NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 SOIL FOREST SEEDLING NURSERIES Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Forest Seedling Nurseries in 

Open Fields (Submitted in 2010 for 2012 Use Season) 

CROP NAME (OPEN FIELD OR PROTECTED): Forest Seedling Nurseries Open Field

QUANTITY OF METHYL BROMIDE NOMINATED: 

TABLE 1: QUANTITY OF METHYL BROMIDE NOMINATED

Year NOMINATION AMOUNT

2012 34,230 kg 

NOMINATING PARTY CONTACT DETAILS:

Contact Person: John Thompson 

Title: Division Director 

Address: Office of Environmental Policy 

 U.S. Department of State 

 2201 C Street, N.W. Room 2658 

 Washington, D.C. 20520 

 U.S.A. 

Telephone: (202) 647-9799 

Fax: (202) 647-5947 

E-mail: thompsonje2@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the 

specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for 

this use would result in a significant market disruption. ■ Yes  No 

 

Signature Name Date 

Title: 

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat website under 

Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on 

which the Party’s first-year exemption was approved, as well as any supplementary information provided by the 

Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not 

re-submit that earlier information. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 1 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 

USA CUN12 SOIL FOREST SEEDLING NURSERIES Open Field 

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: 

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

No. of 

kilobytes 

Date sent to Ozone 

Secretariat 

USA CUN12 SOIL FOREST SEEDLING NURSERIES Open Field 

* Identical to paper documents 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 2 of 15 
METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

FOREST SEEDLING NURSERIES 

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

Forests are increasingly important as challenges to the environment have global implications. 

The first step in forest establishment is the production of tree seedlings by forest tree nurseries. 

These nurseries provide healthy starting material for newly planted forests. The U.S. nomination 

is for a critical use of methyl bromide for those nurseries where registered alternatives are not 

effective or sufficiently tested to enable commercial use. The use of methyl bromide is 

considered critical where alternatives are not suitable because of regulatory, economic, or 

technical constraints. 

The USG has reviewed all factors affecting transition rates in this sector. Based on this 

assessment the transition rate has been greatly increased for most portions of this sector. For the 

area covered in this nomination, the USG believes that the narrative discussion included in this 

document is technically valid. The USG has nominated amounts of methyl bromide based only 

on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate. 

In 2009, four consortia submitted applications. However, only three consortia requested critical 

use exemptions for methyl bromide—the Southern Forest Nursery Management Cooperative 

(Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, 

Oklahoma, South Carolina, Tennessee, Texas, and Virginia), the Michigan Seedling Growers 

(Michigan, one nursery in Indiana), and the Northeastern Forest and Conservation Nursery 

Association (Illinois, Indiana, Kentucky, Maryland, Missouri, New Jersey, Ohio, Pennsylvania, 

West Virginia, and Wisconsin). The Northeastern Forest and Conservation Nursery Association 

has reduced their request for critical use of methyl bromide to 3,257 kg for use on 16 ha. 

ArborGen submitted an application, but appears to have no additional critical use request (states 

with ArborGen nurseries are included in the Southern Forest Nursery Management Cooperative 

request). The application states that “all use is QPS for Arbor Gen, LLC.” The purpose of the 

submission was to provide ”the EPA with an estimate of current and future MBr use and to 

provide information on the effectiveness of current and future MBr use reduction measures.” 

Of the registered alternatives, iodomethane offers a potential alternative to methyl bromide for 

forest seedling nurseries. A major hindrance in adopting this newly registered product is its lack 

of availability for nurseries even for experimental trials. The registered product for iodomethane 

is controlled by the registrant and forest nursery representatives throughout the U.S. have not 

been able to contract fumigant applicators to fumigate with iodomethane. Continuing field trials 

should address uncertainties associated with appropriate use rates, formulation type, application 

techniques, and certification acceptability. Ongoing area-wide trials in the southeastern U.S. 

continue to refine the efficacy of alternatives (Quicke et al., 2009). However, the status of 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 3 of 15 
effective glue technology for low permeable films remains uncertain for commercial broadcast 

fumigation. Quicke et al. (2009) found that gluing virtually impermeable film required five 

hours to treat 0.5 ha as compared to four hours to treat 1.5 ha with standard film. The U.S. 

believes a transition period requiring continued critical use of methyl bromide is necessary to 

resolve these issues. 

For some other alternatives, inconsistency in overall pest management performance (e.g. metamsodium and dazomet) has been the primary concern for this sector, and the reason that methyl 

bromide continues to have some critical use. While direct yield losses, in terms of 

seedlings/hectare, may not be large on average, intensive seedling production relies on the ability 

of nursery managers to meet quality and yield goals as well as certification that plants are 

essentially pest-free. 

Effective fumigation can manage fungal pathogens (e.g., Fusarium, Alternaria, Phytophthora, 

Pythium, Rhizoctonia, Cylindrocladium spp., Cylindrocarpon, and Macrophomina), nematodes 

(e.g., Circonemoides, Helicotylenchus), and yellow and purple nutsedges (species of Cyperus). 

Nutsedge species are generally considered among the major pests of forest seedling nurseries in 

the eastern U.S. and the pests most difficult to manage. 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

For the 2012 use season, methyl bromide remains a critical need for forest seedling nurseries to 

produce plants free of pests in order to meet state certification standards, as well as customer 

expectations. The use protocols for the effective alternatives have not been developed 

sufficiently to provide effective control of the key pests to depths of 1 m. In addition, there are 

few, if any, markets for plants that do not meet the certification standards, which mean that 

losses up to 100% are possible when inadequate pest control occurs. Failure to adequately 

manage pests in transplants will jeopardize the viability of the planted forests. 

A new registration for iodomethane presents a potential alternative to methyl bromide (it is 

currently registered in all states except California, New York, and Washington). Iodomethane 

use rates and formulations (98:2 or 50:50) need to be tested by seedling nurseries to determine 

what rates are the most effective and cost-feasible. However, a lack of availability of the 

iodomethane product for forest nursery testing has been a disappointment to nursery managers 

and researchers. Chloropicrin appears to be a possible alternative, but strict regulations make its 

future uncertain when used at the high rates that have been shown to be effective (South, 2007; 

Enebak, 2007). 

According to nursery specialists from requesting consortia (Enebak, 2008; Lowerts, 2008; 

Talbert, 2008; Overton, 2008), iodomethane holds promise as an effective alternative to methyl 

bromide. However, the following comments highlight concerns by nursery experts of potential 

problems with a transition to iodomethane for the forest seedling nursery industry: 

 Research has been scant for testing the efficacy of iodomethane in forest seedling 

nurseries. One two-year study conducted in the southeast U.S. (Starkey et al., 2007) 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 4 of 15 
indicated that the size of pine seedlings with iodomethane were similar to that with 

methyl bromide for both years. Weed populations were significantly greater in one of 

the two years of the study. There is a need to validate the studies to determine if 

iodomethane manages weed populations sufficiently for commercial production. 

 The limited number of field studies that have been conducted is not sufficient to 

confirm that iodomethane is a suitable alternative to methyl bromide; the industry 

cannot afford to risk production until the new product is rigorously tested. One 

consortium stated that “most researchers consider 3 years of trials over several 

locations are needed to develop reliable data for pesticide guidelines.” Trials for this 

sector have not been completed or reported. Trials conducted in the northeast are 

limited to a few vegetable crops with custom applicators from outside the region. 

 Research trials with iodomethane conducted in Washington (where iodomethane is 

not currently registered for commercial use) have found encouraging results. 

 Cost estimates for the southeast for application and tarp removal of 350 lb/acre [392 

kg/ha] of 98:2 methyl bromide was approximately $4,450 per hectare. The cost of 

175 lb/acre [196 kg/ha] of 98:2 iodomethane was approximately $6,280 per hectare. 

Cost in the northeast for iodomethane products range from $15 per kg (50:50) to $20 

per kg (98:2). This compares to $7 per kg for methyl bromide (98:2). Estimated 

costs of fumigation per hectare for northeastern nurseries average $8,300 for 

iodomethane (98:2), $10,500 for iodomethane (50:50), and $4,820 for methyl 

bromide (98:2). If these cost differences are maintained the industry would find 

iodomethane to be economically infeasible. 

 Regional fumigation contractors do not currently have the equipment to broadcast 

iodomethane. According to the iodomethane label, “The treated ground must be 

sealed using closing shoes, roller, compaction roller, cultipacker or other equivalent 

equipment that will sufficiently cover chisel marks left after soil injection. The 

equipment shall cover the chisel marks with soil immediately prior to the placement 

of the tarpaulin being laid down (with fumigant injection) by tarpaulin-laying 

equipment mounted on the application tractor.” Demand for the product may change 

this situation, but the industry is not able currently to broadcast iodomethane. 

 Use of iodomethane resulted in a reduction of beneficial Trichoderma fungi 

populations in soil 12 and 18 months following treatment in both years of a two-year 

study (Starkey et al., 2007). This effect will have to be confirmed by additional 

studies, but would result in long-term reduced production quality. 

 Methyl bromide is accepted by state control boards as meeting phytosanitary 

requirements for nursery shipments. Iodomethane will require the same acceptance, 

but as yet, this certification standard has not been addressed by the registrant of 

iodomethane or state regulators. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 5 of 15 
 According to consortia representing northeast and southeast nurseries, Arysta 

(manufacturer of MIDAS iodomethane) has no representatives or applicators of the 

iodomethane product for forest nurseries in northeastern or southeastern states. 

 The iodomethane label (MIDAS) does not make clear if use is allowed for production 

of deciduous tree seedlings (“strawberries, stone fruits, tree nuts, and conifer trees”). 

Deciduous seedlings are generally more valuable than conifer seedlings and have 

greater pest management requirements. 

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

STANDARD?

This sector is covered by certification requirements. All states have certification standards and 

all nurseries have additional internal quality control standards as well (NPB, 2008 for summaries 

of nursery plant regulations for all states). USDA-APHIS has guidelines for containment of 

sudden oak death through movement of nursery material (USDA-APHIS, 2004). An example 

from Mississippi, “All nursery stock shipped into Mississippi must carry on each container or 

bundle a valid nursery inspection tag (inspection certificate) of the State of origin. Containers 

should also be plainly marked with the names and addresses of shipper and consignee” (MDAC, 

2003). Similarly from Alabama, “Nursery stock entering the State of Alabama must be certified 

as being apparently free from plant pests. Certificate tags issued by the official certifying agency 

of the state of origin stating such must be firmly attached to each box, bundle or package of 

nursery stock moved into the state” (ADAI, 2004). In addition, “No inspection certificate shall 

be issued for the sale, offering for sale, or movement of any nursery stock until the stock in 

question shall have been inspected by the Commissioner and found to be apparently free from 

seriously injurious plant pests” (ADAI, 2004). Other states have similar regulations (NPB, 

2008). 

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

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

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE. 

All nurseries currently treat production beds with methyl bromide due to certification and 

production requirements. Where weeds are of primary pests, methyl bromide has been the most 

effective treatment and accepted by state inspectors. Methyl bromide allows conifer seedling 

beds to be fumigated after two or three crops (as opposed to after every crop) because of the 

effectiveness of methyl bromide, which usually makes a second-year treatment unnecessary. 

Iodomethane is a new fumigant and may be an effective alternative, but multi-season information 

on its use for forest nurseries is lacking and product availability appears to be limited for testing 

in forest seedling nurseries. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 6 of 15 
5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO 

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

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE 

THIS? 

Preliminary results of research suggest iodomethane has value as a replacement for methyl 

bromide, but it first must be tested to prove efficacy and acceptability for certification. In 

addition, as with all new products, adjustment of use rates and application experience with 

iodomethane will require a few seasons where nurseries can transition from methyl bromide, 

assuming costs do not limit the use of iodomethane. Nursery managers attest to their inability to 

find iodomethane to use even for testing purposes. Apparently distribution of the product to 

professional applicators has been limited by the registrant for this sector. 

The USG has reviewed all factors affecting transition rates in this sector. Based on this 

assessment the transition rate has been greatly increased for most portions of this sector. For the 

area covered in this nomination, the USG believes that the narrative discussion included in this 

document is technically valid. The USG has nominated amounts of methyl bromide based only 

on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate. 

6. SUMMARY OF RECENT RESEARCH 

Research with low permeability films and methods to glue them for broadcast fumigation 

appears to be progressing. However, the feasibility for commercial broadcast with low 

permeable films is still questionable. The standard width of film used in the nursery industry 

(400 cm) is not available for the film that currently can be glued, which may slow adoption, 

according to a representative of Pliant Corporation, a major manufacturer of low permeable films 

in the U.S. Research trials with VIF have primarily been conducted with bed, rather than the 

standard broadcast fumigation due to problems gluing film. Glues are apparently proprietary and 

manufacturing information is difficult to attain. Ajwa (2008) reported some preliminary 

successes in strawberry research trials gluing VIF and totally impermeable film (TIF). He cited 

reports that researchers in Florida had had difficulty gluing TIF. 

In 2008, iodomethane was registered in all states requesting a critical use of methyl bromide, 

except Washington, for use in forest seedling nurseries. Unfortunately, research on iodomethane 

use for this industry is minimal and rates, formulation, and application techniques will have to be 

optimized for commercial applications. The registrant, Arysta, has not yet completed work to 

support pest-free certification with the product and the product is not available to most of the 

nurseries even for testing purposes. Fumigant trials have been conducted with conifers, not 

hardwoods, which constitute a valuable portion of many nurseries. 

 At two sites in Alabama forest seedling nurseries, Quicke et al. (2009) found no 

significant differences in seedling counts among several fumigant treatments (98:2 

methyl bromide at both 450 kg/ha and 264 kg/ha and 392 kg/ha of 67:33; 70:30 methyl 

bromide [98:2]:solvent A at 450 kg/ha; Pic+ solvent A at 336 kg/ha; chloropicrin at 336 

kg/ha; Chlor60 [60% chloropicrin, 40% 1,3-D] at 450 kg/ha; DMDS/Pic [79:21] at 480 

kg DMDS/ha; iodomethane at 180 kg/ha of 50:50 and 112 kg/ha of 98:2). At one 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 7 of 15 
location no differences were observed in Trichoderma populations, at one location the 

DMDS treatment resulted in the highest Trichoderma population. The use of virtually 

impermeable film with the iodomethane treatments were said to be the largest broadcast 

trials with this product. Results were positive, but time of gluing after fumigation was 

seen as a hindrance for commercial adoption of this product (five hours to treat 0.5 ha as 

compared to four hours to treat 1.5 ha with standard film). 

 Quicke et al. (2008) studied two nursery sites in South Carolina. Randomized blocks 

were treated with one of seven fumigants (98:2 methyl bromide at both 450 kg/ha and 

264 kg/ha; 70:30 methyl bromide at 450 kg/ha; Pic+ at 336 kg/ha; chloropicrin at 336 

kg/ha; Chlor60 at 450 kg/ha; DMDS/Pic at 480 kg DMDS/ha). At both sites, all 

treatments provided comparable seedling densities. No nematodes were detected in any 

fumigated soil. Trichoderma populations were greatest in soil that had been treated with 

a high rate of chloropicrin. 

 Results from experiment-sized plots conducted in Mt. Vernon Research Center, 

Washington (Talbert, 2008) in 2007 in cooperation with USDA, found that iodomethane 

treatments generally provided acceptable weed and pathogen control. Concerns were 

raised about the effectiveness of spring fumigation with iodomethane and consistency 

throughout different locations. Additional testing is planned for western nurseries and 

two to three seasons is considered necessary to gauge efficacy and feasibility. 

 Research (Weiland et al., 2008) to study the efficacy of reduced doses of fumigants 

(methyl bromide, iodomethane, and DMDS) under VIF and their effects on soil 

pathogens and weeds is underway in Oregon and Washington. Trials will be analyzed in 

the fall of 2009. 

 In a two-year study conducted in Georgia, Starkey et al. (2007) found that 

iodomethane:chloropicrin (168 kg/ha of 98:2) produced seedlings with characteristics 

(density, diameter, height, root and shoot biomass) comparable to methyl bromide-treated 

beds. Methyl bromide and chloropicrin (168 kg/ha of 98:2) with VIF produced seedlings 

comparable to methyl bromide:chloropicrin (336 kg/ha of 98:2) with standard films. 

Weeds in iodomethane-treated beds were comparable to methyl bromide in a 2006 trial 

and more than in methyl-bromide-treated beds in a 2005 trial. This was attributed to the 

rate of iodomethane that was used. The regeneration of the beneficial fungus 

Trichoderma was reduced under VIF and with iodomethane treatments compared to 

methyl bromide. 

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

This study calculated net revenue as gross revenue minus operating costs. This is a good 

measure of the direct losses of income that may be suffered by the users. It should be noted that 

net revenue does not represent net income to the users. Net income, which indicates profitability 

of an operation for an enterprise, is gross revenue minus the sum of operating and fixed costs. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 8 of 15 
Net income is smaller than the net revenue measured in this study, often substantially so. Fixed 

costs were not included because they are difficult to measure and verify. 

The economic analysis 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. The alternative analyzed as technically feasible was 

iodomethane/chloropicrin. 

The economic factors that drive the feasibility analysis for nursery stock production uses of 

methyl bromide are: (1) yield losses, referring to reductions in the quantity produced, (2) 

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 (3) quality losses, which generally affect the quantity and price received for the goods, 

and (4) missed market windows due to plant back time restrictions, which also affect the quantity 

and price received for the goods. 

The economic reviewers then analyzed crop budgets forest nurseries to determine the likely 

economic impact if methyl bromide were unavailable. Various measures were used to quantify 

the impacts, including the following: 

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

measure, but may be difficult to interpret in isolation. 

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

bromide to crop production. 

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

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

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

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

impacts on the profitability of the activity. 

(4) Loss as a Percentage of Net Operating Revenue. We define net cash revenues as gross 

revenues minus operating costs. This is a very good indicator as to the direct losses of income 

that may be suffered by the owners or operators of an enterprise. However, operating costs can 

often be difficult to measure and verify. 

(5) Operating Profit Margin. We define operating profit margin to be net operating revenue 

divided by gross revenue per hectare. This measure would provide the best indication of the 

total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be 

difficult to measure and fixed costs even more difficult, therefore fixed costs were not included 

in the analysis. 

These measures represent different ways to assess the economic feasibility of methyl bromide 

alternatives for methyl bromide users, who are tomato producers in this case. Because producers 

(suppliers) represent an integral part of any definition of a market, we interpret the threshold of 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 9 of 15 
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. 

The results of the analysis of methyl bromide compared to iodomethane are shown in Tables 2 

and 3. Iodomethane is assumed to provide the same yields as methyl bromide. Therefore, the 

only losses shown in the tables below as a result of methyl bromide not being available are 

increased fumigation and hand weeding costs. Since one study (Starkey et al., 2007) indicated 

increased weed pressure with iodomethane compared to methyl bromide, almost $800 per 

hectare per year was added for hand weeding costs with the use of iodomethane. 

The yields, revenues, and costs listed in Tables 2 and 3 are averages per year over fumigation 

cycles of 2 – 4 years. Most of the yields, revenues, and costs occur 1 – 2 years out of 2 – 4 

fumigation cycles, while fumigations are usually done once during the fumigation cycle and 

sometimes twice for certain species. Since the costs are average annual costs, the increased costs 

will be less than the full increased cost of a single iodomethane fumigation compared to methyl 

bromide. 

Also, revenues and costs will vary between regions due to different yields, species, and cultural 

and fumigation practices. 

Furthermore, these tables do not show other possible losses discussed earlier in this nomination 

and summarized below, which include: 

 Efficacy. While the analysis of economic feasibility assumed equal yields, the limited 

number of field studies that have been conducted is not sufficient to confirm that 

iodomethane has equal efficacy as methyl bromide. If efficacy is not equal there could be 

impacts on seedling quality and forest health. 

 Forest Health. Seedlings free of pathogens and other pests help establish forests with 

less pest pressure, thus resulting in faster growth and less use of pesticides. 

 Certification. Methyl bromide is accepted by state control boards as meeting 

phytosanitary requirements for nursery shipments. Iodomethane will require the same 

acceptance, but as yet, with limited efficacy studies, this certification standard has not 

been established. There are few, if any, markets for plants that do not meet the 

certification standards, which mean that losses up to 100% are possible when inadequate 

pest control occurs. 

 Product Availability and Application Equipment. The lack of availability of 

iodomethane to forest nurseries has been noted. This has affected the scheduling of 

comparative field trials. In addition, the continued comments about the feasibility of 

gluing low permeable films for broadcast applications reduces the commercial 

applicability of iodomethane for forest nurseries. Demand for iodomethane may change 

this situation, but the industry is not able currently to broadcast iodomethane. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 10 of 15 
 Deciduous trees. The iodomethane label (MIDAS) does not make clear if use is allowed 

for production of deciduous tree seedlings, which are generally more valuable than 

conifer seedlings and have greater pest management requirements. 

TABLE 2 SOUTHERN FOREST NURSERY MANAGEMENT COOPERATIVE: ECONOMIC IMPACTS OF METHYL 

BROMIDE ALTERNATIVES PER YEAR

SOUTHERN FOREST NURSERY MANAGEMENT COOPERATIVE

METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0% 

 Yield (seedling) per Hectare Pine 779,617 779,617 

* Price per Unit (U.S. $/seedling) $0.05 $0.05 

Gross Revenue per Proportion (88% of seedlings; 72% of acres) $25,234 $25,234 

 Yield (seedling) per Hectare Longleaf Pine 423,785 423,785 

* Price per Unit (U.S. $/seedling) $0.09 $0.09 

Gross Revenue per Proportion (3% of seedlings; 5% of acres) $1,759 $1,759 

 Yield (seedling) per Hectare Hardwood 243,399 243,399 

* Price per Unit (U.S. $/seedling) $0.25 $0.25 

Gross Revenue per Proportion (9% of seedlings; 24% of acres) $14,337 $14,337 

= GROSS REVENUE PER HECTARE (US$) $41,330 $41,330 

− OPERATING COSTS PER HECTARE (US$)** $23,401 $24,648 

= NET REVENUE PER HECTARE (US$) $17,929 $16,682 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,248 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $15 

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 7% 

5. OPERATING PROFIT MARGIN (%) 43% 40% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 11 of 15 
TABLE 3. NORTHEASTERN FOREST AND CONSERVATION: ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES PER YEAR 

NORTHEASTERN FOREST AND CONSERVATION

METHYL 

BROMIDE

IODOMETHANE

YIELD LOSS (%) 0% 0% 

 Yield (seedling) per Hectare Conifer (1-0) 247,105 247,105 

* Price per Unit (U.S. $/seedling) $0.26 $0.26 

Gross Revenue per Proportion (8% of acres) $5,140 $5,140 

 Yield (seedling) per Hectare Conifer (2-0) 185,329 185,329 

* Price per Unit (U.S. $/seedling) $0.26 $0.26 

Gross Revenue per Proportion (4% of acres) $1,927 $1,927 

 Yield (seedling) per Hectare Conifer (3-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.35 $0.35 

Gross Revenue per Proportion (14% of acres) $6,054 $6,054 

 Yield (seedling) per Hectare Deciduous Trees (1-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.32 $0.32 

Gross Revenue per Proportion (55% of acres) $21,745 $21,745 

 Yield (seedling) per Hectare Deciduous Trees (2-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.37 $0.37 

Gross Revenue per Proportion (9% of acres) $4,114 $4,114 

 Yield (seedling) per Hectare Deciduous Shrubs (1-0) 123,553 123,553 

* Price per Unit (U.S. $/seedling) $0.29 $0.29 

Gross Revenue per Proportion (10% of acres) $3,583 $3,583 

= GROSS REVENUE PER HECTARE (US$) $42,564 $42,564 

− OPERATING COSTS PER HECTARE (US$)** $31,879 $33,418 

= NET REVENUE PER HECTARE (US$) $10,684 $9,146 

LOSS MEASURES ** 

1. LOSS PER HECTARE (US$) $0 $1,538 

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $16 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 4% 

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 14% 

5. OPERATING PROFIT MARGIN (%) 25% 21% 

** Note that the measures in this table must be interpreted carefully. Operating costs do not include fixed costs and 

net revenue equals gross revenue minus operating costs. 

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

Three consortia submitted applications. Two consortia requested critical use exemptions for 

methyl bromide—the Southern Forest Nursery Management Cooperative and the Northeastern 

Forest and Conservation Nursery Association. 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 12 of 15 
ArborGen’s submission appears to have no critical use needs. The application states that “all use 

is QPS for Arbor Gen, LLC.” The purpose of the submission was to provide ”the EPA with an 

estimate of current and future MBr use and to provide information on the effectiveness of current 

and future MBr use reduction measures.” 

The Northeastern Forest and Conservation Nursery Association has reduced their request for 

critical use of methyl bromide to 3,257 kg for use on 16 ha. 

The USG has also applied an aggressive transition rate, which is reflected in the nomination 

amount and detailed in Table 4. 

TABLE 4. NOMINATION AMOUNT: 

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 13 of 15 
CITATIONS 

ADAI (Alabama Department of Agriculture and Industries). 2004. Chapter 80-10-1, Nursery 

and Nursery Stock. Plant Industry Administrative Code. 

http://www.msapms.org/new/newsletters/Nursery%20and%20Nursery%20Stock%20Regula

tions_New.pdf

Ajwa, H. 2008. Personal communication, original email to S. Weiss, SRRD-OPP, EPA, 

November 20, 2008. 

Enebak, S. 2008. Personal communication, email to L. Yourman, October 28, 2008. 

Enebak, S. 2007. Personal communication, email to L. Yourman, Aug. 16, 2007. 

Enebak, S., Starkey, T., and McCraw, D. 2006. Tree seedling quality and weed control with 

Basimid, MBR and methyl iodide. Annual International Research Conference on Methyl 

Bromide Alternatives. 

http://www.mbao.org/2006/06Proceedings/040StarkeyTMBAOMIMBrBasamidTES.pdf

Lowerts, G. 2008. Personal communication (ArborGen), email to L. Yourman, October 29, 

2008. 

MDAC (Mississippi Department of Agriculture and Commerce). 2003. Summary of plant 

protection regulations.Bureau of Plant Industry, Plant Pest Division. 

http://nationalplantboard.org/docs/mississippi.doc. Moulton, R. J. and Hernandez, G. 2000. Tree 

planting in the United States, 1998. Tree Planters Notes V49(2). USDA Forest Service. pp 

1-36. 

NPB (National Plant Board). 2008. Laws and Regulations. 

http://www.nationalplantboard.org/laws/index.html 

Overton, R. 2008. Personal communication (Purdue University, NE Area Regeneration 

Specialist, email to L. Yourman, October 31, 2008. 

Quicke, M., Starkey, T., and Enebak, S. 2009. 2009 Methyl bromide alternatives in Alabama 

forest tree seedling nurseries. Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/038QuickeM2009%20Areawide%20Nov%20San%20Diego%20MBAO.pdf

Quicke, M., Starkey, T., and Enebak, S. 2008. 2008 Area-wide demonstration of alternatives: 

Forest nurseries in the southern U.S. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2008). 

http://www.mbao.org/2008/Proceedings/013QuickeM2008Area-wideNovOrlandopaper.pdf

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 14 of 15 
USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 15 of 15 

South, D. B. 2007. Chloropicrin as a soil fumigation treatment in southern pine nurseries. 

Southern Journal of Applied Forestry 31(1):47-51. 

Starkey, T., Enebak, S., and McCraw, D. 2007. Seedling quality and weed control with dazomet, 

methyl bromide and methyl iodide at the Glennville Regeneration Center 2005-2006. 

Research Report 06-05, Southern Forest Nursery Management Cooperative, Auburn, AL. 

also, http://www.mbao.org/2006/06Proceedings/040StarkeyTMBAOMIMBrBasamidTES.pdf; 

http://mbao.org/2006/06PowerPoints/MBAO%20PDFs/Preplant/7%20-

%20Ornamentals,%20Tree%20Crop%20and%20Forest%20tree%20Nurseries/Starkey.pdf

Talbert, C. B. 2008. Personal communication with Director of Forestry and Regeneration , 

Weyerhaeuser Corporation, Western Timberlands. October 31, 2008. 

USDA-APHIS (Animal and Plant Health Inspection Service), Plant Protection and Quarantine. 

2004. Sudden Oak Death. Amended order restricting movement of nursery stock from 

California nurseries. http://www.aphis.usda.gov/ppq/ispm/pramorum/pdf_files/sodorder4-22-04signed.pdf

Weiland, J., Pinkerton, J. N., Littke, W., Browning, J., Masters, C., Rose, R., Haase, D., Miller, 

T., Edmonds, B. and Leon A. 2008. Methyl bromide alternatives in Oregon and 

Washington forest tree nurseries. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2008). 

http://www.mbao.org/2008/Proceedings/015WeilandJMBASummary01.pdf