NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 SOIL PEPPERS Open Field

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Peppers Grown in Open Fields (Submitted in 2010 for 2012 Use Season)

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

QUANTITY OF METHYL BROMIDE REQUESTED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION

Year N OMINATION A MOUNT (K ILOGRAMS )

2012 28,366 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 critic al 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 exem ption for 2005 and/or 2 006 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.

US A CUN12 SOIL Peppers Open Field Page 1 of 15CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

C ontact/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 PEPPERS Open Field 15

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming convention see notes above) No. of kilobytes Date sent to Ozone
Secretariat

USA CUN12 SOIL PEPPERS OPEN FIELD

* Identical to paper documents

US A CUN12 SOIL Peppers Open Field Page 2 of 15

### METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT)

PEPPERS

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

This renomination covers only peppers grown in the southeastern US, Georgia, Florida,. These crops generally are grown in open fields on plasti c tarps, often followed by various other crops.
Harvest is destined for the fresh market.

Only areas that cannot use altern ative fumigants or non-fumigant options have been included in
the calculation of nominated amounts and area to be treated. The applicants’ requests have also been adjusted downward to account for the lo wer methyl bromide dose rates (see BUNNIE in Appendix A) for the southern regions of US pepper production, since increased use of high barrier films in conjunction with lowe r rates has been reported there.

The USG has reviewed all factor s affecting transition rates in this sector. Based on this assessment the transition rate has been greatly incr eased 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 nomi nated 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 examin ed 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. Un fortunately none of th e studies located by the
USG met the criteria that earlier cited studies di d. These criteria include : the use of fumigant alternatives registered for the crop nominated, the presence of both a methyl bromide standard
and an untreated control as treatments as well as the monitoring of yields under each treatment. Several such studies included a methyl bromide tr eatment or an untreated control but not both, or included both but did not monitor yield, or includ ed 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 chlo ropicrin followed by metam-sodium) did meet these criteria, Therefore, nominations for the so uthern US areas were adjusted to reflect the apparent technical feasibility of this three way combination of alternative fumigants under VIF or metallized films, as a replacement for spring-time appli cations of methyl bromide+chloropicrin, after accounting for areas in the south that face prohibition of 1,3-D due to the presence of karst topographical features.

The recent renewal of the federal registration of iodomethane, along with its registration at the state level in all the pepper producing regions co vered by this nomination, will be factored into
calculations of the total amount of methyl bromide being reques ted for peppers. This calculation
takes into account the issue that time will be needed for the indus try to transition to the use of
this material in areas where it is feasible. Th is transition is part of the BUNNIE included in Appendix A.

US A CUN12 SOIL Peppers Open Field Page 3 of 152. SUMMARIZE WHY KEY ALTER NATIVES ARE NOT FEASIBLE

The U.S. nomination is only for those areas where the alternatives are not suitable. In U.S. pepper production there are several factors that make the potential alternatives to methyl bromide
unsuitable. These include:

- Pest control efficacy of alternat ives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/or economically infeasible for use in pepper production.

- Geographic distribution of key ta rget pests: i.e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the U.S. is only nominating a CUE for peppers where the key pest pressure is moderate to high such as nutsedge in the Southeastern U.S.

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

- Infeasibility of fall-season fumigation in the so utheastern US, even with the best available combination of alternatives (1,3 D followed by chloropicrin followed by metam-sodium).

- There are significant restrictions on which cr ops can be rotated th rough after use of a given alternative (e.g., halosulf uron 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, preven t use of this alternative as a post-emergent weed control in those regions).

Florida, Georgia, and the Southeas tern U.S. (outside Florida and Georgia) are each presented as separate regions in this nomina tion to reflect the separate appl ications from growers in these areas. In this nomination, th e Southeastern U.S. includes the following states: Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, and Virginia. A brief description of their need fo r methyl bromide follows, also presented on a regional basis.

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a certific ation standard for peppe r vegetable production.

4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE,
INDICATE THE REASON WH Y METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTER NATIVE STRATEGIES ARE USED TO
CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL
BROMIDE THERE.

In southeastern U.S., Florida, and Georgia, ar eas not treated have low levels of nutsedge or nematodes in pepper fields

US A CUN12 SOIL Peppers Open Field Page 4 of 155. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO
COVER AT LEAST PART OF THE CRO P THAT HAS REQUESTED USE OF
METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE
THIS?

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

The USG has reviewed all factor s affecting transition rates in this sector. Based on this assessment the transition rate has been greatly incr eased 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 nomi nated amounts of methyl bromide based only on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate.

6. SUMMARY OF RECENT RESEARCH

As mentioned earlier in this document, iodomet hane formulated with chloropicrin has shown good efficacy against key pepper pests, including nutsedge, in a number of trials with peppers and related vegetables such as tomatoes (e.g., Louws et al. 2006, Culpepper 2006, 2007, 2008, Culpepper et al. 2008, Olsen 2008). Iodomethane ha d time limitations removed from its federal label in October, 2008, and has re ceived state-level approval in 47 US states (California, Washington, and New York are the exceptions at this time). However, other important
constraints must be considered when assessi ng the feasibility of iodomethane as a methyl bromide alternative. These include: (1) the cost of iodomethane formulations is higher than methyl bromide, and will probably remain so for the next several years, (2) growers and
researchers will need time to evaluate iodometha ne use in the various local production conditions covered by this nominations, and (3) growers and applicators will need to make some equipment modifications to adapt to the lower flow ra tes typical with less expensive iodomethane application rates and to avoid the corrosion of some metals that can occur with iodomethane (Sumner 2005, Noling et al. 2006). The economic impact of using iodomethane is further described in Part E of this document (below). A consideration of these aspects has led the USG to conclude that while iodomethane appears to be technically feasible to manage key pepper pests in all parts of the US where it has been registered, time will be needed for growers and extension service experts to adapt its use successf ully. Therefore, the amount of methyl bromide nominated for peppers has been adjusted downwar d while also considering the time needed to
transition to iodomethane.

In the short term, and in situations where pepper producers cannot use iodomethane, the USG concludes that other fumigant alternatives to methyl bromide woul d have to be used. The details of this conclusion are similar to the previous year’s pepper CUN, and are further discussed
below.

Narrative description of studies rel evant to key weeds and nematodes

For nutsedge pests, which are widespread in all requesting regions, pepper growers do not currently have technically feasible alternativ es to methyl bromide use at planting. Metamsodium and 1,3 D + chloropicrin have shown some e fficacy in small-plot trials in other vegetable

US A CUN12 SOIL Peppers Open Field Page 5 of 15crops (e.g, tomato). However, at best, metam s odium 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 fact ors suggest that even th is 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 isot hiocyanate levels decline more rapidly, thus further compromising efficacy, in areas where th ese 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 disulfid e) are currently unreg istered for peppers,

In one recent study, Culpepper and Langston (2004) conducted studies at 2 sites in spring 2003
and one site in the fall season of 2004. Pl ot sizes were 20 feet X 32 inches (4.94 m 2 ). Treatments were: Methyl bromide standard (6 7:33 formulation), untreated control, 2 formulations of Telone (1,3 D + chloropicrin ) at various doses, followed by an additional application of either chloropicr in 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 herbicid e treatment (clomazone + halosu lfuron) later in the season.

Some important caveats must be men tioned 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 nu tsedge is dominant will be controlled as effectively. A number of other studies have indicated that purple nutsedge is a hardier species, and ev en in Culpepper and Langston’s study, it appeared more resistant to the methyl bromide alternativ es. For example, iodomethane gave “77 % control” of yellow nutsedge, but only “37 % c ontrol” of purple nutsedge . Control in this case was apparently defined as the reduction in nutsedge pop ulations as compared to populations in the un treated control.

Another recent study of methyl bromide altern atives involving key weed pests was done by Gilreath et al. 2005 (Crop Prot ( 24): 903-908). One of 3 tria ls in that study showed an average of 30 % lower bell pepper yields with nutsedge and nematodes as the ke y pests present. In the other 2 trials yields were not significantly different across different fu migant treatments, but nutsedge pressure was lower in those trials as compared to the third. Other impor tant caveats to these results are - this was a small-plot study and wa s 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, se veral other recent studi es conducted in the production circumstances of the southeastern US ha ve examined several fumigant alternatives to methyl bromide, most done in crops other than peppers (e.g., Santos et al. 2006, Candole et al. 2007, Santos and Gilreath 2007, Gilreath and Sant os 2005, 2007). These studies either focused solely on nutsedge weeds or a combination of nutsedges, diseases, and nematodes. However,

US A CUN12 SOIL Peppers Open Field Page 6 of 15USG has examined these papers and concludes that for peppers, these studies do not meet all the
criteria that allowed the use of earlier studies in estimating yi eld and quality losses that may occur if such methyl bromide alternatives are us ed as direct replacements for methyl bromide.

These criteria are: the use of fumigant altern atives registered for the crop nominated, the presence of both a methyl bromid e standard and an untreated cont rol as treatments as well as the monitoring of yields under each treatment. Seve ral 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, chlor opicrin, herbicides, or combinations thereof, they cannot yet be used to alter yield estimates

.

Therefore, for this nomination, the USG conc ludes that, for pepper growers who can only use either 1,3-D + chloropicrin or metam-sodium+chl oropicrin in fall-season fumigations to control nutsedge and nematode pests, the yield loss estimates used in last year’s nomination continue to be applicable. These loss estimates are illustrated in Table 2 below, and are used as the basis of part of the economic assessment in the following section.

T ABLE 2. DATA ON YIELD LOSSES WITH LIKELY ME THYL BROMIDE ALTERNATIVES AND NUTSEDGE

PRESENT AS A CROP PEST

.

Chemicals Rate (kg/ha) Average Nutsedge Density (#/m 2 ) Average

Marketable
Yield (ton/ha) % Yield Loss (compared to MB)

Untreated (control)
- 300 ab 20.1 a 59.1 methyl bromide + Pic(67-33), chiselinjected 390 kg 90 c 49.1 b

---

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

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

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

Locascio et al. 1997.

Recent studies that are useful (within the cont ext of this nomination) in assessing technical feasibility of a combination of methyl bromide al ternatives 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-wa y, 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 Culpeppe r et al. have. An example of the results obtained

US A CUN12 SOIL Peppers Open Field Page 7 of 15in spring fumigation with this combination in peppe rs is presented in the table below. Also see several research reports available fr om the University of Georgia at www.gaweed.com ).

T ABLE 3. N UMBER OF P EPPER F RUIT

- M ETHYL B ROMIDE : C HLOROPICRIN V ERSUS T HREE W AY C OMBINATION

. S PRING 2006
Fruit Size Methyl Bromide : Chloropicrin (# of Fruit) UGA 3 way 1,3-D fb chloropicrin fb

metam Na
Jumbo 30 b 125 a X-Large 219 a 237 a Large 153 a 143 a Chopper 217 a 252 a
Cull 11 a 9 a Jumbo + X-Large + Large 402 b 505 a Footnote: Culpepper 2006. fb means followed by or a sequential treatment. Plots were 3 rows by 100 feet long.

Since Georgia is similar to other areas of the southeastern US, except Maryland/Delaware peppers which face a different key pest ( F. oxysporum niveum ), these results should be applicable to spring usage of methyl bromide in these regi ons. However, other results thus far
indicate that summer / fall fumigation is not similarly eff ective 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 vegeta ble production. In this experiment , fields were fumigated during for fall-season crop production on July 17 2007. So il temperature was 84 degrees at 8 inches. The experiment consisted of 4 fumigant treatment s (Table 4) that were replicated three times. Even under high-barrier film (“Blockade”), th e ‘UGA 3 way’ gave less control of purple nutsedge as compared to the methyl bromide sta ndard under the same type of film. Yields were consistently lower with the ‘ UGA 3 way’ as well, with a roughly 50 % reduction in both number and weight of harvested vegetables (Table 4). The economic im plications of this level of yield loss for Georgia pepper growers are fu rther described in section 7, below.

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

Fumigant Mulch Late-season purple nutsedge

control Harvests 1-2 (Jumbo pepper) Harvests 1-4 (Jumbo pepper)

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

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

US A CUN12 SOIL Peppers Open Field Page 8 of 15Methyl
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. Rate s as shown are not planting bed-strip ad justed. (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 ev en the technical feasibil ity of the ‘UGA 3 way’ use in spring fumigations. Growers must make se veral application modifications to properly use the approach, and this may incur significant capita l expenditure. Culpepper et al. estimate their
costs to do this for their research trials at about $ 15,000 (Culpepper et al. 2007b). Application
costs will also increase as more chemicals and runs of tractor equipment are required to conduct the ‘UGA 3 way’, and the cost of VIF or metalliz ed 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 ex ample of this issue is i llustrated in recent work by Chellemi et al. (2008). These researchers ev aluated the ‘UGA 3 way’ in on-farm tests in Florida peppers. Results of four trials were highly variable, with two showing better yields than the methyl bromide standard, and two showing wors e results. All four tr ials showed a reduction in larger (more profitable) pe ppers in the ‘UGA 3 way’ as compared to the methyl bromide standard. The cause appeared to be an overload of potassium in the soil, created by the combined use of the metam-potassium in the ‘UGA 3 way’ and the growers’ standa rd practice of applying a high-potassium fertilizer.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

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

Reader, please note that in this study net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct losses of income that may be experienced by the
users. It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitabili ty of an operation of an enterp rise, is gross revenue minus the sum of operating and fixed costs. Net income s hould be smaller than the net revenue measured in this study. We did not include fixed costs because these costs are often difficult to measure and verify.

Summary of Economic Feasibility

The economic analysis of pepper applications co mpared data on the yields, crop prices, revenues and costs of using methyl bromide or alternative pest control regimens. This was done in order to

US A CUN12 SOIL Peppers Open Field Page 9 of 15US A CUN12 SOIL Peppers Open Field Page 10 of 15 estimate impacts on pepper growers with the decr easing availability of methyl bromide. The
alternatives identified as technically feasible (in cases of low pest infestation 1 ) for Georgia, Florida, and the Southeaster U.S. for peppers are: (a) Iodomethane a nd (b) the Georgia 3-Way Method, which includes 1,3-dichlo ropicrin with chloropicrin followed by metam sodium.

The economic reviewers then analyzed crop budgets for pre-plant sectors to determine the likely economic impact if methyl bromide were unavailab le. 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 meas ure, at least over some unit, e.g. , a hectare of land or a storage operation. However, high value commodities or cr ops may provide high revenues but may also entail high costs. Losses of even a small per centage 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 ma rgin 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 di fficult, therefore fixed costs were not included in the analysis.

These measures represent different ways to a ssess the economic feasibili ty of methyl bromide alternatives for methyl bromide users, who are pepper producers in this case. Because producers (suppliers) represent an integral part of any defi nition of a market, we in terpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using methyl bromide. The economic measures provide the basis for making that determination.

GEORGIA, FLORIDA, AND THE SOUTHEASTERN U. S.

In Georgia, Florida, and the Southeastern U.S., the Georgia 3-Way on spring plantings and iodomethane are considered technically and eco nomically feasible alternatives to methyl bromide, although some limitations exist. Referri ng to Table 5, 6, and 7, the loss of net revenue

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.using the Georgia 3-Way is negligible in Florid a and the Southeastern U.S. in comparison to methyl bromide, while gains in net revenue are expected in Georgia. Although no gains in gross revenue are expected when using iodomethane, losses in net revenue are negligible. One drawback to the Georgia 3-Way is that yield losses are expected in fall pl antings, with studies in Georgia’s application show a 50% yield loss. These losses are not expected when iodomethane is used. The Georgia 3-Way also cannot be used on pe ppers that are grown in karst soils since it contains 1,3-D; however, iodomethane can be, making methyl bromide unnecessary for pepper production in areas with karst topography. Note th at data describing Georgia and Florida pepper production are based on double crop ping production practices.

T ABLE 5. G EORGIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA PEPPER METHYL
BROMIDE GEORGIA 3-
WAY: SPRING
APPLICATION GEORGIA 3-
WAY: FALL
APPLICATION IODOMETHANE

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

PRODUCTION PER
HECTARE 5,797 5,797 2,899 5,797 * PRICE PER UNIT (US$) $12 $12 $12 $12

= GROSS REVENUE PER HECTARE (US$) $67,907 $67,907 $33,954 $67,907

- OPERATING COST PER HECTARE (US$) $55,279 $41,211 $41,211 $56,433

= NET REVENUE PER HECTARE (US$) $12,629 $26,696 -$7,258 $11,475

LOSS MEASURES *

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

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 -$151 $214 $12

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -21% 29% 2%

4. LOSS AS A PERCENTAGE OF
NET OPERATING REVENUE (%) 0% -111% 157% 9%

5. OPERATING PROFIT MARGIN (%) 19% 39% -21% 17% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

T ABLE 6. F LORIDA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA PEPPER-DOUBLE CROP METHYL
BROMIDE GEORGIA 3-
WAY IODOMETHANE

PRODUCTION LOSS (%) 0% 0% 0%

PRODUCTION PER HECTARE 4,379 4,379 4,379 * PRICE PER UNIT (US$) $12 $12 $12

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

- OPERATING COST PER HECTARE (US$) $48,934 $49,030 $49,522 = NET REVENUE PER HECTARE (US$) $2,822 $2,726 $2,234

LOSS MEASURES *

US A CUN12 SOIL Peppers Open Field Page 11 of 151. LOSS PER HECTARE (US$) $0 $96 $588

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $6

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 3% 21% 5. OPERATING PROFIT MARGIN (%) 5% 5% 4% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

T ABLE 7. S OUTHEASTERN USA ( EXCEPT G EORGIA ): E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES SOUTHEASTERN USA (EXCEPT GEORGIA)

PEPPER METHYL
BROMIDE GEORGIA 3-
WAY IODOMETHANE

PRODUCTION LOSS (%) 0% 0% 0%

PRODUCTION PER HECTARE 2,965 2,965 2,965 * PRICE PER UNIT (US$) $8 $8 $8 = GROSS REVENUE PER HECTARE (US$) $24,463 $24,463 $24,463 - OPERATING COST PER HECTARE (US$) $21,955 $22,051 $22,543 = NET REVENUE PER HECTARE (US$) $2,508 $2,412 $1,920

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

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $6

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 0% 2%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 4% 23%
5. OPERATING PROFIT MARGIN (%) 10% 10% 8% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

US A CUN12 SOIL Peppers Open Field Page 12 of 158. RESULTANT CHANGES TO RE QUESTED EXEMPTION QUANTITIES

The USG has applied an aggressi ve transition rate, which is re flected in the nomination amount
and detailed in Table 8.

TABLE 8. N OMINATION A MOUNT :



### CITATIONS

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