USA CUN14 SOIL Strawberry Fruit Open Field Page 1 of 15

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN14 SOIL STRAWBERRY FRUIT Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Strawberry Fruit Grown in 

Open Fields (Submitted in 2012 for the 2014 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Strawberry Fruit Open Field

QUANTITY OF METHYL BROMIDE NOMINATED:

TABLE 1: QUANTITY OF METHYL NOMINATED

Year NOMINATION AMOUNT 

2014 415,067 kg

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

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

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 CUN14 SOIL Strawberry Fruit Open Field Page 2 of 15

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger

Title: Director

Address: Biological and Economic Analysis Division

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W. Mailcode 7503P

Washington, D.C. 20460

U.S.A.

Telephone: (703) 308-8200

Fax: (703) 308-7042

E-mail: Housenger.Jack@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE:

1. PAPER DOCUMENTS: 

Title of paper documents and appendices

No. of pages Date sent to Ozone 

Secretariat

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 CUN14 SOIL STRAWBERRY FRUIT

* Identical to paper documents
USA CUN14 SOIL Strawberry Fruit Open Field Page 3 of 15

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT)

STRAWBERRY FRUIT

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

This nomination is for the critical use of methyl bromide for the production of strawberries in 

California (Table 1). Use of methyl bromide has been reduced over the years. For many

production areas, use of 1,3-D/chloropicrin formulations with low permeable tarps and standard 

cultural practices (e.g. such as crop rotation, cover crop, cultivar selection, etc.) are effective for 

managing an array of pests with comparable yields compared to methyl bromide (e.g., 

Fennimore and Ajwa, 2011). An economic analysis (see Tables 3 and 4) indicates fumiganttreated soils can result in gains or losses to net revenue that range from +10% (with Pic-Clor 60

(1,3-dichloropropene with chloropicrin)) to -9% (with methyl iodide/chloropicrin), based on the 

cost of the individual fumigant. 

California growers have a critical need for methyl bromide to treat fields where the primary 

alternative, 1,3-D/chloropicrin, cannot be used due to township caps restricting the total amount 

of 1,3-D that can be used (Fennimore and Ajwa, 2011) or where diseases caused by 

Macrophomina and Fusarium cannot be managed effectively (Ajwa, personal communication, 

email 11/7/11). Methyl iodide (iodomethane, Midas®) was registered in California in December 

2010. To date, it has only been used on a few acres throughout California and only a few of 

those acres have been for strawberry production. This is likely due to cost concerns and to fear 

by growers that the public will perceive that the methyl iodide fumigation is unsafe and that 

strawberries are unsafe if they have been produced on methyl iodide-treated land. 

The U.S. Government (USG) has reviewed all factors preventing the transition away from the 

use of methyl bromide in this sector. This assessment determines, the amount nominated for this 

sector. For the area covered in this nomination, the USG believes that the narrative discussion 

included in this document is accurate. 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.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

1,3-D/Chloropicrin Treatments

Efficacy and yield with 1,3-D formulations has been shown to be comparable to methyl bromide

where maximum label rates are permitted. Regulatory restrictions may reduce the overall 

adoption of 1,3-D or chloropicrin treatments to strawberry production land (Fennimore and 

Ajwa, 2011). However, methods being studied such as use of totally impermeable films (e.g., 

Fennimore and Ajwa, 2011) and low permeable films with carbonation (in Florida) of 1,3-

D/chloropicrin formulations (e.g., Thomas et al., 2011b) can reduce the use rate of 1,3-D while 

providing acceptable yields and pest management allowing for more hectares to be treated with 

the same amount of 1,3-D.
USA CUN14 SOIL Strawberry Fruit Open Field Page 4 of 15

California extension specialists have observed that some fields with a history of non-methyl 

bromide fumigant use have become infested with Macrophomina and Fusarium pathogens

(Koike, 2008). Anecdotal information has indicated that the disease has not occurred in fields 

routinely treated with methyl bromide. Such fields may require methyl bromide to “clean-up” 

those areas. Preliminary field trials have indicated that 1,3-D provides comparable efficacy and 

yield to methyl bromide treatments. Those studies compared drip application of 1,3-D and 

methyl bromide and it is unclear if this application method provides commercially acceptable

yields (see the following section). Further research is planned on the effectiveness of broadcast 

application of 1,3-D on Macrophomina and Fusarium, as well as the use of carbonation, totally 

impermeable films, and other alternatives, including non-fumigant measures. 

Shank vs. Drip Application Methods

Drip irrigation of 1,3-D may not successfully manage Macrophomina and Fusarium (Ajwa, 

personal communication, email 11/7/11). According to Ajwa, growers in Ventura and Oxnard 

are shifting back to shank fumigation with methyl bromide/chloropicrin because drip fumigation 

did not control Macrophomina and Fusarium. In Ventura/Oxnard, drip fumigation dropped from 

55% of the acreage in 2009 to 30% in 2010. In 2011, drip fumigation was used on less than 25% 

of the strawberry acreage. One researcher was unable to find any grower with whom he could 

set up drip research in 2011. In 2008, for all California strawberry land, over 55% used drip 

irrigation (UC Pest Management Guidelines, 2008). No information was provided concerning 

the efficacy of shank applied 1,3-D in comparison to methyl bromide. In Florida, shank-applied 

1,3-D (as Telone® C35) provided significantly greater yields compared to methyl bromide shank 

fumigation (Noling and Cody, 2011). Further research should be able to validate these findings 

for California conditions.

Methyl Iodide Treatments

Methyl iodide is registered in California and could help to relieve township cap overages of 1,3-

D. While California currently requires a larger buffer zone than for methyl bromide, the federal 

buffer zones will increase for most fumigants beginning in 2013. Research with methyl iodide

generally indicates acceptable efficacy and yields compared to grower standards, and has shown 

good results at rates 40% lower than methyl bromide (e.g., Othman et al., 2011). 

However, methyl iodide cannot be a viable replacement for methyl bromide or alleviate 1,3-D 

township caps unless it is actually used by growers as a soil treatment. As of this writing, methyl 

iodide has been used commercially on a very few hectares of strawberry in California. There are 

two likely explanations for its lack of adoption in spite of what field trials indicate is an effective 

fumigant. The cost of methyl iodide is first possible explanation. Methyl iodide is more 

expensive than methyl bromide when used to treat infested fields at a rate considered effective

(300 lb, 67/33 formulation). However, many areas may not require such high rates. For those 

areas, the cost of methyl iodide at lower rates (200 lb, 67/33 formulation) appears to be 

comparable in both cost and efficacy to methyl bromide (used at higher rates) and other

alternatives, including 1,3-D/chloropicrin. 

The second explanation for the lack of adoption of methyl iodide is a campaign by some groups 

to question the safety of methyl iodide. A letter from 38 members of the California Assembly to 
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EPA Administrator Jackson and then Assistant Administrator Owens urged the suspension of the 

registration for methyl iodide pending a review of its safety

(http://www.panna.org/sites/default/files/Monning%20Letter%20to%20USEPA%20re_%20regis

tration%20of%20methyl%20iodide.pdf, April 4, 2011; CA Assembly Letter, 2011). 

A “Safe Strawberry” campaign addressed to retail food outlets has suggested that consumers will 

be wary of buying fruit from their stores if it has been grown on soil fumigated with methyl 

iodide. For example, Californians for Pesticide Reform attached a survey to Raley’s Family of 

Fine Stores suggesting that the manager “document Raley’s progress towards offering your 

customers Safe Strawberries by filling out the enclosed survey...” (Letter from CPR to Mr. John 

Holder, Produce Manager, July 20, 2011). A local branch of Planned Parenthood issued “its 

first-ever environmental action alert” urging its members to call the governor of California to ban 

methyl iodide (Rubin, 2011). 

As a result of these efforts, according to the CSC, growers who might have been willing to use

methyl iodide for pest management are not willing to use it in the current political climate and

risk the perception that their fruit is “tainted”. 

Steam Treatments

Steam appears to have the potential to be an effective soil treatment (Fennimore et al., 2011b)

and has potential to replace methyl bromide for sensitive areas, such as buffer zones near schools 

and houses. Currently steam treating soil is a slow process. Technologies adapted to strawberry 

production are being examined and revised. Steam application by traditional pipe and hose 

methods are expensive. Blending soil with steam improves heat distribution in the soil. Use of 

steam in substrate production may allow recycling of substrate, which would save on costs. 

Automatic steam systems should be more cost-effective. The addition of mustard seed meal may 

increase steam efficiency. Future work will attempt to maximize applicator efficiency (e.g., 

Fennimore et al., 2011d). 

Anaerobic Soil Disinfestation (ASD) Treatments

ASD has been successfully implemented by organic vegetable producers in Florida (Rosskopf et 

al., 2011) and is being investigated for strawberry production in Florida and California. ASD 

research (e.g., Shennan et al., 2011; Daugovish et al., 2011b; Shennan et al., 2010) has shown 

consistently good Verticillium dahliae suppression and yields comparable to methyl bromide 

treatments and other chemical fumigants. What is yet to be determined through additional 

research is 1) whether ASD will acceptably manage Macrophomina and Fusarium, 2) whether it 

can be used on full-field production acreage, and 3) whether it is an economically feasible 

treatment. Currently, some costs may be higher for ASD due to apparently lower yields than the 

methyl bromide standard (Klonsky et al., 2011). Results in Florida indicate that solarization may 

have to be combined with ASD for acceptable weed control where high infestation is likely 

(Rosskopf et al., 2011). USDA is currently funding studies on ASD to answer these questions

(e.g., Butler et al., 2011; Louws et al., 2011).

Resistant Cultivars

Some breeding lines show resistance to Macrophomina or Fusarium (Daugovish et al., 2011a). 

Some available cultivars appear to exhibit negative cross-resistance—Chandler, Seascape, 
USA CUN14 SOIL Strawberry Fruit Open Field Page 6 of 15

Monterey, San Andreas, and Ventana are resistant to one pathogen, but susceptible to the other. 

Drip-applied fumigants that were tested on the Camarosa cultivar (including methyl bromide, 

methyl iodide, chloropicrin—high and low rates, and Pic-Clor 60) resulted in comparable yields

in the presence of Macrophomina; the untreated control had a 28% reduced yield in comparison.

Substrate System

Research into amending soil in beds or using non-soil substrates may be both biologically and 

economically feasible as production systems are developed (Fennimore et al., 2011a; Fennimore 

et al., 2011c). Results of the latest research (Thomas et al., 2011a) indicate advantages include 

1) starting with disease-free growing media, 2) efficient management of water, nutrients, and 

runoff, and 3) yields competitive with grower standards. Currently, however, the process is labor 

intensive, there is a complex fertigation system, and high costs associated with non-soil 

substrates, growers must adopt a different 4 row bed system (instead of 2 row system), and 

adjustments must be made to fertilizer injectors and other equipment. Research is continuing to 

try to reduce costs and scale-up for commercial use.

Dimethyl Disulfide (DMDS)

DMDS is registered for use in strawberries, although not in California. Consequently, it is not a 

viable alternative to methyl bromide for consideration. For areas with a DMDS registration, it 

appears to offer comparable yields and pest management options compared to methyl bromide 

(e.g., Othman et al., 2011; Noling, 2010; Freeman and McAvoy, 2011).

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

There is no certification standard for strawberry fruit production.

4. PROPORTION OF CROP USING METHYL BROMIDE 

TABLE 2. PROPORTION OF CROP USING METHYL BROMIDE AS A CRITICAL USE

REGION WHERE METHYL 

BROMIDE USE IS REQUESTED

TOTAL CROP 

AREA1(HA)

AREA NOMINATED2FOR 

METHYL BROMIDE USE 

IN 2014 (HA)

PROPORTION OF TOTAL 

CROP AREA TO BE 

TREATED WITH CUE

METHYL BROMIDE (%)

California 15,116 2442 16

1 California Strawberry Commission Estimate (http://www.calstrawberry.com/commission/asurvey.asp)

2 Based on the amount of methyl bromide nominated for the 2014 use season for strawberry fruit production.

5. 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.

There still remains production land that is unable to be treated with 1,3-D due to township cap 

restrictions. Chloropicrin also has county restrictions. Currently, 1,3-D with chloropicrin is the 
USA CUN14 SOIL Strawberry Fruit Open Field Page 7 of 15

most feasible alternative to methyl bromide. However, where township cap restrictions limit the 

use of 1,3D, other chemical fumigants such as methyl iodide with chloropicrin and chloropicrin 

alone are available for land where other regulatory restrictions do not limit their use (e.g., caps 

on maximum use rate or buffer restrictions). Non-chemical methods that are being examined 

appear to offer great possibilities including ASD, steam, and non-soil substrates. These have not 

been tested on a commercial-scale as of yet. In addition, to manage diseases caused by 

Macrophomina and Fusarium, breeding efforts are underway to identify lines that show 

resistance to both pathogens.

Research has indicated that with the use of totally impermeable films, drip-applied 1,3-

D/chloropicrin formulations (Telone C-35 with 63% 1,3-D) at 200 lb per acre (225 kg per ha) is 

as effective in terms of yield and weed control as a standard methyl bromide treatment 

(Fennimore and Ajwa, 2011). This can lower the amount of 1,3-D by 33% below the rate 

typically used with standard films and, therefore, may result in reducing the burden of caps that 

restrict the overall amount of 1,3-D used in a township. Pic-Clor 60 is formulated with lower 

rates of 1,3-D (39% 1,3-D) and has been effective in field trials, but chloropicrin restrictions are 

also in place in some counties and reduce its use. These research trials did not address issues 

associated with Macrophomina or Fusarium. 

Carbonation of 1,3-D/chloropicrin formulations may help to reduce the overall use of 1,3-D by 

increasing its dispersal in the soil while providing yields comparable to methyl bromide (Thomas 

et al., 2011b). In Florida trials (Noling and Cody, 2011) “most alternative fumigants evaluated 

produced yields which were statistically equivalent to that of methyl bromide chloropicrin 50/50 

(320 lb/[treated] acre). Coformulated fumigants such as Telone C-35, generally performed better 

than that of Pic-Clor 60 for maintaining strawberry crop productivity and nematode control.”

6. 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?

Expansion of alternative methods (described in Section 2, above) to areas currently considered 

critical for methyl bromide will occur and effective alternatives are available. Factors that may 

affect farmer transition to alternatives include regulatory restrictions, perception of the 

consequences of methyl iodide use, results of the effectiveness of non-fumigant technologies, 

and remedies to biological issues, such as the emergence of Macrophominia phaseolina and 

Fusarium oxysporum as major pests in some areas. 

The California Strawberry Commission and University of California Extension have continued 

to support and fund the “Farming-Without-Fumigants Initiative” whose goal is to develop 

strawberry fruit production methods that eliminates the need for fumigants all together (Legard, 

2011). Numerous reports on such research were presented at the 2011 Annual International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions. Results of 

these studies highlight the promising potential for alternatives to methyl bromide, including nonchemical alternatives. Technologies such as steam (Fennimore, 2011b), soilless production with 
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substrates and landscape fabrics (Thomas et al., 2011a; Cabrera et al., 2011), cultivar selection 

(Daugovish et al., 2011a), buffer zone management (Daugovish et al., 2011c), anaerobic soil 

disinfestations (Daugovish et al., 2011b; Shennan et al., 2011; Rosskopf et al., 2011),

biofumigation (Mazzola, 2011), and innovative applications pesticides (Sances et al., 2011; 

Daugovish and Fennimore, 2011; Thomas et al., 2011b). Transition from methyl bromide is 

expected to continue with the refinement of these new technologies being funded by USDA 

nationwide. For example, the University of Florida will be completing research on carbonation 

of fumigants such as Telone to enable greater depth penetrations and lateral dispersion in order 

to limit the time for reinfestation by nematodes (Thomas et al., 2011c). This effort will also 

evaluate the use of low-permeable tarps to increase efficacy and reduce emissions. The 

University of Florida will also complete large-scale demonstration trials and industry-wide 

testing on the use of two drip tapes per plant bed in the spring and or fall with Telone (Noling 

and Cody, 2011).

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

Net revenue is calculated here as gross revenue minus operating costs. This is known as a partial 

budget analysis and is a good measure that can be used to describe the direct losses of income 

that may be suffered by the users. The net revenue presented here does not represent net income 

to the users. Net income, which is an indication of the profitability of an operation of an 

enterprise, is gross revenue minus the sum of operating and fixed costs. Net income should be 

smaller than the net revenue measured in this study. Fixed costs were not included because they 

are often difficult to measure and verify.

Summary of Economic Feasibility

The economic analysis of strawberry fruit production compared data on yields, crop prices, 

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

estimate the loss of methyl bromide availability. For California, the primary alternative is 1,3-

D/Chloropicrin at 33 gallons per acre or chloropicrin at 300 pounds per acre where it is allowed. 

The economic factors that drive the feasibility analysis for the use of methyl bromide for fresh 

market strawberry fruit are increased production costs, which may be due to the higher-cost of 

using an alternative, additional pest control requirements, and/or resulting shifts in other 

production or harvesting practices and yield losses. The feasibility of alternatives as compared 

to methyl bromide is dependent on maintaining yield and fruit quality at a competitive cost. An 

economic analysis (see Tables 3 and 4) indicates fumigant-treated soils can result in gains or 

losses to net revenue that range from +10% (with Pic-Clor 60 (1,3-D plus chloropicrin)) to -9% 

(with methyl iodide, 67:33), based primarily on the cost of the individual fumigant.

Crop budgets were analyzed 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: 
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(1) Loss per Hectare. For crops, this measure is closely tied to income. It is relatively easy to 

measure, but may be difficult to interpret in isolation.

(2) Loss per Kilogram of Methyl Bromide. This measure indicates the value of methyl 

bromide to crop production.

(3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross 

revenues are usually easy to measure, at least over some unit, e.g., a hectare of land or a storage 

operation. However, high-value commodities or crops may provide high revenues but may also 

entail high costs. Losses of even a small percentage of gross revenues could have important 

impacts on the profitability of the activity.

(4) Loss as a Percentage of Net Operating Revenue. Net cash revenues are defined as gross 

revenues minus operating costs. This is a very good indicator of 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. Operating profit margin is defined as 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 strawberry fresh fruit producers. Because producers (suppliers) represent an 

integral part of any definition of a market, the threshold of significant market disruption is met if 

there is a significant impact on commodity suppliers using methyl bromide. These economic 

measures provide the basis for making that determination. 

The analysis presented in Tables 3 and 4 below compares different fumigation and steam 

treatment costs to the cost of treating with methyl bromide. Table 3 compares methyl bromide 

and broadcast alternatives impacts while Table 4 compares methyl bromide to steam and drip 

alternatives for California strawberry fruit growers. Costs consist of all production costs 

including labor, equipment and material. Yield losses were assumed to be zero based on the lack 

of publically verifiable yield loss data associated with methyl bromide alternative treatments. In 

the areas where the alternatives can be used California strawberry producers are not expected to 

suffer significant impacts if methyl bromide were not available. Currently, growers are using 

Pic-Clor 60 in both broadcast and drip applications with no measurably known decrease in net 

revenue. 

Iodomethane is registered for use, but there are several impediments for its use by growers,

primarily due to the public’s concern about methyl iodide’s safety (see Section 2, above). 

Iodomethane may be used in combination with chloropicrin in a 67/33 formulation at a rate of 

224 kg/ha. To date, about 10-15 acres of methyl iodide have been applied in total in California. 

Iodomethane is more expensive than Pic-Clor 60 and chloropicrin if used in a broadcast 

application. The drip application of methyl iodide appears to be profitable, but this assessment 

does not take into account the cost of the negative perception issues described above. See Tables
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3 and 4 below for the 2011 comparison of methyl iodide to methyl bromide in the economic 

impact assessment for California strawberry fruit growers.

Steam is another promising alternative, but the costs that are presented below are based on small 

plots (10 acres or less) and, therefore, steam may not be available for use on a commercial scale 

in the near future. The cost of fuel is the primary driver for the cost of steam. Current diesel 

prices in California average around $4.20 per gallon as quoted by Pricelock.com on October 13, 

2011 (www.pricelock.com/index). See Table 4 below.

TABLE 3. CALIFORNIA: ECONOMIC IMPACTS OF METHYL BROMIDE BROADCAST ALTERNATIVES

CALIFORNIA FRESH 

STRAWBERRY

METHYL 

BROMIDE +

PIC 50/50

1,3 D +

PIC

@33GPA

IODOMETHANE

+ PIC

67/33 @ 200

IODOMETHANE +

PIC 67/33

@ 300

CHLORPICRIN 

@300 LB/A

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

 PRODUCTION PER 

HECTARE (KG/HA)

79,074 79,074 79,074 79,074 79,074

**PRICE PER UNIT (US$) $ 2.51 $ 2.51 $ 2.51 $ 2.51 $ 2.51

= GROSS REVENUE PER 

HECTARE (US$) $ 198,734 $ 198,734 $ 198,734 $ 198,734 $ 198,734

- OPERATING COSTS PER 

HECTARE (US$)** $ 164,990 $ 163,754 $ 165,607 $ 168,078 $ 164,248

= NET REVENUE PER 

HECTARE (US$) $ 33,744 $ 34,980 $ 33,126 $ 30,655 $ 34,485

*LOSS MEASURES *

1. LOSS/GAIN PER 

HECTARE (US$) $0 $ 1,236 ($ 618) ($ 3,089) $ 741

2. LOSS/GAIN PER 

KILOGRAM OF METHYL 

BROMIDE (US$)

$0 $ 7.27 ($ 3.63) ($ 18.17) $ 4.36

3. LOSS/GAIN AS A 

PERCENTAGE OF GROSS 

REVENUE (%)

0% 1% 0% -2% 0%

4. LOSS/GAIN AS A 

PERCENTAGE OF NET 

OPERATING REVENUE 

(%)

0% 4% -2% -9% 2%

5. OPERATING PROFIT 

MARGIN (%) 17% 18% 17% 15% 17%

**Note that the measures in the tables above must be interpreted carefully. Operating costs do not include fixed 

costs and net revenue equals gross revenue minus operating costs. Values may not calculate due to rounding during 

conversion from $/lb to $/kg.
USA CUN14 SOIL Strawberry Fruit Open Field Page 11 of 15

TABLE 4. CALIFORNIA: ECONOMIC IMPACTS OF METHYL BROMIDE STEAM AND DRIP

ALTERNATIVES

**Note that the measures in the tables above must be interpreted carefully. Operating costs do not include fixed 

costs and net revenue equals gross revenue minus operating costs. Values may not calculate due to rounding during 

conversion from $/lb to $/kg.

CALIFORNIA FRESH 

STRAWBERRY

METHYL BROMIDE 

+ PIC 50/50 STEAM PIC-CLOR 60EC 25 GPA

MIDAS EC @ 140

LB/A

IODOMETHANE +

PIC

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

 PRODUCTION PER HECTARE (KG/HA) 79,074 79,074 79,074 79,074

**PRICE PER UNIT (US$) $ 2.51 $ 2.51 $ 2.51 $ 2.51

= GROSS REVENUE PER HECTARE 

(US$) $ 198,734 $ 198,734 $ 198,734 $ 198,734

- OPERATING COSTS PER HECTARE 

(US$)** $ 164,990 $ 165,434 $ 161,283 $ 163,260

= NET REVENUE PER HECTARE (US$) $ 33,744 $ 33,299 $ 37,451 $ 35,474

*LOSS MEASURES *

1. LOSS/GAIN PER HECTARE (US$) $0 ($445) $ 3,459 $ 1,730

2. LOSS/GAIN PER KILOGRAM OF 

METHYL BROMIDE (US$) $0 ($ 2.62) $ 20.35 $ 10.17

3. LOSS/GAIN AS A PERCENTAGE OF 

GROSS REVENUE (%) 0% 0% 2% 1%

4. LOSS/GAIN AS A PERCENTAGE OF 

NET OPERATING REVENUE (%) 0% -1% 10% 5%

5. OPERATING PROFIT MARGIN (%) 17% 17% 19% 18%
USA CUN14 SOIL Strawberry Fruit Open Field Page 12 of 15

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

The USG has applied a transition rate to the alternatives, which is reflected in the nomination 

amount and detailed in Table 5. The amount requested reflects adjustments for areas with high 

pest pressure, 1,3-dichloropicrin (TeloneTM) township caps, local regulatory restrictions on the 

use of chloropicrin, and the impact of buffer distances on the use of iodomethane. 

TABLE 5. NOMINATION AMOUNT: 

9. CITATIONS

Butler, D. M., Shennan, C., Rosskopf, E. N, Muramoto, J., Koike, S. T., Klonsky, K. M. 2011. 

Advanced development and implementation of anaerobic soil disinfestations technology as 

an alternative to methyl bromide. CRIS/University of Tennessee research project report. 

http://www.reeis.usda.gov/web/crisprojectpages/222950.html

Cabrera, J. A., Wang, D., Gerik, J., and Gan, J. 2011. Effects of landscape fabrics on pest control 

in a raised-bed trough system for strawberry production without fumigation. International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2011).

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Daugovish, O. and Fennimore, S. 2011. S-Metolachlor (Dual magnum) safety for strawberry in 

southern California. International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions (2011).

http://mbao.org/2011/Proceedings/78DaugovishODualMagnum.pdf

 California 

Strawberry 

Commission 

 Sector Total 

Quantity Requested for 2013: Amount (kgs) 531,737 531,737

Quantity Recommended by 

MBTOC/TEAP for 2013 :

Amount (kgs) 461,186 461,186

Amount (kgs) 461,186 461,186

Area (ha) 2,713

Rate 170

Transition from 2014 Baseline 

Adjusted Value

Percentage (%) -10%

Amount (kgs) 415,067 415,067

Area (ha) 2,442

Rate 170

2014 Methyl Bromide Usage Newer Numerical Index 

Transition Use Reduction Description Spreadsheet

STRAWBERRY FRUIT

SECTOR

Quantity Authorized by Parties 

for 2013:

Quantity Required for 

2014 Nomination:
USA CUN14 SOIL Strawberry Fruit Open Field Page 13 of 15

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