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NOMINATING PARTY: The United States of America

DATE: JULY 14, 2011

FILE NAME: USA CUE13 MBTOC REPLIES 07-2011

BRIEF DESCRIPTIVE TITLE :

Methyl Bromide Critical Use Nomination for 2013, U.S. Replies to MBTOC Report (Submitted 

in 2011 for 2013 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Cucurbits, Eggplant, Ornamentals, 

Peppers, Rose Nursery, Strawberry Fruit, Tomato and Dried Meat Products

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Policy Advisor

Address: Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2657

Washington, D.C. 20520 U.S.A.

Telephone: (202) 647-3819

Fax: (202) 647-1052

E-mail: SanMartiniFM@state.gov

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

The U.S. is withdrawing its request for the following uses based on the data that is currently 

available to us having requested further justification from the applicants that would demonstrate 

that the lack of availability of methyl bromide will result in significant market disruption and that 

there are no technically and economically feasible alternatives. 

Table 1. Amount of methyl bromide (kg) to be withdrawn by the United States

Sector Applicant Methyl Bromide (kg)

Cucurbits MarDel (Maryland & Delaware) 348

Cucurbits Southeast Consortium 7,665

Pepper Southeast Consortium 68

Nursery Stock California Rose Growers 65

Tomato Southeast Consortium, Maryland, 

and Virginia

1,633

Total 9,779
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Cucurbit

MBTOC (TEAP 2011) recommends a CUE of 11.899 tonnes for this use in 2013, provided the Party submits 

further explanation on the specific issues that have arisen for the alternatives by July 15th, 2011 recognizing 

that the nominated amount represents an almost complete phase-out in this industry. The USG may either 

support or withdraw this nominated sector at the OEWG. If the US proposes an increased amount, MBTOC will 

need to reassess. From this amount, 0.815 t are for Georgia squash, 0.657 tonnes for Georgia cucumber; 2.415 

tonnes for Georgia melon; and 7.665 t for the Southeast region and 0.348 t for Mardel area.

U.S. Reply

The U.S. is requesting that MBTOC recommend the amount nominated for Georgia 

cucurbits in the U.S. Nomination for one final year (2013). 

For Georgia, the U.S. review of the available information indicates that small growers (growing 

less than 4 ha or 10 acres of this crop) need an additional year to successfully transition to the 

alternatives. These small growers do not have as much experience with the alternatives and need 

to convert their equipment to the 3-Way mixture (1, 3-dichloropropene plus chloropicrin plus 

metam). The United States conducted an economic assessment of small grower’s ability to 

convert their equipment (see Table 2 below). The assessment demonstrates that despite the 3-

Way mixture being more affordable than MeBr plus chloropicrin on a per acre basis, retrofitting 

farm equipment to use the 3-Way mixture at a cost of $ 3450 (Culpepper, 2011) is not affordable 

for growers under four acres, amortized over 10 years at 7% interest (7% is a current home 

equity loan rate for this region, interest on agricultural loans could be lower). However, due to 

variations in impacts for individual growers and uncertainties in the assumptions used in this 

economic analysis, farms less than 10 acres are reasonably expected to incur negative impacts 

from having to covert to the 3-Way mixture. Based on this assessment, the amount of methyl 

bromide being requested this year will be allocated to farmers with less than 4 ha (10 acres) of 

this crop. Small farms of this size in Georgia are a very small subset of vegetable growers and 

account for 10 to 15% of the vegetable farms (Census of Agriculture, 2007). There are currently 

no commercial fumigation/applicators in Georgia so these applications cannot be done by 

someone else. 

Table 2. Comparison of the Costs of Using Methyl Bromide versus the GA 3-Way on a 3, 4, 

and 10-Acre Tomato Farm in Georgia

Alternatives 3 Acre Farm 4 Acre Farm 10 Acre Farm

MeBr:Pic 3-Way Mix MeBr:Pic 3-Way Mix MeBr:Pic 3-Way Mix

Gross Revenue $ 70,830 $ 70,830 $ 94,440 $ 94,440 $ 236,101 $ 236,101 

Total Operating Costs $ 70,002 $ 69,484 $ 93,337 $ 92,646 $ 233,341 $ 231,614 

Net Revenue $ 828 $ 1,346 $ 1,104 $ 1,795 $ 2,759 $ 4,487 

Difference between Net 

Revenue Earned per 

Farm When Applying

MeBr vs. Net Revenue 

Earned When Applying 

3-Way & Accounting 

for Cost to Retrofit*

N/A $ (106) N/A $ 67 N/A $ 1,104

Notes: EPA assumes retrofitting costs of $ 3450 are amortized over a 10 year period at 7%, compounded. This 

interest rate is based on the assumption that farmers would be subject to the same interest rates as those on a 

home equity loan, which currently in Georgia for a 10-year loan are approximately 7%.
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Eggplant

MBTOC (TEAP 2011) recommends 1.381 tonnes for this use for 2013, provided the Party submits further 

explanation on the specific issues that have arisen for the alternatives by July 15th, 2011. Of this amount, 0.769 

t are for Georgia and 0.612 t are for Florida. If substantiation is not provided, MBTOC does not recommend this 

nomination. The USG may either support or withdraw this nominated sector at the OEWG. If the US proposes 

an increased amount, MBTOC will need to reassess.

U.S. Reply

The U.S. is requesting that MBTOC recommend the amount nominated for Georgia and 

Florida eggplant in the U.S. Nomination for one final year (2013). 

For Georgia, the U.S. review of the available information indicates that small growers (growing 

less than 4 ha or 10 acres of this crop) need an additional year to successfully transition to the 

alternatives. These small growers do not have as much experience with the alternatives and need 

to convert their equipment to the 3-Way mixture (1, 3-dichloropropene plus chloropicrin plus 

metam). The United States conducted an economic assessment of small grower’s ability to 

convert their equipment (see Table 3 below). The assessment demonstrates that despite the 3-

Way mixture being more affordable than MeBr plus chloropicrin on a per acre basis, retrofitting 

farm equipment to use the 3-Way mixture at a cost of $ 3450 (Culpepper, 2011) is not affordable 

for growers under four acres, amortized over 10 years at 7% interest (7% is a current home 

equity loan rate for this region, interest on agricultural loans could be lower). However, due to 

variations in impacts for individual growers and uncertainties in the assumptions used in this 

economic analysis, farms less than 10 acres are reasonably expected to incur negative impacts 

from having to covert to the 3-Way mixture. Based on this assessment, the amount of methyl 

bromide being requested this year will be allocated to farmers with less than 10 acres of this 

crop. Small farms of this size in Georgia are a very small subset of vegetable growers and 

account for 10 to 15% of the vegetable farms (Census of Agriculture, 2007). There are currently 

no commercial fumigation/applicators in Georgia so these applications cannot be done by 

someone else. 

Table 3. Comparison of the Costs of Using Methyl Bromide versus the GA 3-Way on a 3, 4, 

and 10-Acre Tomato Farm in Georgia

Alternatives 3 Acre Farm 4 Acre Farm 10 Acre Farm

MeBr:Pic 3-Way Mix MeBr:Pic 3-Way Mix MeBr:Pic 3-Way Mix

Gross Revenue $ 70,830 $ 70,830 $ 94,440 $ 94,440 $ 236,101 $ 236,101 

Total Operating Costs $ 70,002 $ 69,484 $ 93,337 $ 92,646 $ 233,341 $ 231,614 

Net Revenue $ 828 $ 1,346 $ 1,104 $ 1,795 $ 2,759 $ 4,487 

Difference between Net 

Revenue Earned per 

Farm When Applying

MeBr vs. Net Revenue 

Earned When Applying 

3-Way & Accounting 

for Cost to Retrofit*

N/A $ (106) N/A $ 67 N/A $ 1,104

Notes: EPA assumes retrofitting costs of $ 3450 are amortized over a 10 year period at 7%, compounded. This 

interest rate is based on the assumption that farmers would be subject to the same interest rates as those on a 

home equity loan, which currently in Georgia for a 10-year loan are approximately 7%.
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Florida surveyed several growers to find out their experience in 2010 with alternatives (see Table 

4). The survey demonstrates that some growers still experience impacts when using the 

alternatives. The individuals responding to the survey describe impacts as yield loss, cost 

increases, or longer plant back intervals when using the alternatives. Allowing the use of methyl 

bromide through 2013 will provide time for Florida growers to adapt their systems to the use of 

the alternatives (different fumigants, potentially an herbicide treatment under the tarp, longer 

plant back interval, different films, etc.). 

Table 4. Florida Survey Data on Alternatives

CROP Percent of Acres Surveyed Impact * % (range)

Eggplant 4 Not listed

Pepper 4 -9 % (0 to 20)

Tomato 28 -8 % (0 to 25)

Notes: * Impact was interpreted by respondents as yield loss, cost increase, or longer plant back intervals 

leading to missing a market window.

Ornamental

MBTOC (TEAP 2011) recommends a reduced amount of 40.818 tonnes for this use in 2013. This includes 

39.907 t for California and 0.911 t for Florida. MBTOC has reduced the nomination by 15% for California and 

25% for Florida, respectively, based on implementation of substrates, steam and uptake and improvement in MI 

technologies by 2013 and the registration time (and rate) for MI.

U.S. Reply

The United States agrees with the 25% reduction that MBTOC recommended for Florida

ornamentals in the U.S. Nomination. The United States is requesting that MBTOC 

recommend the amount nominated for California ornamentals in the U.S. Nomination. 

The United States has conducted an economic assessment of ornamental production in California 

and Florida comparing methyl bromide plus chloropicrin to iodomethane plus chloropicrin (see 

Table 5 and 6). The assessment demonstrates there would be some impacts on Florida 

ornamental growers. Some but not all growers have been able to incorporate the alternatives into 

their ornamental production systems. The United States is optimistic that as growers gain 

experience with their own ornamental cultivars, production systems and timing schedules they 

will be able to use the alternatives with very few impacts. The United States believes the 25% 

reduction in Florida suggested by MBTOC can be sustained absent further information being 

provided

The situation in California is different than that in Florida because California registered MidasTM 

(iodomethane) in December of 2010 at lower use rates and there is no research data to determine 

the yield and quality impacts at the registered rates. When California registered MidasTM 

(iodomethane) at lower use rates it left us without any research data to determine the yield and 

quality impacts at the registered rates. Therefore, we have assumed a 20% yield loss using 

iodomethane plus chloropicrin until we obtain research data indicating the correct implications of 

the lower use rates. In addition, California has much larger buffer distances around sensitive
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sites for iodomethane (1/2 mile buffers) and early work indicates a large percentage of acres 

cannot use iodomethane.

Please note that in the economic assessment net operating revenue is calculated as gross revenue 

minus operating costs. In general, this is a good measure of the direct losses of income that may 

be suffered by the users. The net operating revenue does not represent net income to the users. 

Net income, which indicates profitability of an operation for an enterprise, is gross revenue 

minus the sum of operating and fixed costs. Net income is smaller than the net operating 

revenue measured in this study, often substantially so. We did not include fixed costs because 

they are difficult to measure and verify. In Table 5, the loss as a percentage of net operating 

revenue is negative, which is difficult to interpret. Therefore, in this case, the loss as a 

percentage of gross revenue would be a more meaningful and consistent measure of loss 

especially for comparison across the two states. 

Table 5. California Cut Flowers - Calla Lily & Ranunculus - Economic Impacts of Methyl 

Bromide Alternatives

California Cut Flowers – Calla Lily & 

Bulbs

METHYL 

BROMIDE

1,3-D + Pic Dazomet Metam 

Sodium

Iodomethane + 

Pic (50:50)

YIELD LOSS (%) 0% 25% 25% 20% 20%

 YIELD PER HECTARE 55,937 41,952 41,952 44,749 44,749 

* PRICE PER UNIT (U.S.$) $ 2.59 $ 2.59 $ 2.59 $ 2.59 $ 2.59 

= GROSS REVENUE PER HECTARE 

(U.S.$) $ 145,107 $ 108,830 $ 108,830 $ 116,086 $ 116,086 

- OPERATING COSTS PER HECTARE 

(U.S.$) $ 161,824 $ 160,685 $ 160,154 $ 158,343 $ 164,206 

= NET OPERATING REVENUE PER 

HECTARE (U.S.$) $ (16,717) $ (51,855) $ (51,323) $ (42,257) $ (48,121)

1. LOSS PER HECTARE (U.S.$) $ - $ 35,138 $ 34,606 $ 25,540 $ 31,404 

2. LOSS PER KILOGRAM OF MEBR

(U.S.$) $ - $ 133 $ 131 $ 97 $ 119 

3. LOSS AS A PERCENTAGE OF GROSS 

REVENUE (%) 0% 24% 24% 18% 22%

4. LOSS AS A PERCENTAGE OF NET 

OPERATING REVENUE (%) 0% -210% -207% -153% -188%

Yield loss of % for iodomethane in Florida is based on data from Rosskopf et al 2010 a and 2010 b. 
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Table 6. Florida Cut Flowers - Lilies - Economic Impacts of Methyl Bromide Alternatives 

Florida Cut Flowers – Lilies Methyl Bromide Iodomethane + Pic

(50:50) 

YIELD LOSS (%) 0% 0%

 YIELD PER HECTARE 31,135 31,135

* PRICE PER UNIT (U.S.$) $ 10.00 $ 10.00

= GROSS REVENUE PER HECTARE (U.S.$) $ 311,353 $ 311,353

- OPERATING COSTS PER HECTARE (U.S.$) $ 259,777 $ 262,616

= NET OPERATING REVENUE PER HECTARE (U.S.$) $ 51,576 $ 48,737

1. LOSS PER HECTARE (U.S.$) $ - $ 2,839

2. LOSS PER KILOGRAM OF MEBR (U.S.$) $ - $ 6.46

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0 % 1 %

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE 

(%) 0 % 6 %

Pepper

MBTOC (TEAP 2011) recommends 5.673 tonnes for this use in 2013, provided the Party submits further 

explanation on the specific issues that have arisen for the alternatives by July 15th, 2011. If substantiation is not 

provided, MBTOC does not recommend this nomination. The USG may either support or withdraw this 

nominated sector at the OEWG. If the US proposes an increased amount, MBTOC will need to reassess the 

nomination. Of the recommended amount, 0.068 t is for the Southeast, 0.189 t is for Georgia and 5.415 t is for 

Florida.

U.S. Reply

The United States is requesting that MBTOC recommend the amount nominated for 

Georgia and Florida pepper in the U.S. Nomination for one final year (2013). 

For Georgia, the U.S. review of the available information indicates that small growers (growing 

less than 4 ha or 10 acres of this crop) need an additional year to successfully transition to the 

alternatives. These small growers do not have as much experience with the alternatives and need 

to convert their equipment to the 3-Way mixture (1,3-dichloropropene plus chloropicrin plus 

metam). The United States conducted an economic assessment of small grower’s ability to 

convert their equipment (see Table 7 below). The assessment demonstrates that despite the 3-

Way mixture being more affordable than MeBr plus chloropicrin on a per acre basis, retrofitting 

farm equipment to use the 3-Way mixture at a cost of $ 3450 (Culpepper, 2011) is not affordable 

for growers under four acres, amortized over 10 years at 7% interest (7% is a current home 

equity loan rate for this region, interest on agricultural loans could be lower). However, due to 

variations in impacts for individual growers and uncertainties in the assumptions used in this 

economic analysis, farms less than 10 acres are reasonably expected to incur negative impacts 

from having to covert to the 3-Way mixture. Based on this assessment, the amount of methyl 

bromide being requested this year will be allocated to farmers with less than 10 acres of this 

crop. Small farms of this size in Georgia are a very small subset of vegetable growers and 

account for 10 to 15% of the vegetable farms (Census of Agriculture, 2007). There are currently 

no commercial fumigation/applicators in Georgia so these applications cannot be done by 

someone else. 
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Table 7. Comparison of the Costs of Using Methyl Bromide versus the GA 3-Way on a 3, 4, 

and 10-Acre Tomato Farm in Georgia

Alternatives 3 Acre Farm 4 Acre Farm 10 Acre Farm

MeBr:Pic 3-Way Mix MeBr:Pic MeBr:Pic 3-Way Mix

Gross Revenue $ 70,830 $ 70,830 $ 94,440 $ 94,440 $ 236,101 $ 236,101 

Total Operating Costs $ 70,002 $ 69,484 $ 93,337 $ 92,646 $ 233,341 $ 231,614 

Net Revenue $ 828 $ 1,346 $ 1,104 $ 1,795 $ 2,759 $ 4,487 

Difference between Net 

Revenue Earned per 

Farm When Applying

MeBr vs. Net Revenue 

Earned When Applying 

3-Way & Accounting 

for Cost to Retrofit*

N/A $ (106) N/A $ 67 N/A $ 1,104

Notes: EPA assumes retrofitting costs of $ 3450 are amortized over a 10 year period at 7%, compounded. This 

interest rate is based on the assumption that farmers would be subject to the same interest rates as those on a 

home equity loan, which currently in Georgia for a 10-year loan are approximately 7%.

Florida surveyed several growers to find out their experience in 2010 with alternatives (see Table 

8). The survey demonstrates that some growers are still experiencing impacts when using the 

alternatives. The individuals responding to the survey describe impacts such as yield loss, cost 

increases, or longer plant back intervals when using the alternatives. Allowing the use of methyl 

bromide through 2013 will provide time for Florida growers to adapt their systems to the use of 

the alternatives (different fumigants, potentially an herbicide treatment under the tarp, longer 

plant back interval, different films, etc.). 

Table 8. Florida Survey Data on Alternatives

CROP Percent of Acres Surveyed Impact * % (range)

Eggplant 4 Not listed

Pepper 4 -9 % (0 to 20)

Tomato 28 -8 % (0 to 25)

Notes: * Impact was interpreted by respondents as yield loss, cost increase, or longer plant back intervals 

leading to missing a market window.

Strawberry fruit

After reviewing the MBTOC report (TEAP 2011), including the text of the minority report, TEAP made a 

recommendation for a reduced amount of 461.186 tonnes for strawberry fruit in California for 2013 and that the 

Party provide further substantiation of why the 70.551 tonnes (or part there of) can not use alternatives 

demonstrated by MBTOC. The amount approved is part of the nominated amount of 531.76 t by the Party. 

After TEAPs Decision, a report was written by nine members of the majority to restate their position on the 

recommendation ... - this report was not reviewed by TEAP.

U.S. Reply

The United States is requesting that MBTOC recommend the amount reflected by the 

Majority Position as nominated for California strawberry fruit in the U.S. Nomination. 
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The United States is pleased that MBTOC has agreed to the 2013 CUN for this sector, which 

reflects a 21% cut made by the United States based on the 2012 CUE approved by the Parties last 

year. However, we would like clarification why this recommendation does not appear to be 

reflected in the TEAP Progress report. Given the majority recommendation of MBTOC, the 

United States does not understand what additional information may be needed as MBTOC has 

already made its recommendation. Nonetheless, United States would like to do its best to 

address any remaining questions or concerns around the U.S. nomination. 

There are several issues the United States would like to clarify. 

ISSUE #1: The first issue is the cut to the U.S. nominated amount as recommended by the first 

minority report and TEAP. In its recommendation, TEAP (TEAP, 2011) noted that restoring the 

difference between the majority opinion of MBTOC and TEAP’s recommendation, which would 

represent an additional 13% cut beyond the 21% cut the United States has already proposed, 

would require further substantiation of the critical area not able to use the alternatives. As is

detailed later in this reply, the minority recommendation is based on incorrect math. 

The minority’s approach is based on inaccuracies in the October 2010 TEAP report. Therefore 

the minority has not calculated the correct amount for 2013. As described by the United States 

in an email of April 14 of this year, the use rate in 2012 should have been listed as 170 kg/ha

(San Martini, 2011). The United States notes that on page 15, Table 4.5 of the October 2010 

TEAP report (see below for a reproduction) it says “For California, the Party nominated 751.596 

t (4421 ha at 170 kg/ha).” But the October 2010 TEAP then contradicts itself on page 16, where 

it incorrectly states “The Party has adopted a dose rate of 196 kg MB/ha in its CUN for 2012 and 

MBTOC has accepted this.” We would like to clarify that for 2012 the U.S. nominated a use rate 

of 170 kg/ha (reflecting what was correctly stated on page 15 of the 2010 TEAP report) and that 

the parties approved 673,085 kg which at an application rate of170 kg/ha is equivalent to 3,959 

treated ha. The U.S. nominated a use rate of 175 kg/ha for use in 2011 so MBTOC would not 

have recommended a use rate of 196 kg/ha for 2012. 

Table 4.5. Final evaluation of the preplant soil use CUNs requested to be reviewed for 2012 by 

the United States after the 30th OEWG (TEAP, 2010)

California nomination in relation to current use of MB (page 15)

For California, the Party nominated 751.596 t (4421 ha at 170 kg/ha). This nominated amount was 100% of 

the previous CUE for California in 2011.

Restrictions to transition in California (page 16)

In Ventura, .... The Party has adopted a dose rate of 196 kg MB/ha in its CUN for 2012 and MBTOC has 

accepted this, although MBTOC encourages wider use of 50:50 formulations, which still allow for complying 

with regulatory restrictions on Pic use.

However, the problem of the incorrect use rate and treated hectares listed by TEAP in 2010 has 

been perpetuated again in 2011 by the minority as seen on page 157 of the May 2011 TEAP 

Progress Report. The minority incorrectly states “MBTOC’s recommendation for the 2010 

nomination for 2012 that was approved by the Parties was based on 3,434 ha at an application 

rate of 196 kg/ha.” The United States would like to make it clear that the number should be 

3,959 ha [673,085 kg / 170 kg/ha = 3,959 ha] reflecting what was correctly stated on page 15 of 

the 2010 TEAP report, as well as what was correctly noted in the 2011 TEAP report in the report 

by some members who supported the majority position (pages175-6). 
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8.5 Minority Reports (page 157 in TEAP, 2011)

The signatories of this Minority Report hold firmly to the view that the MB-treated area in 2013 should be 

calculated on the basis of the approved area in 2012, namely 3,434 ha. A 21% reduction should therefore 

result in a MB-treated area of no more than 2,713 ha in 2013, as this is 21% less than the area proposed for 

treatment in 2012 of 3,434 ha. This area of 2,713 ha would result in a recommendation by MBTOC of 

461.186 tonnes of methyl bromide at the rate of 170 kg/ha (see summary of these figures in 8-4).

Thus, using the correct starting kilogram or hectare values the calculated number would agree 

with the amount nominated by the United States:

TABLE 9

NOMINATION AMOUNT BY U.S. FOR STRAWBERRY FRUIT IN 2010 FOR USE IN 2012: 

SECTOR California Strawberry Commission 

Quantity Requested for 2011: Amount (kg) 952,543

Quantity Recommended by 

MBTOC/TEAP for 2011 :

Amount (kg) 751,596

Quantity Approved by Parties 

for 2011:

Amount (kg) 751,596

Area (ha) 4,421 

Rate 170 

Transition from 2011 Baseline 

Adjusted Value Percentage (%) 0%

Quantity Required for 

2012 Nomination:

Amount (kg) 751,596

Area (ha) 4421

Rate 170

ISSUE #2: The second issue the U.S. would like to address is the number of acres of strawberry 

fruit grown in California. During the MBTOC and U.S. bilateral in Turkey we were told that 

MBTOC uses the California Department of Pesticide Data (DPR), Pesticide Usage Report (PUR) 

to estimate strawberry acreage. During that meeting, the U.S. also pointed out that the California 

DPR database is designed to accurately track pesticide usage not crop acres and consistently 

under-reports strawberry acres thus resulting in an under-estimate of California strawberry 

production. Table 10 shows that using the MBTOC methodology as described in the 2010 

MBTOC meeting in Spain and again confirmed at the 2011 MBTOC meeting in Turkey can lead 

to an assessment that would not account for 5,469 acres or 16% of California strawberry 

production. 
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Table 10. Area by county of California strawberry fruit and percent under-reported by 

California Department of Pesticide Regulation based on California Department of Food and 

Agriculture data.

County 2011 acres

DPR underreported (%)

Acres potentially 

missing from 

MBTOC 

assessment

Monterey 10,701 7.9% 845

San Luis Obispo 2,789 28.1% 784

Santa Barbara 7,249 28.1% 2037

Santa Cruz 2,647 7.9% 209

Ventura 10,419 15.3% 1594

Total 33,805 5469

The U.S. considers the California Department of Food and Agriculture (CDFA) to be a more 

appropriate authority of estimating crop acreage than the PUR database, which is not designed to 

estimate total crop acreage. The CDFA estimates agree quite closely with the CSC estimates 

(see Table 11). By using a lower estimate of strawberry acres (from the PUR database) MBTOC 

would over-estimate the amount of acres that could be grown under the TeloneTM township cap. 

In addition it could lead to an over-estimate of the acres that could be grown with straight 

chloropicrin. 

Table 11. Comparison of California Department of Food and Agriculture and Calfornia 

Strawberry Commission strawberry acreage estimates from 2001 through 2011.

Year CSC Strawberry Acreage Estimate1 CDFA 

Estimate3 Difference Fall Summer Organic CSC Total2

2001 na Na 305 25,143 26,400 1,257 

2002 23,365 3,464 378 26,829 28,500 1,671 

2003 24,286 3,944 607 28,230 29,600 1,370 

2004 26,847 4,792 607 31,639 33,200 1,561 

2005 28,625 4,012 541 32,637 34,300 1,663 

2006 29,187 4,082 965 33,269 35,800 2,531 

2007 29,937 4,704 1,575 34,641 35,500 859 

2008 31,169 5,350 1,794 36,519 37,600 1,081 

2009 35,915 2,718 1,776 38,633 39,800 1,167 

2010 34,425 3,184 1,655 37,609 na na 

2011 34,438 2,987 1,636 37,425 na na 

Notes Information provided by the California Strawberry Commission.

1 Acreage estimates from the California Strawberry Commission's Annual survey. Fall = fall planted, Summer

= summer planted) 

2 Total = Fall acres + Summer acres 

3 CDFA acreage estimate from CDFA Annual Resource Directory : http://www.cdfa.ca.gov/statistics/ 

4 Acreage difference between CSC and CDFA estimates = CSC estimate - CDFA estimate.
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ISSUE #3: The third issue that the U.S. would like to address is the lack of research data on 

Midas TM (iodomethane plus chloropicrin) at the rates registered in California. Recent data from 

strawberry grower test plots in California (California Strawberry Commission, 2011) suggest that 

under areas of high pest pressure that Midas TM may lead to losses of 7 to 18 percent compared to 

methyl bromide (see Table 12). This grower trial was applied as broadcast treatments with 2 

replications of 5 bed plots. The Midas 33:67 treatments had a 7-18% reduction in yield 

compared to the methyl bromide and PicClor 60 controls. The grower-observed yield reduction 

may be attributed to phytotoxicity that was observed in the Midas treatments. 

Table 12. Marketable yield and difference in yield compared to methyl bromide in Oxnard 

California during the 2010-2011 season.

Treatment Marketable 

Fruit (g)

Difference from MeBr 

(%)

MeBr:Pic (50:50) 350 lb/acre 209,867 0

Midas:Pic (33:67) 200 lb/acre 194,928 -7

Midas:Pic (33:67) 250 lb/acre 171,473 -18

Midas:Pic (33:67) 300 lb/acre 180,360 -14

PicClor 60 250 lb/acre 211,183 -.6

PicClor 60 350 lb/acre 209,877 0.0

Note: 1. All three Midas treatments had significant phytotoxicity symptoms on the strawberry foliage. 

ISSUE #4: During the MBTOC and U.S. bilateral in Turkey the impact of the Midas TM 

(iodomethane plus chloropicrin) buffer requirements in California were discussed. An analysis 

was recently conducted by the California Strawberry Commission using County Agricultural 

Commissioner farm data and a GIS system to calculate buffer zone impacts on a farm-by-farm 

basis. The U.S. EPA has proposed that in California it will make the future methyl bromide

buffer equal to the currently used California buffer zones except for additional restrictions for 

difficult to evacuate sites. New labels for all fumigants, including methyl bromide, which specify 

buffer distances around fumigated fields, should be in place by 2012. This analysis was conducted 

using the “new” methyl bromide label restrictions (300 lbs of 50:50 MB:PIC: 60 feet for 5 acre 

block, 100 feet for 10 acre block and 1/8 mile for difficult to evacuate sites). The Midas analysis 

used the current California buffer zones restrictions (300 lbs of Midas 33:67 broadcast; 265 feet for 5 

acre block, 445 feet for 10 acre block and 1⁄2 mile for difficult to evacuate sites). A summary of the 

buffer zone impacts is presented (see Table 13). This analysis shows that the impacts of the new 

methyl bromide buffer zones will be minimal with only a 2% loss in acreage compared to a 30-40% 

loss with applications of methyl iodide. These buffer impacts may restrict the amount of methyl 

iodide that can be used for California strawberry fruit. 

Table 13. Estimated percentage of acres that cannot be treated due to buffer zone and 

label restrictions for methyl iodide and methyl bromide on a representative set of farms 

located within 3 miles of Salinas, CA. 

Fumigation Type

Buffer Zone Acreage That Cannot Be Treated Total Acreage 

Impacted (%) 5 Acre 

Application

10 Acre 

Application 

Difficult to 

Evacuate Site

Methyl bromide 10.0 % 2 % 2.1% 2 – 4 %

Methyl iodide 235% 40 % na 

3

35 – 40 %

Methyl iodide drip 330 % 32 % na 30 – 32 %
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Notes: 1 300 lbs 50:50 MB:PIC broadcast application (60 ft buffer for 5 acres and 100 ft buffer zones for 10 

acres). 1/8 mile buffer for difficult to evacuate sites. 

2 300 lbs 33:67 Midas broadcast application (265 ft buffer for 5 acres and 445 ft buffer for 10 acres). 1/2 mile 

buffer for difficult to evacuate site already added to each block size) 

3 Difficult to evacuate site buffer already incorporated into totals under the 5 and 10 acre application blocks. 

4 200 lbs Midas Gold drip application. 1/2 mile buffers already included. 

ISSUE #5: The final California strawberry fruit issue the U.S. would like to address is the 

disagreement between the amount of methyl bromide nominated by the U.S. and the amount the 

California Strawberry Commission thought was needed. The minority members of MBTOC 

noted in the May 2011 TEAP report (page 157): “The CSC advised MBTOC that it was “in 

dispute” with the US nomination of 531.737 tonnes, as it believed the nominated amount for 

California in 2013 should be 685.896 tonnes of methyl bromide. This larger quantity was more 

than the amount approved by the Parties for producing strawberry fruit in California in 2012.” 

The United States would like to reiterate that the official U.S. nomination for California 

strawberry fruit remains at 531,737 kg of methyl bromide.

Tomato

MBTOC (TEAP 2011) recommends an amount of 10.741 tonnes for this use in 2013, provided the Party 

submits further explanation on the specific issues that have arisen for the alternatives by July 15th, 2011. If 

substantiation is not provided, MBTOC does not recommend this nomination. The USG may either support or 

withdraw this nominated sector at the OEWG. If the US proposes an increased amount, MBTOC will need to 

reassess. Of the nominated amount, 0.1 t is for Maryland, 0.129 t for Virginia, 1.633 t for SE, 0.776 t for 

Georgia, and 8.331 t for Florida.

U.S. Reply

The United States is requesting that MBTOC recommend the amount nominated for 

Georgia and Florida tomatoes in the U.S. Nomination for one final year (2013). 

For Georgia, the U.S. review of the available information indicates that small growers (growing 

less than 4 ha or 10 acres of this crop) need an additional year to successfully transition to the 

alternatives. These small growers do not have as much experience with the alternatives and need 

to convert their equipment to the 3-Way mixture (1, 3-dichloropropene plus chloropicrin plus 

metam). The United States conducted an economic assessment of small grower’s ability to 

convert their equipment (see Table 14 below). The assessment demonstrates that despite the 3-

Way mixture being more affordable than MeBr plus chloropicrin on a per acre basis, retrofitting 

farm equipment to use the 3-Way mixture at a cost of $ 3450 (Culpepper, 2011) is not affordable 

for growers under four acres, amortized over 10 years at 7% interest (7% is a current home 

equity loan rate for this region, interest on agricultural loans could be lower). However, due to 

variations in impacts for individual growers and uncertainties in the assumptions used in this

economic analysis, farms less than 10 acres are reasonably expected to incur negative impacts 

from having to covert to the 3-Way mixture. Small farms of this size in Georgia are a very small 

subset of vegetable growers and account for 10 to 15% of the vegetable farms (Census of 

Agriculture, 2007). There are currently no commercial fumigation/applicators in Georgia so 

these applications cannot be done by someone else. 
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Table 14. Comparison of the Costs of Using Methyl Bromide versus the GA 3-Way on a 3, 

4, and 10-Acre Tomato Farm in Georgia

Alternatives 3 Acre Farm 4 Acre Farm 10 Acre Farm

MeBr:Pic 3-Way Mix MeBr:Pic 3-Way Mix MeBr:Pic 3-Way Mix

Gross Revenue $ 70,830 $ 70,830 $ 94,440 $ 94,440 $ 236,101 $ 236,101 

Total Operating Costs $ 70,002 $ 69,484 $ 93,337 $ 92,646 $ 233,341 $ 231,614 

Net Revenue $ 828 $ 1,346 $ 1,104 $ 1,795 $ 2,759 $ 4,487 

Difference between Net 

Revenue Earned per 

Farm When Applying

MeBr vs. Net Revenue 

Earned When Applying 

3-Way & Accounting 

for Cost to Retrofit*

N/A $ (106) N/A $ 67 N/A $ 1,104

Notes: EPA assumes retrofitting costs of $ 3450 are amortized over a 10 year period at 7%, compounded. This 

interest rate is based on the assumption that farmers would be subject to the same interest rates as those on a 

home equity loan, which currently in Georgia for a 10-year loan are approximately 7%.

Florida surveyed several growers to find out their experience in 2010 with alternatives (see Table 

15). The survey demonstrates that some growers are still experiencing impacts when using the 

alternatives. The individuals responding to the survey describe impacts such as yield loss, cost 

increases, or longer plant back intervals when using the alternatives. Allowing the use of methyl 

bromide through 2013 will provide time for Florida growers to adapt their systems to the use of 

the alternatives (different fumigants, potentially an herbicide treatment under the tarp, longer 

plant back interval, different films, etc.). 

Table 15. Florida Survey Data on Alternatives

CROP Percent of Acres Surveyed Impact * % (range)

Eggplant 4 Not listed

Pepper 4 -9 % (0 to 20)

Tomato 28 -8 % (0 to 25)

Notes: * Impact was interpreted by respondents as yield loss, cost increase, or longer plant back intervals

leading to missing a market window.

Dried Meat Products

MBTOC (TEAP 2011) is unable to assess this CUN pending the receipt of the results of large scale trials to be 

conducted in spring and summer of 2011 and 2010. The Party had nominated 3.730 tonnes, the amount 

nominated by the Party, for use in cured pork sector in 2013. This is the same amount granted by the Parties for 

this use in 2012. 

U.S. Reply

The United States is requesting that MBTOC recommend the amount nominated for dried 

meat products in the U.S. Nomination. 
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The first large-scale tests for dried meat products took place in May of 2011. In order to control 

for temperature and weather the next tests are scheduled for September and October of 2011 

(once it cools down) (Schilling and Phillips, 2011). The data from those trials should be 

available in November or December of 2011. The researchers need replicated experiments 

(May, September, and October) before the statistical analysis can be run. If phosphine works in 

multiple commercial settings for more than one season the United States believes that it will take 

at least 2 years to develop the logistical and practical use in the dried meat industry to ensure the 

widespread adoption of phosphine in the industry. 

Large-scale testing was not conducted in 2010 because additional testing was needed in the 

laboratory to determine if greater concentrations of phosphine were needed to kill larger sample 

populations of ham mites at all life stages (Schilling and Phillips, 2011). The United States

submitted the results of the 2010 studies with our nomination package submitted in January 

2011. Studies so far suggest that concentrations would need to be above 1000 ppm for exposure 

times longer than 48 hours for studies that are conducted in commercial settings. 

CITATIONS

California Strawberry Commission. June 2, 2011. Communication.

Culpepper, S. April 1, 2011. Personal communication on Georgia fumigation costs. 

Rosskopf, E.N., N. Kokalis-Burelle, E. Nissen, O. Nissen, R. Hartman, R. McSorley, E. Skvarch, 

T.J. Swaford, C. Owens, S. Brooks, and K. Register. 2010 a. Evaluation of currently 

available alternatives to methyl bromide for ornamental crop production in Florida. 

Proceedings of the Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions. 

http://mbao.org/2010/082RosskopfAreawideOrnamental..pdf

Rosskopf, E.N., N. Kokalis-Burelle, D.M. Butler, J. Holzinger, S. Fennimore. 2010 b. Evalution 

of steam for nematode and weed control in cut flower production inFlorida. Proceedings 

of the Annual International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions. Available at http://mbao.org/2010/083RosskopfSteam.pdf

Schilling, W. and T. Phillips. June 24, 2011. Personal communication on dried meat research. 

SanMartini, F. April 14, 2011. Email entitled U.S. Reply to MBTOC Soils Questions sent to 

Porter, I. and Besri, M. 

TEAP (2010). Report of the Technology and Economic Assessment Panel, Oct. 2010. Montreal 

Protocol on Substances that Deplete the Ozone Layer, United Nations Environment 

Programme, Nairobi.
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TEAP (2011) Report of the Technology and Economic Assessment Panel, May 2011. Vol 1, 

Progress Report. Montreal Protocol on Substances that Deplete the Ozone Layer, United 

Nations Environment Programme, Nairobi.

U.S. Department of Agriculture. 2007. Census of Agriculture 2007. Accessed June 2011 and 

available at http://www.agcensus.usda.gov/