NOMINATING PARTY: The United States of America

FILE NAME: USA CUN 12 SOIL EGGPLANT GROWN IN OPEN FIELDS

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Pre-plant Soil Use for Eggplants Grown in Open Fields (Submitted in 2010 for 2012 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Pre-plant Soil Use for Eggplant Grown in Open Fields

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF

NOMINATION:

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

Y EAR N OMINATION A MOUNT

2012 6,904 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).)

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 Eggplant Grown in Open Fields Page 1 of 15CONTACT 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 EGG PLANT GROWN IN OPEN FIELDS 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 Eggplant Open Field

* Identical to paper documents

USA CUN12 SOIL Eggplant Grown in Open Fields Page 2 of 15

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

EGGPLANT

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

This nomination covers eggplant grown for fresh ma rket in the States of Florida and Georgia. The crop is generally grown in open fields a nd followed by various other crops. Harvest is mainly for fresh market.

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.

Georgia

Continued efforts are underway in Georgia to implement effective and economical alternatives to methyl bromide. A 3-WAY fumigation system , developed by University of Georgia, and dimethyl disulfide (DMDS, currently unregistered in the US) plus chloropicrin are two alternatives that appear to be pot ential replacements for methyl bromide

. During 2008, 40% of the fumigated plasticulture land for vegetable cr ops was treated with the 3-WAY which includes a systems approach of 1,3-dichloropropene, ch loropicrin, and metam sodium. Dimethyl disulfide plus chloropicrin has also proven to be effective in managing many pests, including nutsedge, and has the potential to be adopted once the product is registered assuming it is economically feasible.

Although both the Georgia 3-WAY and DMDS + chloropicrin appear promising, neither fumigant system will stand alone in managing pest s. An effective herbicide program must also be developed to complement these fumigant sy stems. The 3-WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system does not adequately control grasses or Amaranthus species. Until a program using fumigants and herbicides is developed, having methyl bromide available is essential.

The two aforementioned fumigant systems also pos e significant challenges when determining the time interval needed between fumigating and planti ng. Initial research results suggest the plant

back interval for the 3-WAY will be at least 3 ti mes longer than that noted with methyl bromide. Early indications suggest that the plant back interval for DMDS plus chloropicrin applied under high barrier mulch will be similar to the 3-WAY fumigation system.

The latest research information indicates that 3-way system continues to perform well in the spring, but perform poorly on nutsedge control in th e fall. Applications of mixture of DMDS and chloropicrin (79:21), at 45 to 50 gallons/acre in the spring and fall will effectively control nutsedge. Present and future research is focusi ng on developing and implementing a herbicide

USA CUN12 SOIL Eggplant Grown in Open Fields Page 3 of 15program to compliment both the 3-WAY and DMDS fumigant systems as well as determining the amount of time that must pass between fumi gating with these alte rnatives and planting.

Florida

The nutsedge, root-knot nematodes, and fungal diseases like phytopthora blight, and southern blights are continued to be major problems in e ggplant production in Florida. In this State, eggplant is grown year-round, and often double cr opped with pepper or cucumber following the eggplant harvest. The crop that follows eggpl ant in a double cropping production system depends upon prevailing environmental and economic factors. Growers in Florida of ten plant eggplant as an extra crop and grow okra, squash, or cucumber s after eggplant has been harvested. A spring crop of eggplant may follow as a second crop after a fall crop of pepper or tomato. Eggplant does best on well-drained, fertile, sandy-loam soils at a pH of 6.0-6.5. Poorly drained soils may result in slow plant growth, reduced root sy stems, and low yields. Eggplant requires a long, warm, frost-free growing season, usually of 14-16 weeks. Cold temperatures below 5 o C injure this crop. The best temperatures are 27-32 o C during the day and 21-32 o C during the night. Plant growth is curtailed at temperatures below 16 o C. Additionally, soil temperature below 16 o C restricts germination. However, most of the eggpla nt is started in the field from transplants. Methyl bromide is always used in the full-bed mulch process.

Until 1999, the chemical formulation primarily used was 98 percent methyl bromide and two percent chloropicrin. Since then, growers have shifted to formulations with lower concentrations of methyl bromide and higher amounts of chloropi crin due to the phase-out schedule of methyl bromide. At present, the standard formulati on contains 50% methyl bromide in Florida. The best alternative, 1,3-D (Telone ), may not be applied in Florid a in the areas overlying karst geology, which is common throughout the Southeaste rn States. There is also a 21-day planting delay (vs. 14 days for MB) due to regulat ory restrictions for 1,3-D + chloropicrin.

Currently, the best alternative to use of methyl bromide in Florida seems to be applying Telone C-35 (1,3-Dichloropropene + 35% Ch loropicrin), applied at prebed 35 gal./acre rate 3 to 5 wks before transplanting. This fumigant applicati on is supplemented by an herbicide treatment (tank mixed treatment of 2 lbs of napropamide with 0.5 lbs of trifluralin per acre to achieve a proper weed control. However, the use of Telone in 63% of Florida eggplant production land is restricted due to the pres ence of Kast topography.

Iodomethane, a new methyl bromide alternative, was registered in the U.S., in October, 2007. Iodomethane, however, is not regist ered for use on eggplant. EPA f eels that it is appropriate not to include iodomethane as a methyl bromide substitute for eggplant at this time. The U.S. nomination is only for those areas in Georgia and Florida where the alternatives are not feasible.

If methyl bromide were to be una vailable for U.S. eggplant, grower s in the regions cited in this

nomination would have to discon tinue growing this crop or suffe r substantial losses. Growers would either leave agriculture entirely or switc h to other crops that do not rely on pre-plant fumigation to control soil pests. The extent of this impact on th e affected growers is debatable, but given the early state of commercial deployment of methyl bromide alternatives, it is possible that growers who currently use methyl bromide would face this outcome.

USA CUN12 SOIL Eggplant Grown in Open Fields Page 4 of 152. SUMMARIZE WHY KEY ALTERNAT IVES ARE NOT FEASIBLE

Although both the 3-WAY and DMDS (dimethyl disulfide) plus chloropicrin appear promising, neither fumigant system will stand alone in ma naging pests. An effective herbicide program must be developed to complement these fumigant systems. It is also important to keep in mind that DMDS remains unregistered for use in the US. Current review of available research indicate that the 3-WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system does not adequately control grasses or Amaranthus species. The most recent studies have reported that a 79:21 mixture of DM DS and chloropicrin is the most effective combination of these two fumiga nts (Culpepper et al., 2008).

In the Southern U.S., mainly in Florida and Geor gia, where nutsedge is a main methyl bromide target pest, 1,3-D or metam sodium, alone or in combination, may not adequately control this weed. In karst topographical feature areas, which include 31 counties in Fl orida. 1,3-D (Telone II) is highly restricted and metam sodium or metam potassium is the best alternatives available. However, further testing of thes e chemicals in large scale commercial fields is needed. In Florida and Georgia, farmers us ing 1,3-D and metam sodium in the fall would require longer waiting periods for planting. Metam sodium or 1,3-D requires waiting periods of 28 and 21 days, respectively, whereas only 14 days are needed for methyl bromide. Such delays could

result in missed market windows. Metam sodium efficacy appears to decline where it is applied repeatedly due to enhanced degradation of its active ingredient, methyl isothiocyanate, by soil microorganisms (Ashley, et al., 1963; Ou et al., 1995; Verhagen et al., 1996; Gamlied et al., 2003).

Iodomethane, a new methyl bromide alternative, was registered for some crops in the U.S., in October, 2007. Iodomethane, however, is not regist ered for use on eggplant. EPA feels that it is appropriate not to include iodomethane as a methyl bromide substitute for eggplant at this time.

3 IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a cer tification standard for eggplant 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.

A three-way fumigation system developed by Univ ersity of Georgia, as well as dimethyl disulfide (DMDS) plus chloropicr in are the two alternatives that appear the most promising to replace methyl bromide. During the spring of 2008, at least 40% of the land fumigated for vegetable crops in the spring was treated with the 3-WAY which includes a systems approach of 1,3-dichloropropene, chloropicrin, an d metam sodium. It is likely that 30 to 40% of Georgia’s total crop will be treate d with this alternative during 2008. Dimethyl disulfide (DMDS) plus

USA CUN12 SOIL Eggplant Grown in Open Fields Page 5 of 15chloropicrin also proven to be effective in managing many pests and has the potential to be adopted once the price structure is know n. Although both the 3-WAY and DMDS appear promising, neither fumigant system will stand alone in managing pests. An effective herbicide program must be developed to compliment th ese fumigant systems. The 3-WAY does not provide adequate nutsedge contro l with summer/fall fumigations and the DMDS system does not adequately control grasses or Amaranthus species. The reader is reminded that DMDS remains unregistered for use in the United States. Until a program using fumigants and herbicides is developed, having methyl bromide available is essential.

In karst topographical feature areas, which include 31 counties in Florida, Telone is highly

restricted and metam sodium or metam potassium is the best alternatives available. However, further testing of these chemicals in large scale commercial fields is n eeded. In Florida and Georgia, farmers using 1,3-D and metam sodium in the fall would require longer waiting periods for planting. Metam sodium or 1,3-D requires wa iting periods of 28 and 21 days, respectively, whereas only 14 days are needed for methyl bromide. Such delays could result in missed market windows. Metam sodium efficacy appears to d ecline where it is applied repeatedly due to enhanced degradation of its active ingredient , methyl isothiocyanate, by soil microorganisms (Ashley, et al., 1963; Ou et al., 1995; Verhag en et al., 1996; Gamliel et al., 2003).

5. WOULD IT BE FEASIBLE TO EXPA ND 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?

The USG has reviewed all factor s affecting transition rates in this sector. Based on this assessment the transition rate has been greatly in creased for most portions of this sector. For the area covered in this nomination, the USG belie ves that the narrative discussion included in this document is technically valid. The USG ha s nominated amounts of methyl bromide based only on those sub-sectors that ca nnot transition away from methyl bromide at the accelerated

rate.

USA CUN12 SOIL Eggplant Grown in Open Fields Page 6 of 156. STATE RELATIVE EFFECTIVEN ESS OF RELEVANT ALTERNATIVES

COMPARED TO METHYL BROMIDE FO R THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED

A: KEY PATHOGENS: Phytophthora capsici

, Pythium spp. and nematodes ( Meloidogyne spp.)

Summary of studies relevant to key pathogens

New research information on use of soil fumiga nts, specifically in eggplant production is not available in the public domain. Hausbeck and Cortright (2004) c onducted a small-plot field trial on several vegetables, including eggplant. Results, submitted with the 2007 CUE request, indicate that 1,3 D + 35 % chloropicrin treatments (shank-injected at 56.7 lit ers/ha) for control of Phytophthora and Fusarium resulted in a 44% yield loss, compared to methyl bromide plots. Chloropicrin plots alone (shank- injected at 233.6 l/ha) showed a 15.5% loss compared to methyl bromide plots. Metam-potassium + chloropicrin plot s showed yields similar to those treated with methyl bromide. Metam-sodium was not tested, butcan be assumed to be equivalent to metampotassium since the active ingredient is the same. Even large differences in average yields across

various treatments were often not statistically significant.

In studies with other vegetable crops, fumiga tion with 1, 3 D + chloropicrin has generally provided better control of fungi than metam-s odium , though still not as good as control with methyl bromide. For example, in a study using a bell pepper - squash rotation in small plots, Webster et al. (2001) found significantly lower fungal populations with 1,3 D + 35 % chloropicrin (drip applied, 146 kg/ha of 1,3 D), as compared to the untreated control. However, methyl bromide (440 kg/ha, shank-injected ) reduced fungal populations even more. P. capsici was not present in test plots, though Fusarium spp. were. However, as compared to the methyl bromide standard treatment plots, squash fruit weight was 63 % lower in the 1,3 D plots. The proportion of marketable squash fruit in the 1,3 D plots was 30 % lower than that in the methyl bromide plots. In another study, conducted on to matoes, Gilreath et al. (1994) found that metamsodium treatments did not match methyl bromide in terms of plant vigor at the end of the season.

Fusarium (but not P. capsici ) was one of severa l pests present.

These studies indicate that, trials show prom ise for metam-sodium/potassium + chloropicrin, there is inconsistency in efficacy and protection from yield losses. However, the trials were conducted in June, and it is unclear whether th ese results would hold if fumigation were done under cooler spring temperatures. Further, no large scale field tria ls have yet been performed to demonstrate consistent pest control simila r to that provided by methyl bromide.

Culpepper and Langston (2004) compared the effectiveness of several soil fumigants on nematodes affecting peppers in Tifton, Georgia. Since eggplants were not included in these tests, data from peppers are again used to “b ridge” a discussion. Results show that 1,3-D followed by chloropicrin was as effective as met hyl bromide against nematodes. Spring and fall crop yield in these plots were similar to yield in methyl bromide plots.

Root knot nematodes Meloidogyne spp., also affect Georgia eggplan ts. Their damage to the root may facilitate plant invasion by f ungal pathogens, which can lead to wilt, loss of plant vigor, and

USA CUN12 SOIL Eggplant Grown in Open Fields Page 7 of 15yield losses. Fumigant alternat ives such as metam-sodium have proven inconsistent (Noling, 2003; FFVA, 2002).

Diseases caused by soil-borne fungi, (e.g., Phytophthora spp., Pythium spp. and Sclerotium rolfsii ) are endemic in many vegetabl e production areas in Georgia. Fungicides such as chlorothalonil and azoxystrobilurin are only used prophylactically and may not offer sufficient plant protection. Resistance of Phytophthora spp. to metalaxyl and mefenoxam has been reported in tomato and pepper (Lamour and Hausbeck, 2003)

The use of 1,3-D and metam sodium in the fall is impractical because of the long waiting periods for planting following applicati on under plastic mulch. For 1,3- D there is a 28 day waiting period; for metam sodium, there is a 21-day waiting period. Such delays would cost growers at

least half of the harves t season, thereby missing the higher mark et windows. Thus, since the fall crop is dependent upon timely planting, the required waiting period would co st growers at least half of the harvest season, thereby missi ng the higher market windows (Kelley, 2003).

B: KEY WEEDS: Nutsedges

T ABLE 2: DATA ON TRIALS OF F UMIGANT A LTERNATIVES TO M ETHYL B ROMIDE FOR P OLYETHYLENE -M ULCHED
T OMATO (L OCASCIO ET AL

. 1997)

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

Marketable Yield (ton/ha) % Yield Loss (compared to methyl bromide)

Untreated (control)

- 300 ab 20.1 a 59.1
methyl bromide + Pic (67-33), chisel-injected 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

Narrative description of studies relevant to target weeds

For nutsedge, which is widespread in all reque sting regions, growers do not have technically feasible alternatives to methyl bromide use at planting. Metam-sodium and 1,3 D + chloropicrin have shown some efficacy in small-plot trials in other vegetable crops (e.g, tomato). However, metam sodium use may result in a 44% yield loss , while use of 1,3 D may result in a 29% loss. These fumigants often provide less control of nut sedges than methyl bromide. Furthermore, there is evidence that both 1,3 D and methyl isot hiocynate levels decline more rapidly due to enhanced degradation of these chemicals by so il microorganisms, thus further compromising efficacy, in areas where these are repeatedly applied (Smelt et al ., 1989; Ou et al., 1995; Gamliel et al., 2003; Dungan and Yates, 2003).

Results from small plot studies conducted in Tifton, Georgia, by Culpepper and Langston (2004) show that 1,3-D followed by chloropicrin was si gnificantly less effective than methyl bromide against both purple and yellow nutse dge, although this treatment performed as well as methyl bromide relative to spring and fall crop yiel d. 1,3-D + chloropicrin, followed by more

USA CUN12 SOIL Eggplant Grown in Open Fields Page 8 of 15chloropicrin was more effective than methyl br omide against yellow nutsedge, but less effective against purple nutsedge. This treatment performed as well as methyl bromide in terms of spring yield, but poorly in terms of fall yield. 1,3- D + chloropicrin, followed by metam sodium was 36% less effective than methyl bromide for purple nutsedge control, but as effective as methyl bromide against yellow nutsedge. However, test plots were small, and it is unclear if these results will hold in commercial fields, considerin g the variable results reported elsewhere for

these alternatives. The nutse dge populations in this study we re dominated by yellow nutsedge (90% of the total). It is not clear if populations where purpl e nutsedge is dominant would be controlled as effectively, since ot her studies have shown that purple nutsedge is a ha rdier species.

Current review of available re search indicate that the 3- WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system does not adequately control grasses or Amaranthus species. The most recent studies have reported that a 79:21 mixture of DMDS and chloropicr in is the most effective combination of these 2 chemicals (Culpepper et al., 2008). Pr esent and future research are focusing on developing and implementing a herbicide program to compliment both the 3-WAY and DMDS fumigant systems as well as determining the amount of time th at must pass between fumigating with these alternatives and planting.

In Florida, the best currently available alternative for eggplant production (which cannot be used in areas containing karst topographical features) is an application of Telone C-35 (1,3-D + 35% chloropicrin), at 35 gallons per acre, 3-5 weeks before transpla nting, followed by an application of a herbicide mix of napropamide and trifluralin to the top of the raised bed at the time of tarp laying (Noling and Botts, 2007).

A soil treatment recently developed by the Universi ty of Georgia appears to be promising as a methyl bromide replacement for Georgia’s eggpla nt spring crop, although not for the summer or fall crops. This treatment, known as the “UGA 3-WAY”, consists of three successive soil fumigations, beginning with 1,3-D, followed by a chloropicrin application, followed by a metamsodium or metam-potassium applicati on (Culpepper, 2007a). In 2006, Culpepper et al . (2007a)

tested the effectiveness of fall applications of methyl brom ide alternatives, including the UGA 3 WAY treatment, on nutsedges infesting the spring bell pepper crop in Tyty, Georgia. Results of this small-plot study show that the UGA 3-WAY alternative (see above) performed as well as the standard methyl bromide application. Similarly, reducing the standard ra tes of methyl bromide by 50%, from 392 kg/ha under standard LDPE fi lm to 196 kg/ha under metalized film, also provided excellent purple nutse dge control. Pepper yields were co mparable in all treated plots.

In a related small plot trial, conducted by Cu lpepper (2007b) in Echols County, Georgia, during the spring of 2006, excellent purple nutsedge control was achieved w ith 484 kg of methyl bromide/ha under standard film and 336 kg of methyl bromide/ha under metalized film. However, further reducing the methyl bromide rate by 50% to 224 kg/ha, under metalized film, resulted in poor nutsedge control. Soil fumiga tion took place in February. Culpepper concludes that, based on research conducted over the past three years with methyl bromide applied under metalized film, a 33% reduction of the standard 67 :33 formulation is possible in fields heavily infested with weeds, and a 40% reduction in fields with light weed infestations, whereas reducing the methyl bromide rate by 50% w ould be unsustainable for weed control.

USA CUN12 SOIL Eggplant Grown in Open Fields Page 9 of 15USA CUN12 SOIL Eggplant Grown in Open Fields Page 10 of 15 Although these results are promising, results from sm all plot research need to be verified at the commercial level, in on-farm trials. Furthermore, most research in Georgia has so far focused on nutsedge. Additional work is needed to determ ine the efficacy of alternatives on other weed species, such as morning glory and pigweed. Finally, the economics of transitioning to alternatives has not been fully worked out, incl uding the cost and durability of films and the modification of fumigation equipment

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

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

Readers please note that in this study net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct loss es of income that may be suffered by the users.

It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitability of an operation of an enterprise, is gross revenue minus the sum of operating and fixed costs. Net income should be smaller than the net revenue measured in this study. We did not include fixed costs because it is often difficult to measure and verify.

Summary of Economic Feasibility

The economic analysis of eggplant applications compared data on the yields, crop prices, revenues and costs of using methyl bromide or al ternative pest control regimens. This was done in order to estimate impacts on eggplant grower s with the decreasing availability of methyl bromide. The Georgia 3-Way (1,3-dichloropr opene with chloropicrin followed by metam sodium) was identified as being a technically feasible alternative (in cases of low pest

infestation 1 and in spring fumigations onl y) to methyl bromide in Georgia and Florida eggplant production. 1,3-D + chloropicrin is also being recognized as an a lternative to methyl bromide; however, it is not considered technically f easible as yield losses are expected.

The economic reviewers analyzed crop budgets fo r 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

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.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 ar e eggplant producers in this case. Because producers (suppliers) represent an in tegral part of any definition of a market, we interpret the threshold of significant market di sruption 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 and Florida

In Georgia and Florida, usi ng the Georgia 3-Way on spring pl antings is believed to be a technically and economically feasible alternative to methyl bromide, although some limitations exist. Referring to Tables 3 and 4, the loss of ne t revenue using the Georgi a 3-Way is negligible for Florida in comparison to methyl bromide, while gains in net revenue ar e expected in Georgia. Unlike spring plantings, however, yield losses ar e expected in fall plan tings, with studies in Georgia’s application showing 50% yield losses. The Georgia 3-Way also cannot be used on eggplants that are grown in kars t soils since it contains 1,3-D. Th erefore, for fall plantings and areas with karst soils, the use of methyl bromide is critical to Georgia’s and Florida’s eggplant production. Note that data desc ribing Georgia eggplant prod uction is based on double cropping production practices.

Florida Analytical Notes:

Florida’s application for methyl bromide critical use indicated that more than one crop is typically grown per growing season but did not provide specific productio n and sales data for this crop. As a result of this gap in data, economic assessment of Florida eggplant production was based on a single crop production system. This characterization of growing conditions could result in the critical need for methyl brom ide appearing smaller than it actually is, because the value the second crop derives from methyl bromide is not included in the analysis.

USA CUN12 SOIL Eggplant Grown in Open Fields Page 11 of 15T ABLE 3: G EORGIA

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA EGGPLANT METHYL

BROMIDE GEORGIA 3-

WAY: SPRING

APPLICATION GEORGIA 3-

WAY: FALL

APPLICATION

PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 7,070 7,070 3,535 * PRICE PER UNIT (US$) $8 $8 $8

= GROSS REVENUE PER HECTARE (US$) $57,547 $57,547 $28,774

- OPERATING COST PER HECTARE (US$) $45,271 $34,610 $34,610 = NET REVENUE PER HECTARE (US$) $12,277 $22,938 -$5,836

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 ($10,661) $18,113

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 ($71) $121

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -19% 31%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% -87% 148%
5. OPERATING PROFIT MARGIN (%) 21% 40% -20% Note: Georgia eggplant revenue and cost measures were calculated using data from a two crop per growing season production system.

 Interpret the loss measures with caution. Negative number s presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

T ABLE 4: F LORIDA

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA EGGPLANT METHYL

BROMIDE GEORGIA 3-

WAY: SPRING

APPLICATION 1,3-D +

CHLOROPICRIN

PRODUCTION LOSS (%) 0% 0% 29%

PRODUCTION PER HECTARE 1,764 1,764 1,252 * PRICE PER UNIT (US$) $11 $11 $11 = GROSS REVENUE PER HECTARE (US$) $19,983 $19,983 $14,188 - OPERATING COST PER HECTARE (US$) $17,891 $17,976 $17,303 = NET REVENUE PER HECTARE (US$) $2,092 $2,007 -$3,116

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $85 $5,208

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $70

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 0% 26%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 4% 249%
5. OPERATING PROFIT MARGIN (%) 10% 10% -22% * 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.

USA CUN12 SOIL Eggplant Grown in Open Fields 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 5.

TABLE 5. N OMINATION A MOUNT :



### CITATIONS

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