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: 

TABLE 1: QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR OF NOMINATION

YEAR NOMINATION AMOUNT 

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 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 Eggplant Grown in Open Fields 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 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 market in the States of Florida and Georgia. 

The crop is generally grown in open fields and followed by various other crops. Harvest is 

mainly for fresh market. 

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. 

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 potential replacements for methyl bromide. During 2008, 40% of 

the fumigated plasticulture land for vegetable crops was treated with the 3-WAY which includes 

a systems approach of 1,3-dichloropropene, chloropicrin, 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 pests. An effective herbicide program must also 

be developed to complement these fumigant systems. 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 pose significant challenges when determining the 

time interval needed between fumigating and planting. Initial research results suggest the plant 

back interval for the 3-WAY will be at least 3 times 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 the 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 focusing on developing and implementing a herbicide 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 3 of 15

 
program to compliment both the 3-WAY and DMDS fumigant systems as well as determining 

the amount of time that must pass between fumigating with these alternatives and planting. 

Florida 

The nutsedge, root-knot nematodes, and fungal diseases like phytopthora blight, and southern 

blights are continued to be major problems in eggplant production in Florida. In this State, 

eggplant is grown year-round, and often double cropped with pepper or cucumber following the 

eggplant harvest. The crop that follows eggplant in a double cropping production system depends 

upon prevailing environmental and economic factors. Growers in Florida often plant eggplant as 

an extra crop and grow okra, squash, or cucumbers 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 systems, and low yields. Eggplant requires a long, 

warm, frost-free growing season, usually of 14-16 weeks. Cold temperatures below 5oC injure 

this crop. The best temperatures are 27-32o

C during the day and 21-32oC during the night. Plant 

growth is curtailed at temperatures below 16oC. Additionally, soil temperature below 16oC 

restricts germination. However, most of the eggplant 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 chloropicrin due to the phase-out schedule of methyl 

bromide. At present, the standard formulation contains 50% methyl bromide in Florida. 

The best alternative, 1,3-D (Telone), may not be applied in Florida in the areas overlying karst 

geology, which is common throughout the Southeastern States. There is also a 21-day planting 

delay (vs. 14 days for MB) due to regulatory 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% Chloropicrin), applied at prebed 35 gal./acre rate 3 to 5 wks 

before transplanting. This fumigant application 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 presence of Kast topography. 

Iodomethane, a new methyl bromide alternative, was registered in the U.S., in October, 2007. 

Iodomethane, however, is not registered for use on eggplant. EPA feels 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 unavailable for U.S. eggplant, growers in the regions cited in this 

nomination would have to discontinue growing this crop or suffer substantial losses. Growers 

would either leave agriculture entirely or switch to other crops that do not rely on pre-plant 

fumigation to control soil pests. The extent of this impact on the 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 15

 
2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

Although both the 3-WAY and DMDS (dimethyl disulfide) plus chloropicrin appear promising, 

neither fumigant system will stand alone in managing 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 DMDS and chloropicrin is the most effective 

combination of these two fumigants (Culpepper et al., 2008). 

In the Southern U.S., mainly in Florida and Georgia, 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 Florida. 1,3-D (Telone 

II) 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 needed. 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 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 registered 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 certification standard for eggplant production 

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. 

A three-way fumigation system developed by University of Georgia, as well as dimethyl 

disulfide (DMDS) plus chloropicrin 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, and metam sodium. It is likely that 30 to 40% of Georgia’s 

total crop will be treated with this alternative during 2008. Dimethyl disulfide (DMDS) plus 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 5 of 15

 
chloropicrin also proven to be effective in managing many pests and has the potential to be 

adopted once the price structure is known. 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 these fumigant systems. 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 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 needed. 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 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; Gamliel et al., 2003). 

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? 

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.

USA CUN12 SOIL Eggplant Grown in Open Fields Page 6 of 15

 
6. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES 

COMPARED TO METHYL BROMIDE FOR 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 fumigants, specifically in eggplant production is not 

available in the public domain. Hausbeck and Cortright (2004) conducted 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 liters/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 plots showed yields similar to those treated with 

methyl bromide. Metam-sodium was not tested, but can 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, fumigation with 1, 3 D + chloropicrin has generally 

provided better control of fungi than metam-sodium , 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 tomatoes, 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 several pests present. 

These studies indicate that, trials show promise 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 these results would hold if fumigation were done 

under cooler spring temperatures. Further, no large scale field trials have yet been performed to 

demonstrate consistent pest control similar 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 “bridge” a discussion. Results show that 1,3-D 

followed by chloropicrin was as effective as methyl 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 eggplants. Their damage to the root 

may facilitate plant invasion by fungal pathogens, which can lead to wilt, loss of plant vigor, and 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 7 of 15

 
yield losses. Fumigant alternatives 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 vegetable 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 application 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 harvest season, thereby missing the higher market windows. Thus, since the fall 

crop is dependent upon timely planting, the required waiting period would cost growers at least 

half of the harvest season, thereby missing the higher market windows (Kelley, 2003). 

B: KEY WEEDS: Nutsedges 

TABLE 2: DATA ON TRIALS OF FUMIGANT ALTERNATIVES TO METHYL BROMIDE FOR POLYETHYLENE-MULCHED 

TOMATO (LOCASCIO ET AL. 1997)

Chemicals Rate 

(kg/ha) 

Average 

Nutsedge Density 

(#/m2) 

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 requesting 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 nutsedges than methyl bromide. Furthermore, 

there is evidence that both 1,3 D and methyl isothiocynate levels decline more rapidly due to 

enhanced degradation of these chemicals by soil 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 significantly less effective than methyl bromide 

against both purple and yellow nutsedge, although this treatment performed as well as methyl 

bromide relative to spring and fall crop yield. 1,3-D + chloropicrin, followed by more 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 8 of 15

 
chloropicrin was more effective than methyl bromide 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, considering the variable results reported elsewhere for 

these alternatives. The nutsedge populations in this study were dominated by yellow nutsedge 

(90% of the total). It is not clear if populations where purple nutsedge is dominant would be 

controlled as effectively, since other studies have shown that purple nutsedge is a hardier species. 

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 DMDS and chloropicrin is the most effective combination of these 2 chemicals 

(Culpepper et al., 2008). Present 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 that 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 transplanting, 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 University of Georgia appears to be promising as a 

methyl bromide replacement for Georgia’s eggplant 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 application (Culpepper, 2007a). In 2006, Culpepper et al. (2007a) 

tested the effectiveness of fall applications of methyl bromide 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 rates of methyl bromide 

by 50%, from 392 kg/ha under standard LDPE film to 196 kg/ha under metalized film, also 

provided excellent purple nutsedge control. Pepper yields were comparable in all treated plots. 

In a related small plot trial, conducted by Culpepper (2007b) in Echols County, Georgia, during 

the spring of 2006, excellent purple nutsedge control was achieved with 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 fumigation 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% would be unsustainable for weed control. 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 9 of 15

 
USA CUN12 SOIL Eggplant Grown in Open Fields Page 10 of 15

 

Although these results are promising, results from small 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 determine 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, including 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 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 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 alternative pest control regimens. This was done 

in order to estimate impacts on eggplant growers with the decreasing availability of methyl 

bromide. The Georgia 3-Way (1,3-dichloropropene with chloropicrin followed by metam 

sodium) was identified as being a technically feasible alternative (in cases of low pest 

infestation1 and in spring fumigations only) to methyl bromide in Georgia and Florida eggplant 

production. 1,3-D + chloropicrin is also being recognized as an alternative to methyl bromide; 

however, it is not considered technically feasible as yield losses are expected. 

The economic reviewers analyzed crop budgets 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: 

(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 

 

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 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 eggplant producers in this case. Because 

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

threshold of significant market disruption to be met if there is a significant impact on commodity 

suppliers using methyl bromide. The economic measures provide the basis for making that 

determination. 

Georgia and Florida 

In Georgia and Florida, using the Georgia 3-Way on spring plantings 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 net revenue using the Georgia 3-Way is negligible 

for Florida in comparison to methyl bromide, while gains in net revenue are expected in Georgia. 

Unlike spring plantings, however, yield losses are expected in fall plantings, with studies in 

Georgia’s application showing 50% yield losses. The Georgia 3-Way also cannot be used on 

eggplants that are grown in karst soils since it contains 1,3-D. Therefore, 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 describing Georgia eggplant production 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 production 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 bromide 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 15

 
TABLE 3: GEORGIA - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

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 numbers presented in rows indicating a “loss” should be 

interpreted as a “gain”. Positive numbers can be interpreted as losses. 

TABLE 4: FLORIDA - ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

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 numbers presented in rows indicating a “loss” should be 

interpreted as a “gain”. Positive numbers can be interpreted as losses. 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 12 of 15

 
8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES 

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

and detailed in Table 5. 

TABLE 5. NOMINATION AMOUNT: 

CITATIONS 

Aerts, M. 2003. Asst. Director, Environmental and Pest Management Division, Florida Fruit and 

Vegetable Association. Personal Communication with G. Tomimatsu, December 2, 2003. 

Banks, H. J. 2002. 2002 Report of the Methyl Bromide Technical Options Committee, 2002 

Assessment. Pg 46. 

Chellemi, D.O., R. C. Hochmuth, T. Winsberg, W. Guetler, K. D. Shuler, L. E. Datnoff, D. T. 

Kaplan, R. McSorley, R. A. Dunn, and S. M. Olson. 1997. Application of soil solarization 

to fall production of cucurbits and pepper. Proc. Fla. State Hort. Soc. 10:333- 336. 

Cortright, B. 2003. Field Research Associate University of Michigan. Personal Communication 

with G. Tomimatsu, November 24, 2003. 

Cortright, B.D. and M.K. Hausbeck. 2004. Evaluation of fumigants for managing Phytophthora 

crown and fruit rot of solanaceous and cucurbit crops, plot two, 2003. Unpublished study 

(MI CUE # 03-0061). 

Csinos, A.S., D.R. Sumner, R.M. McPherson, C. Dowler, C.W. Johnson, and A.W. Johnson. 

1999. Alternatives for methyl bromide fumigation of tobacco seed beds, pepper, and tomato 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 13 of 15

 
seedlings. Proc. Georgia Veg. Conf. Available on the Web at 

http://www.tifton.uga.edu/veg/Publications/Gfvga99.pdf 

Culpepper, A.S. 2007a. Methyl bromide CUE data generated in Georgia (Fall, 2006 – Spring, 

 2007), Appendix 1. 

Culpepper, A.S. 2007b. Impact of mulch type on rate of methyl bromide needed to control 

 nutsedge. Methyl bromide CUE data generated in Georgia (Fall, 2006 – Spring, 2007), 

 Appendix 4. 

Culpepper, A.S., A.L. Davis, T.M. Webster, A.W. MacRae, and D.L. Langston. 2007a. Bell 

 pepper and nutsedge response to fall applied methyl bromide alternative fumigants in 

 Georgia. UGA Weed Science. At: www.gaweed.com

Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. Mayfied, T. Webster, and W. 

 Upchurch. 2007b. Can Georgia growers replace methyl bromide? MBAO Conference, 

 San Diego, California, 2007. 

http://mbao.org/2007/PDF/Preplant/PP4/Culpepper(20).pdf

Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. Mayfied, T. Webster, and W. 

Upchurch. 2008. DMDS or the 3-Way: Which is more effective in Georgia. Orlando, 

Florida, 2008. http://mbao.org/2008/007Culpepper.pdf

Duncan, R. S. and S. R. Yates. 2003. Degradation of fumigant pesticides: 1,3-Dichloropropene, 

Methyl isothiocyanate, chloropicrin, and methyl bromide. Vadose Zone Journal 2:279-286. 

Florida Fruit and Vegetable Association (FFVA). 2002. Application for the Methyl Bromide 

Critical Use Exemption on Solanaceous Crops (other than tomato). September 9, 2002. 

Frank, J.R., P. H. Schwartz and W.E. Potts. 1992. Modeling the effects of weed interference 

periods and insects on bell peppers (Capsicum annuum). Weed Sci. 40:308-312. 

Gevens, A.J. and M.K. Hausbeck. 2003. A first report of Phytophthora capsici in irrigating water 

near cucurbit fields in Michigan (Abstr). 

Gilreath, J. P. B. M. Santos, T. N. Motis, J. W. Nolling, and J. M. Mirusso. 2005. Methyl 

Bromide alternatives for nematode and Cyperus control in bell pepper (Capsicum annum). 

Crop Protection 24:903-908. 

Kelley, W. T. 2003, Professor, University of Georgia. Personal communication with G. 

Tomimatsu, November 24, 2003. 

Lamour, K. H. and M. Hausbeck. 2003. Effect of Crop Rotation on the survival of 

Phytophthora capsici in Michigan. Plant Dis. 87:841-845. 

USA CUN12 SOIL Eggplant Grown in Open Fields Page 14 of 15

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

 

Lewis, C. 2003 (President, Hy-Yield Bromine). Personal communication through S.A. Toth 

(steve_toth@ncsu.edu) , Extension Entomologist & Pest Management Information 

Specialist, North Carolina State University; message forwarded electronically to G. 

Tomimatsu, December 29, 2003. 

Melban, K. 2003. California Pepper Commission. Personal Communication with G. Tomimatsu. 

Kenny@tabcomp.com. 11/26/2003. 

Noling, J. W. 2003. University of Florida-Lake Alfred. Personal Communication with G. 

Tomimatsu. Jwn@lal.ufl.edu. 11/25/2003. 

Noling, J.W., E. Rosskopf, and D.L. Chellemi. 2000. Impacts of alternative fumigants on soil 

pest control and tomato yield. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives 

and Emissions Reductions. Available on the web at http://www.mbao.org/mbrpro00.html. 

Noling, J.W. and D.A. Botts. 2007. Alternatives to methyl bromide soil fumigation for Florida 

 vegetable production. University of Florida IFAS Publication. At: 

http://edis.ifas.ufl.edu/CV290 and: 

http://edis.ifas.ufl.edu/pdffiles/CV/CV29000.pdf

Stall, W.M. and J. Morales-Payan. 2000. The critical period of nutsedge interference in tomato. 

S.W. Florida Research & Education Center. 

www.imok.ufl.edu/liv/groups/IPM/weed_con/nutsedge.htm

USDA. 2002. Crop Profiles: Florida Eggplant. 

http://pestdata.ncsu.edu/cropprofiles/docs/FLeggplant_.html

U.S. EPA. 2002. Peppers-Field. Peppers Grown Outdoors on Plastic Mulch. CUN2003/058 

Webster, T. M., A.S. Csinos, A.W. Johnson, C. C. Dowler, D. R. Sumner, R. L. Fery. 2001. 

Methyl bromide alternatives in a bell pepper-squash rotation. Crop Protection 20:605-614.