NOMINATING PARTY: THE UNITED STATES OF AMERICA

FILE NAME: USA CUN12 SOIL CUCURBITS Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

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

Fields (Submitted in 2010 for 2012 Use Season) 

CROP NAME: Cucurbits Open Field

QUANTITY OF METHYL BROMIDE REQUESTED: 

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

Year NOMINATION AMOUNT (KILOGRAMS) 

2012 59,500 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 Cucurbits Open Field Page 1 of 22 
CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: 

Contact/Expert Person: Jack E. 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: jack.housenger@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 CUCURBITS Open Field 23 

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 CUCURBITS Open Field 

* Identical to paper documents 

USA CUN12 SOIL Cucurbits Open Field Page 2 of 22 
METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

CUCURBITS 

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

This renomination covers cucurbits of several types (squash, melons, and/or cucumber) grown in 

the southeastern US (except Florida), Maryland, and Delaware. 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, and that face moderate 

to severe infestations of key pests, 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 cucurbit production, since increased use of high barrier films in conjunction with lower rates 

has been reported there. For the mid-Atlantic region, the low dose rates requested by the 

applicants were incorporated into calculations. 

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 recent 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, southern US areas were adjusted to reflect the 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 karst topographical features. 

USA CUN12 SOIL Cucurbits Open Field Page 3 of 22 
The U.S. nomination is only for those areas where the alternatives are not suitable. For example, 

continuing research indicates that the three way combination mentioned above (the “UGA 3 

way”) does not adequately control key pests when used in place of methyl bromide in “fall” (i.e. 

August or September) fumigations. In U.S. cucurbit production there are several factors that 

make the potential alternatives to methyl bromide unsuitable. These include: 

 The efficacy of alternatives may be significantly less effective than methyl bromide in 

some areas, making these alternatives technically and/or economically infeasible for use 

in cucurbit production. 

 Some alternatives may be comparable to methyl bromide as long as key pests occur at 

low pressure. The U.S. is only nominating a critical use exemption (CUE) for cucurbits 

where the key pest pressure is moderate to high such as nutsedge in the Southeastern U.S. 

 Regulatory constraints prevent use of some chemicals, e.g., 1,3-dichloropropene (1, 3-

dichloropropene ) use is limited in Georgia due to the presence of karst topographical 

features. 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE: 

Our review of available research on other methyl bromide alternatives discussed by MBTOC for 

cucurbits suggests that, of registered (i.e., legally available) chemistries only metam sodium and 

1,3 D + chloropicrin have shown potential as commercially viable replacement to methyl 

bromide. Non-chemical alternatives are either unviable for US cucurbits or require more 

research and commercial development before they can be technically and economically feasible. 

For some areas in the southeastern US, a 3 way combination of 1,3 D followed by chloropicrin 

alone, followed by metam-sodium, has shown promise against key cucurbit pests in spring 

season fumigation. The transition rate included in the BUNNIE incorporates an estimate of 

projected use of this strategy. In this nomination, the Southeastern U.S. includes the following 

states: Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, 

Tennessee, and Virginia. 

The recent Federal registration of iodomethane has not been used to adjust the amount of methyl 

bromide requested in this CUE, because this material has not been registered on cucurbits. Other 

reasons for considering an alternative technically infeasible for cucurbits include: 

- 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). 

The following is the procedure followed for the 2009 allocation year: 

For Southeastern U.S. and Georgia, metam-sodium and 1, 3 D + chloropicrin are the most 

promising alternatives for nutsedges and nematodes, respectively, which are the key target pests 

USA CUN12 SOIL Cucurbits Open Field Page 4 of 22 
in these regions. However, where nutsedges are severe, metam-sodium, used alone, is technically 

and economically infeasible due to planting delays, yield losses and inconsistent efficacy, while 

1,3 D + chloropicrin is infeasible in some areas due to (1) its use being prohibited on Karst 

topographic features, which are widespread in these regions, (2) a 21 day planting delay, and (3) 

yield losses. 

There is also evidence that the pesticidal efficacy of both 1,3 D and metam-sodium declines in 

areas where it is repeatedly applied, due to enhanced degradation of methyl isothiocyanate by 

soil microbes (Ou et al., 1995; Verhagen et al., 1996; Dungan and Yates, 2003; Gamliel et al., 

2003). 

While one study in 2006 showed good efficacy of a combination of 1,3 D + chloropicrin and the 

herbicides napropamide + halosulfuron or metolachlor + trifloxysulfuron in small plots of 

Florida tomatoes (Santos et al. 2006), these results are not applicable to cucurbits because neither 

metolachlor or trifloxysulfuron are registered in the US for cucurbits, and halosulfuron can have 

phytotoxic effects on cucurbits. 

All other potential or available methyl bromide alternatives are also technically infeasible for 

U.S. cucurbits. 

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a certification standard for cucurbit 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. 

 In Southeastern U.S. Georgia, and Maryland, areas not treated do not have nutsedges or 

pathogens naturally present in cucurbit fields. Simple absence of all pests is the only 

reason these areas are not presently treated with methyl bromide. 

 In Delaware and Maryland areas without the existence of several races of Fusarium 

oxysporum niveum, one of which is highly aggressive, or without high concentration of 

the pathogen could use some alternatives such as 1,3-D. 

USA CUN12 SOIL Cucurbits Open Field Page 5 of 22 
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 primary reason that some cucurbits may be grown without methyl bromide in these regions 

is the absence of both key target pests and constraints to use of alternatives (e.g., absence of 

nutsedge, nematodes, and fungal pathogens in the Southeast, and Georgia, several races of 

Fusarium and nutsedges in Delaware and Maryland, and karst topographic features in Georgia). 

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: 

Narrative description of studies relevant to key pathogens 

This section focuses on research relevant to effectiveness of methyl bromide alternatives against 

Fusarium wilt, since that is the main key pest cited by CUE applicants from the 

Maryland/Delaware regions. In studies with vegetable crops in the southeastern US, 1, 3 D + 

chloropicrin has generally shown better control of fungi than metam-sodium formulations 

(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 % 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. Iodomethane had no significant suppressive effect, as compared to the 

untreated control. However, neither of these methyl bromide alternatives increased squash fruit 

weight significantly over the untreated control. Indeed, as compared to the methyl bromide 

standard treatment plots, squash fruit weight was 63 % lower in the 1,3 D plots, and 41 % lower 

in the iodomethane plots. The proportion of unmarketable squash fruit (defined only as those 

fruit so bad as to have to be discarded) in the 1,3 D plots was 30 % worse than that in the methyl 

bromide plots, though in the iodomethane plots it was equivalent to methyl bromide . 

In another study conducted on tomatoes, Gilreath et al. (1994) found that metam-sodium 

treatments did not match methyl bromide in terms of plant vigor at the end of the season; again, 

Fusarium was one of several pests present. 

In another study, by Hausbeck and Cortright (2007), cucurbit plant vigor was measured to 

determine fumigant/mulch performance under either LPDE or VIF plastic mulch for the control 

of Fusarium oxysporum. Of the fumigants used in the study, the methyl bromide and 

iodomethane treatments resulted in cantaloupe plants with the highest vigor (Table 7.1). In 

general, treatments under LPDE had higher plant vigor when compared with plants grown under 

VIF. It is noteworthy that in this study VIF tarps were prone to wind removal, which reduces 

their reliability under some growing conditions. 

USA CUN12 SOIL Cucurbits Open Field Page 6 of 22 
TABLE 2: EVALUATION OF FUMIGANTS AND PLASTIC MULCHES FOR MANAGING FUSARIUM IN 

CUCURBIT CROPS 2007 

TREATMENT (TIME AFTER TREATMENT TO PLANTING) 

RATE OF 

FORMULATED 

PRODUCT

VIGOR* 

Untreated control under LDPE (5 days) ......................................... 1.0-1.3 a

**

Iodomethane+chloropicrin 50:50 under LDPE (10 days)............... 196 kg/ha 1.0 a 

Iodomethane+chloropicrin 50:50 under VIF (10 days) .................. 196 kg/ha 3.0 c 

Methyl bromide+chloropicrin 67:33 under LDPE (10 days).......... 280 kg/ha 1.0 a 

Methyl bromide+chloropicrin 67:33 under VIF (10 days) ............. 280 kg/ha 2.7 bc 

1,3 D + chloropicrin 65:35 under LDPE (21 days)......................... 187 liters/ha 2.3 bc 

1,3 D + chloropicrin 65:35 under VIF (21 days) ............................ 187 liters/ha 4.7 d 

Chloropicrin under LDPE (14 days) ............................................... 187 liters/ha 2.7 c 

Chloropicrin under VIF (14 days)................................................... 187 liters/ha 3.3 cd *

Vigor rating of plant health; 1=healthy plants with no stunting, 5= moderated plant stunting with variable stand, 

10=complete plant death. 

**Column means with a letter in common are not significantly different (Fisher LSD Method; P=0.05). 

From Hausbeck and Cortright 2007. 

In addition to the limitations of VIF discussed above, the USG notes that the plant vigor in 1,3 D 

treatments in these new trials is lower than that seen in methyl bromide treatments. This is 

similar to what was seen in previous years’ tests (Hausbeck and Cortright 2004; see also 

discussions in earlier cucurbit nominations). 

As far as the USG has been able to determine, no other studies have been conducted since 2007 

to evaluate the technical and commercial feasibility of fumigant alternatives to methyl bromide 

for controlling F. oxysporum subtypes under production conditions relevant to the 

Maryland/Delaware regions. 

Research continues to also be conducted to identify Fusarium resistant watermelon stock that 

can be grafted on a commercially feasible basis. While rootstocks protective under conditions of 

low to moderate pathogen infestation have been identified and tested, this work will require 

several more years before it produces methyl bromide alternatives that are both technically and 

economically feasible, and that functions under severe infestations. Such work is being planned 

in the southeastern US (Roberts et al. 2007, Taylor et al. 2007, Bruton, personal communication). 

Results of cucurbit rootstock resistant to root knot nematode (Meloidogyne incognita) were 

presented at the MBAO conference in November 2008 (Kokalis Burrell et al. 2008, Kubota et al. 

2008). Results with muskmelon showed that the evaluated rootstocks have potential as an option 

in an integrated multi-tactic approach to replace methyl bromide. However, this work is in its 

initial stages and further evaluation is needed to assess feasibility of control of other soil pests. 

Furthermore, these trials did not evaluate resistance or commercial feasibility of rootstocks 

USA CUN12 SOIL Cucurbits Open Field Page 7 of 22 
against the Fusarium pests that are key targets for the Maryland/Delaware region. In general, 

grafting of resistant rootstocks is still in an early stage of evaluation and commercial 

implementation for US east coast cucurbit production, and so the USG does not consider them 

viable alternatives to methyl bromide for the purposes of this nomination. 

In conclusion, the USG continues to use the best case yield loss estimates from the previous 

years’ nominations for the Maryland/Delaware region, since these need methyl bromide mainly 

for F. oxysporum control. To paraphrase these loss estimates: 1,3-D +chloropicrin is the likely 

best available alternative for areas in this region that can use (i.e. areas not close to the water 

table). Even with this alternative, a yield loss of about 6 % is likely (based on Hausbeck and 

Cortright, 2004, and discussions in the 2004-2007 cucurbit nominations). The economic impact 

of this loss is further examined in other sections of this document, below. 

Narrative description of studies relevant to key weeds and nematodes 

For nutsedge pests, which are widespread in all requesting regions, cucurbit 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 cucurbits, 

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. 

Watermelon – the only cucurbit crop addressed in these experiments – showed no significant 

(final) yield differences across any fumigant treatment. The same lack of difference was 

observed when herbicides were added. In fact, there was no difference in yield even when 

pesticide treatments were compared to the untreated control. However, nutsedge populations in 

the study appeared to be relatively low (e.g., 667 plants per plot or 135/m2

, in the untreated 

control, at the end of the study). 

USA CUN12 SOIL Cucurbits Open Field Page 8 of 22 
Furthermore, a number of 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. 

(3) This study was done only with watermelons, and it is not clear if other cucurbits will 

respond so favorably in terms of yield, or lack of phytotoxic response. Also, a custombuilt applicator had to be used for the metam-sodium applications to eliminate worker 

exposure risks, according to the authors. It is not yet clear if such an applicator can be 

mass-produced and/or used reliably in a commercial setting. 

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). 

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 cucurbits/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 cucurbits, 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. 

USA CUN12 SOIL Cucurbits Open Field Page 9 of 22 
Therefore, for this nomination, the USG concludes that, for cucurbit 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 7.2 below, and are used as the basis of 

part of the economic assessment in the following section. 

TABLE 3: 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 

MARKETABL

E 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 c 49.1 b --- 

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

Metam Sodium, Flat Fumigation 300 l 320 a 22.6 a 54.0 

Metam Sodium, drip irrigated 300 l 220 b 32.3 c 34.2 

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 

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. Results 

have been similar for cucurbit crops (Culpepper, personal communication; also see several 

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

TABLE 4: 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 

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

USA CUN12 SOIL Cucurbits Open Field Page 10 of 22 
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 7.4) 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 7.4). The economic implications of this level of yield 

loss for Georgia cucurbit growers are further described in Part E, below. 

TABLE 5: COMPARING METHYL BROMIDE AND THE 3-WAY FOR THE CONTROL OF NUTSEDGE AND 

PEPPER YIELD. 

LATE-SEASON 

PURPLE NUTSEDGE 

CONTROL

HARVESTS 1-2 

(JUMBO PEPPER) 

HARVESTS 1-4 

FUMIGANT MULCH (JUMBO PEPPER) 

% # fruit/plot lbs/plot # fruit/plot lbs/plot 

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. 2007). 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 trails 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 

USA CUN12 SOIL Cucurbits Open Field Page 11 of 22 
USA CUN12 SOIL Cucurbits Open Field Page 12 of 22 

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. 

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. 

Summary of Economic Feasibility 

The economic analysis of cucurbit 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 cucurbit 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 the Southeastern United States. Due to differences in climate and 

pests, it is uncertain whether or not the same assumption holds for Maryland and Delaware 

cucurbit production. 1,3-D + chloropicrin and metam sodium are also presented in this analysis 

as recognized alternatives to methyl bromide; however, neither are 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 

 

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. 
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 cucurbit 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. 

Maryland and Delaware 

The U.S. concludes that, at present, no economically feasible alternatives to methyl bromide 

exist for use in Maryland and Delaware melon production. Yield loss and missed market 

windows, which are discussed individually below, have proven most important in reaching this 

conclusion. 

1. Yield Loss

Expected yield losses of 6% are anticipated throughout Maryland and Delaware melon 

production. 

2. Missed Market Windows

USG agrees with Maryland and Delaware’s assertion that growers will likely receive 

significantly lower prices for their produce if they switch to 1,3-D + chloropicrin. This is due to 

changes in the harvest schedule caused by the above described soil temperature complications 

and extended plant back intervals when using 1,3-D + chloropicrin. 

The analysis of this effect is based on the fact that prices farmers receive for their cucurbits vary 

widely over the course of the growing season. Driving these fluctuations are the forces of supply 

and demand. Early in the growing season, when relatively few cucurbits are harvested, the 

supply is at its lowest and the market price is at its highest. As harvested quantities increase, the 

price declines. In order to maximize their revenues, cucurbit growers manage their production 

systems with the goal of harvesting the largest possible quantity of cucurbits when the prices are 

USA CUN12 SOIL Cucurbits Open Field Page 13 of 22 
USA CUN12 SOIL Cucurbits Open Field Page 14 of 22 

at their highs. The ability to sell produce at these higher prices makes a significant contribution 

toward the profitability of cucurbit operations. 

To describe economic conditions in Maryland and Delaware melon production, EPA used 

weekly and monthly cucurbit sales and production data from the U.S. Department of Agriculture 

for the previous three years to gauge the impact of early season price fluctuations on gross 

revenues. Though data availability was limiting, analysts assumed that if cucurbit growers adjust 

the timing of their production system, as required when using 1,3-D + Chloropicrin, gross 

revenues will decline by approximately 5% over the course of the growing season, due solely to 

price effects. The season average price was reduced by 5% in the analysis of the alternatives to 

reflect this effect. Based on currently available information, the U.S. believes this reduction in 

price serves as a reasonable indicator of the typical effect of planting delays resulting when 

methyl bromide alternatives are used in Maryland and Delaware melon production. 

Other Considerations: 

In Maryland and Delaware cucurbits, Fusarium oxypsorum niveum exists in three separate races, 

and no one crop cultivar has resistance to all races. Crop experts in Maryland report that methyl 

bromide alternatives provided lower protection against the pathogen while also creating 

obstacles to meeting premium market windows. USG believes that the best alternatives (1,3 D + 

chloropicrin) may offer some defense against the pathogen (with a yield loss similar to that likely 

in Michigan). However, since the crop acreage involved is in low-lying coastal plain, waterlogged soils frequently occur in rainy periods and this could delay fumigation with this and other 

alternatives (such as metam-sodium) and cause additional losses by forcing growers to miss key 

mid-July market windows. 

The Southeastern USA2

 and Georgia 

In the Southeastern U.S. and Georgia, 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 Tables 6 through 14, the loss of gross revenue using the Georgia 3-

Way is negligible for Georgia and the Southeastern U.S., while in some cases 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 cucurbits 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 

the Southeastern United States’ cucurbit production. Note that data describing Georgia cucurbit 

production is based on double cropping production practices. 

Southeastern U.S. Analytical Notes 

The applicant provided no data on the operating costs of alternatives. Analysts assumed, 

however, that these costs were similar to those of methyl bromide with slight upward 

adjustments for the costs of applying the alternatives and a slight downward adjustment for the 

cost of the alternative product. In addition, the applicant did not provide data for second crops 

 

2

 Except Georgia 
(including revenues and operating costs). Analysts assumed that Southeastern cucurbits are 

grown in a single crop production system. However, if double cropping is practiced in the actual 

production system, this assumption could make the critical need for methyl bromide appear 

smaller than it actually is, because the value the second crop derives from methyl bromide is not 

included in the analysis 

Georgia Analytical Notes 

Other potentially significant economic factors, such as price reductions due to missed market 

windows, were not analyzed for this region as the case for critical use of methyl bromide is 

sufficiently strong based solely on Georgia 3-Way fall yield losses. 

Economic analysis of Georgia growing conditions included cost and production data 

representing a second cucurbits or peppers crop. 

TABLE 6. MARYLAND AND DELAWARE MELON - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

MARYLAND AND DELAWARE MELON 

METHYL 

BROMIDE 1,3-D + CHLOROPICRIN 

PRODUCTION LOSS (%) 0% 6% 

 PRODUCTION PER HECTARE 2,347 2,207 

* PRICE PER UNIT (US$) $11 $11 

= GROSS REVENUE PER HECTARE (US$) $25,822 $24,273 

- OPERATING COST PER HECTARE (US$) $21,073 $20,366 

= NET REVENUE PER HECTARE (US$) $4,749 $3,907 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 $843 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $11 

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

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0% 18% 

5. OPERATING PROFIT MARGIN (%) 18% 16% 

* 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 CUN12 SOIL Cucurbits Open Field Page 15 of 22 
TABLE 7. SOUTHEASTERN USA (EXCEPT GEORGIA) CUCUMBER -: ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA) 

CUCUMBER 

METHYL 

BROMIDE 

GEORGIA 

3-WAY 

1,3-D + 

CHLOROPICRIN 

METAM 

SODIUM 

PRODUCTION LOSS (%) 0% 0% 29% 44%

 PRODUCTION PER HECTARE 828 828 588 464

* PRICE PER UNIT (US$) $16 $16 $16 $16

= GROSS REVENUE PER HECTARE (US$) $13,245 $13,245 $9,404 $7,417

- OPERATING COST PER HECTARE (US$) $10,556 $10,652 $9,691 $9,736

= NET REVENUE PER HECTARE (US$) $2,689 $2,593 -$288 -$2,319

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 $96 $2,976 $5,007 

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 $1 $32 $54 

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 1% 22% 38%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 4% 111% 186%

5. OPERATING PROFIT MARGIN (%) 20% 20% -3% -31%

* 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 8. SOUTHEASTERN USA (EXCEPT GEORGIA) MELONS - ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA) 

MELON 

METHYL 

BROMIDE 

GEORGIA 

3-WAY 

1,3-D + 

CHLOROPICRIN 

METAM 

SODIUM 

PRODUCTION LOSS (%) 0% 0% 29% 44%

 PRODUCTION PER HECTARE 815 815 579 457

* PRICE PER UNIT (US$) $15 $15 $15 $15

= GROSS REVENUE PER HECTARE (US$) $12,232 $12,232 $8,685 $6,850

- OPERATING COST PER HECTARE 

(US$) $11,202 $11,297 $10,337 $10,381

= NET REVENUE PER HECTARE (US$) $1,030 $934 ($1,652) -$3,531

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 $96 $2,682 $4,562 

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 $1 $29 $49 

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 1% 22% 37%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 9% 260% 443%

5. OPERATING PROFIT MARGIN (%) 8% 8% -19% -52%

* 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 CUN12 SOIL Cucurbits Open Field Page 16 of 22 
TABLE 9. SOUTHEASTERN USA (EXCEPT GEORGIA) SQUASH -: ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA) 

SQUASH 

METHYL 

BROMIDE

GEORGIA 

3-WAY 

1,3-D + 

CHLOROPICRIN 

METAM 

SODIUM 

PRODUCTION LOSS (%) 0% 0% 29% 44%

 PRODUCTION PER HECTARE 311 311 221 174

* PRICE PER UNIT (US$) $29 $29 $29 $29

= GROSS REVENUE PER HECTARE 

(US$) $9,029 $9,029 $6,411 $5,056

- OPERATING COST PER HECTARE 

(US$) $7,338 $7,433 $6,473 $6,517

= NET REVENUE PER HECTARE (US$) $1,692 $1,596 -$62 -$1,461

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 $96 $1,754 $3,152 

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 $1 $19 $34 

3. LOSS AS A PERCENTAGE OF 

GROSS REVENUE (%) 0% 1% 19% 35%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 6% 104% 186%

5. OPERATING PROFIT MARGIN (%) 19% 18% -1% -29%

* 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 10. ALL SOUTHEASTERN US (EXCEPT GEORGIA) CUCURBITS - ECONOMIC IMPACTS OF METHYL 

BROMIDE ALTERNATIVES

ALL SOUTHEAST US (EXCEPT 

GEORGIA) CUCURBITS 

METHYL 

BROMIDE 

GEORGIA 3-

WAY 

1,3-D + 

CHLOROPICRIN 

METAM 

SODIUM 

PRODUCTION LOSS (%) 0% 0% 29% 44%

 PRODUCTION PER HECTARE 652 652 463 303

* PRICE PER UNIT (US$) $18 $18 $18 $17

= GROSS REVENUE PER 

HECTARE (US$) $11,502 $11,502 $8,166 $5,235

- OPERATING COST PER 

HECTARE (US$) $9,802 $9,899 $8,939 $8,984

= NET REVENUE PER HECTARE 

(US$) $1,700 $1,603 -$773 -$3,749

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 $97 $2,472 $5,449

2. LOSS PER KILOGRAM OF 

METHYL BROMIDE (US$) $0 $1 $27 $59

3. LOSS AS A PERCENTAGE OF 

GROSS REVENUE (%) 0% 1% 21% 47%

4. LOSS AS A PERCENTAGE OF 

NET OPERATING REVENUE (%) 0% 6% 145% 321%

5. OPERATING PROFIT MARGIN 

(%) 15% 14% -9% -72%

* 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 CUN12 SOIL Cucurbits Open Field Page 17 of 22 
TABLE 11. GEORGIA CUCUMBER - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

GEORGIA CUCUMBERS METHYL 

BROMIDE 

GEORGIA 3-WAY: 

SPRING 

APPLICATION 

GEORGIA 3-WAY: 

FALL 

APPLICATION 

PRODUCTION LOSS (%) 0% 0% 50%

 PRODUCTION PER HECTARE 5,740 5,740 2,870

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

= GROSS REVENUE PER HECTARE (US$) $67,223 $67,223 $33,611

- OPERATING COST PER HECTARE (US$) $54,251 $40,226 $40,226

= NET REVENUE PER HECTARE (US$) $12,972 $26,997 -$6,615

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 -$14,024 $19,587

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 -$151 $211

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% -21% 29%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% -108% 151%

5. OPERATING PROFIT MARGIN (%) 19% 40% -20%

* 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 12. GEORGIA MELON ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

GEORGIA MELONS METHYL 

BROMIDE 

GEORGIA 3-

WAY: SPRING 

APPLICATION 

GEORGIA 3-

WAY: FALL 

APPLICATION 

PRODUCTION LOSS (%) 0% 0% 50% 

 PRODUCTION PER HECTARE 4,275 4,275 2,137 

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

= GROSS REVENUE PER HECTARE (US$) $49,696 $49,696 $24,848 

- OPERATING COST PER HECTARE (US$) $42,085 $43,288 $43,288 

= NET REVENUE PER HECTARE (US$) $7,610 $6,408 -$18,440 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 $1,202 $26,050 

2. LOSS PER KILOGRAM OF METHYL 

BROMIDE (US$) $0 $13 $280 

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 2% 52% 

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% 16% 342% 

5. OPERATING PROFIT MARGIN (%) 15% 13% -74% 

* 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 CUN12 SOIL Cucurbits Open Field Page 18 of 22 
TABLE 13. GEORGIA SQUASH - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

GEORGIA SQUASH METHYL 

BROMIDE 

GEORGIA 3-

WAY: SPRING 

APPLICATION 

GEORGIA 3-

WAY: FALL 

APPLICATION 

PRODUCTION LOSS (%) 0% 0% 50%

 PRODUCTION PER HECTARE 5,251 5,251 2,625

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

= GROSS REVENUE PER HECTARE 

(US$) $40,556 $40,538 $20,269

- OPERATING COST PER 

HECTARE (US$) $43,739 $31,348 $31,348

= NET REVENUE PER HECTARE 

(US$) -$3.183 $9,188 -$11,079

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 -$12,372 $7,896

2. LOSS PER KILOGRAM OF 

METHYL BROMIDE (US$) $0 -$132 $85

3. LOSS AS A PERCENTAGE OF 

GROSS REVENUE (%) 0% -31% 19%

4. LOSS AS A PERCENTAGE OF 

NET OPERATING REVENUE (%) 0% -389% 248%

5. OPERATING PROFIT MARGIN 

(%) -6% 21% -58%

* 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 CUN12 SOIL Cucurbits Open Field Page 19 of 22 
TABLE 14. ALL GEORGIA CUCURBITS - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

GEORGIA CUCURBITS METHYL 

BROMIDE 

GEORGIA 3-

WAY: SPRING 

APPLICATION 

GEORGIA 3-

WAY: FALL 

APPLICATION 

1,3-D + 

CHLOROPICRIN

PRODUCTION LOSS (%) 0% 0% 50% 29% 

 PRODUCTION PER HECTARE 4,741 4,741 2,370 3,404 

* PRICE PER UNIT (US$) $10 $10 $10 $10 

= GROSS REVENUE PER 

HECTARE (US$) $46,439 $46,435 $23,217 $33,325 

- OPERATING COST PER 

HECTARE (US$) $44,278 $40,213 $40,213 $43,999 

= NET REVENUE PER HECTARE 

(US$) $2,161 $6,222 -$16,995 -$10,675 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $0 -$4,062 $19,156 $12,835 

2. LOSS PER KILOGRAM OF 

METHYL BROMIDE (US$) $0 -$44 $206 $138 

3. LOSS AS A PERCENTAGE OF 

GROSS REVENUE (%) 0% -9% 41% 28% 

4. LOSS AS A PERCENTAGE OF 

NET OPERATING REVENUE (%) 0% -188% 887% 594% 

5. OPERATING PROFIT MARGIN 

(%) 5% 13% -73% -32% 

* 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 15. 

TABLE 15. NOMINATION AMOUNT.

USA CUN12 SOIL Cucurbits Open Field Page 20 of 22 
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