in the 

soils treated with methyl bromide, 1,3-D + 35% chloropicrin (high rate), 1,3-D + 35% 

chloropicrin (low rate with VIF), and InLine with VIF. In addition, VIF significantly reduced 

fumigant emissions. 

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

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

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

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

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

ability to use tree-site or strip fumigation (see Section 7 below). 

Results of research on walnut was recently reported (Beede et al., 2009; Beede et al., 2008) and 

is an ongoing attempt to: 1) identify cost-effective commercial fumigant alternatives to methyl 

bromide, 2) test new application technologies, and 3) initiate outreach to growers for walnut 

production, and 4) test clonal vs. seedling plant material. 

Research continues to indicate that the continued use of the common rootstock Paradox is not 

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

USA CUN12 SOIL Orchard Replant Open Field Page 7 of 19 
USA CUN12 SOIL Orchard Replant Open Field Page 8 of 19 

Various treatments (different rates and application methods) with 1,3-D, chloropicrin, and 

methyl bromide were evaluated. Conclusions from recent research (Beede et al., 2009) confirms 

previous findings that 1,3-D and chloropicrin show comparable pathogenic nematode 

management potential to methyl bromide 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

In this study net revenue is calculated as gross revenue minus operating costs. This is a measure 

of 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. Fixed costs were not 

included because it is often difficult to measure and verify. 

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

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

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

technically feasible - in cases of low pest infestation1

 – are different combinations of 

chloropicrin, metam sodium and 1,3- D. 

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

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

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

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

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

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

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

Without effective fumigation growers who replant orchards can face losses from: 

• Delayed planting 

• Fallow 

• Additional use of herbicides 

• Tree loss 

• Replant costs to replace tree losses 

• Loss of trees replanted 

• Yield loss of fruit or nuts 

• Delayed achievement of full yield potential 

• Earlier loss of productivity of whole orchard 

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

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

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

 

1

 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 CUN12 SOIL Orchard Replant Open Field Page 9 of 19 

The benefits of fumigation for orchard or vineyard replant can be measured by future yields 

(orchard crops require several years to begin bearing) when production may be adversely 

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

in healthier young plants. Other fumigants besides methyl bromide are used for fumigation, but 

in some cases, such as where there are heavy soils or township caps on 1,3-D, these alternatives 

may not be available. 

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

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

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

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

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

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

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

production. 

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

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

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

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

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

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

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

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

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

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

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

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

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

orchard under different streams of costs and returns. Net present value (NPV) is a way of 

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

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

 

 

T

t

t t t

r

NPV

0 )1(

Revenue Cost

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

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

individual’s trade-off of money between time periods2

. Since revenues and costs are not 

adjusted for future inflation, all measures are in real terms. 

 

2

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

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

private capital (OMB, 2003). 
Since the choice of discount rate is somewhat arbitrary, BEAD also presents the internal rate of 

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

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

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

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

California Walnuts and Almonds 

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

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

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

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

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

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

methyl bromide. 

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

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

an early age, stunting their growth. Table 1 presents the expected differences in production and 

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

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

accordingly. 

USA CUN12 SOIL Orchard Replant Open Field Page 10 of 19 
Table 1. Gross revenue, operating costs, and net operating revenues, California walnuts 

orchard at full production. 

Methyl bromide + 

Chloropicrin 

1,3-D + Chloropicrin 

(% change) 1

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

(-4.0%) 

Price ($/kg) 1.43 1.43 

Gross Revenue ($/hectare) 5,315 5,101 

(-4.0%) 

Operating Costs ($/hectare) 1,403 1,403 

Harvest Costs ($/hectare) 895 867 

(-2.8%) 

Net Operating Revenue ($/hectare) 3,018 2,660 

(-11.9%) 

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

due to rounding.

1 Percent change in comparison to methyl bromide with chloropicrin. 

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

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

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

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

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

far more dire. 

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

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

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

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

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

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

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

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

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

higher replant rates represent the lower survival rate if nematodes are controlled but orchard 

replant disorder or pathogens are not. Trees begin to produce in the fourth year, initially at 10% 

of production, climbing to full production in the eighth year (Buchner et al., 2002). Returns 

during full production are shown in Table 2. 

USA CUN12 SOIL Orchard Replant Open Field Page 11 of 19 
Table 2. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a walnut orchard. 

Year Stage 

Methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

Field Preparation -585 -585 

Fumigation 1 -3,127 -1,855 

1 

Establishment -3,789 -3,789 

2 Non-bearing 2 -978 -1,018 

3 Non-bearing -897 -897 

4 Initial production 3 -637 -657 

5 Partial production 5 -417 -457 

6 Partial production 6 -106 -165 

7 Partial production 6 1,331 1,213 

8 Full production 7 3,018 2,660 

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

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

IRR 13.8% 13.9% 

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

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

discount rate. 

1 Fumigation costs include chemical costs and application costs. 

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

3 Initial production is 10% of full production. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

additional yield is valued at about $370/hectare, therefore methyl bromide adds about $63.3 

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

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

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

USA CUN12 SOIL Orchard Replant Open Field Page 12 of 19 
some orchards would probably not be established at all; thus these figures may understate the full 

value of the methyl bromide. 

California Stone Fruit 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

consequences are expected to be more dire. 

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

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

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

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

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

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

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

approximately $125/hectare. 

USA CUN12 SOIL Orchard Replant Open Field Page 13 of 19 
Table 3. Gross revenue, operating costs, and net operating revenues, California prune 

orchard at full production. 

Methyl bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

(% change) 1

Yield (dried ton/hectare) 4.4 4.2 

(-4.0%) 

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

Gross Revenue ($/hectare) 5,002 4,802 

(-4.0%) 

Operating Costs ($/hectare) 2,080 2,080 

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

(-4.0%) 

Net Operating Revenue ($/hectare) 1,028 904 

(-12.1%) 

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

due to rounding.

1 Percent change in comparison to methyl bromide with chloropicrin. 

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

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

on net operating revenue, NPV, and IRR for a prune orchard under the treatment options. Field 

preparation costs are similar for any type of fumigation, but fumigation costs differ according to 

the mix of chemicals and the cost of application. Chemical costs are average per-hectare cost of 

products, which incorporates typical application rates. Trees are planted the following spring 

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

the following year. We assume that 2% are replanted following fumigation with methyl bromide 

an chloropicrin (Buchner et al., 2001); 3% are replanted with 1,3-D and chloropicrin; The higher 

replant rate represents the lower survival rate if nematodes are controlled but soil pathogens are 

not and amount to two or four trees. Trees begin to produce in the fourth year, initially at 20% of 

production, climbing to full production in the seventh year (Buchner et al., 2001). Returns 

during full production are shown in Table 4. 

USA CUN12 SOIL Orchard Replant Open Field Page 14 of 19 
Table 4. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a prune orchard. 

Year Stage 

Methyl 

bromide + 

chloropicrin 

1,3-D + 

chloropicrin 

0 Field Preparation -618 -618 

Fumigation 1 -2,519 -2,025 

1 Establishment -3,137 -3,137 

2 Non-bearing 2 -995 -1,018 

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

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

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

6 Partial production 2 -82 

7 Full production 1,028 904 

8-40 Full production 1,028 904 

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

IRR 6.3% 5.7% 

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

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

discount rate. 

1 Fumigation costs include chemical costs and application costs. 

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

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

alone. 

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

5

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

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

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

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

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

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

plum grown on heavier soils. 

USA CUN12 SOIL Orchard Replant Open Field Page 15 of 19 
8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

TABLE 5. NOMINATION AMOUNT:

 CA G&TFL - 

Stone Fruit 

 CA G&TFL - 

Raisin Grape 

 CA Walnut 

Commission 

 Almond Hullers 

& Processors 

 CA Wine Grapes 

Replant Sector Total / Average 

Quantity Requested for 2011: Amount (kgs) 8,544 134,696 22,200 17,575 20,577 203,592 

Quantity Recommended by 

MBTOC/TEAP for 2011 : Amount (kgs) 6,260 126,992 18,443 16,599 14,938 183,232 

Amount (kgs) 6,260 126,992 18,443 16,599 14,938 183,232 

Area (ha) 31 635 92 83 75 916 

Rate 200 200 200 200 200 200 

Transition from 2011 

Baseline Adjusted Value

Percentage 

(%) -90% -90% -90% -90% -90% -90%

Amount (kgs) 626 12,700 1,844 1,660 1,494 18,324 

Area (ha) 63 3 9 8 7 92

Rate 200 200 200 200 200 200

SECTOR

ORCHARD REPLANT

Quantity Approved by Parties 

for 2011:

Quantity Required for 

2012 Nomination:

USA CUN12 SOIL Orchard Replant Open Field Page 16 of 19 
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