NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 SOIL STRAWBERRY FRUIT Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: 

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

Open Fields (Submitted in 2010 for the 2012 Use Season) 

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

QUANTITY OF METHYL BROMIDE NOMINATED: 

TABLE 1: QUANTITY OF METHYL NOMINATED

Year NOMINATION AMOUNT 

2012 756,515 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).) 

This form is to be used by holders of single-year exemptions to reapply for a subsequent year’s exemption (for 

example, a Party holding a single-year exemption for 2005 and/or 2006 seeking further exemptions for 2007). It 

does not replace the format for requesting a critical-use exemption for the first time. 

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

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

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

re-submit that earlier information. 

USA CUN12 SOIL Strawberry Fruit Open Field Page 1 of 17 
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 STRAWBERRY FRUIT 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 STRAWBERRY FRUIT Open Field 

* Identical to paper documents 

USA CUN12 SOIL Strawberry Fruit Open Field Page 2 of 17 
METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT) 

STRAWBERRY FRUIT 

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

This nomination is for methyl bromide for the production of strawberries in California, Florida, 

and several other states in the southeastern U.S. (Alabama, Arkansas, Georgia, Illinois, 

Kentucky, Louisiana, Maryland, Mississippi, Missouri, New Jersey, North Carolina, Ohio, South 

Carolina, Tennessee, and Virginia). Strawberry growers have been replacing methyl bromide 

and reducing its use rates in all production areas. 

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. 

California. California growers have a critical need for methyl bromide, for 2011, to treat fields 

where alternatives are not available due to regulations or to complete a fumigation program that 

includes a once per three year treatment with methyl bromide to manage two new diseases. 

Iodomethane is unlikely to be registered for use in California in the near future and, therefore, 

cannot reduce methyl bromide critical needs. Although use of methyl bromide has been reduced 

over the years (approximately one-third of strawberry land was treated with methyl bromide in 

2006 (NASS, 2007; Table 1) this trend is in danger of being slowed if the incidences of two new 

diseases continue to increase in strawberry fields. Macrophomina and Fusarium oxysporum

have emerged in some fields that have been treated annually with alternatives (Legard, personal 

communication, 2008). These pathogens have not been found in any of the fields that have been 

treated annually with methyl bromide (Legard, personal communication, 2008). 

The lowest formulation of methyl bromide that is likely to be allowed in California is 57:43 

(methyl bromide:chloropicrin) due to severe restrictions on the use of chloropicrin. High rates of 

chloropicrin (greater than 225 kg/ha) are restricted by regulation and lower rates may not be 

optimally effective against plant pathogens. Township caps restricting the use of 1,3-D may 

affect between 5,700 and 9,000 hectares by 2011 (California Strawberry Commission, 2008—

Appendix JJ.11). 

Florida. Iodomethane is now registered in Florida. Fumigant trials indicate comparable results 

to methyl bromide. A transition from methyl bromide to iodomethane should occur quickly if 

first-users of iodomethane report successes in the 2008 and 2009 seasons. However, use rates, 

formulation and differences in application techniques require development of protocols for 

effective use of the new product. 

USA CUN12 SOIL Strawberry Fruit Open Field Page 3 of 17 
Some production areas in Florida are located above karst geological formations. For these areas, 

there are restrictions on the use of 1,3-D to prevent contamination of ground water. Fields with 

key disease problems have achieved good control with chloropicrin, but those with sting 

nematode problems require either methyl bromide or 1,3-D. Results of several years of research 

trials in Florida with low permeable films indicate that an effective rate of methyl bromide with 

these films may be as much as 50% less than the historical use rate for some Florida strawberry 

production land (Noling and Botts, 2007a; Noling and Botts, 2007b). Rates that are 25-50% 

lower than historical methyl bromide rates are being used in Florida as the use of VIF-type films 

has increased. This has allowed a reduced rate of methyl bromide while maintaining efficacy. 

Eastern Region. Growers in 15 states have reduced their use of methyl bromide from previous 

years. Continuing research and extension trials (e.g., Welker et al., 2008; Poling and Schiavone, 

2008) suggest that growers will transition to alternatives as rates and application methodologies 

are optimized. For 2012, this consortium requested on average a rate of 70 kg methyl 

bromide/ha to be used with a 50:50 (methyl bromide: chloropicrin) formulation. Diverse 

climatic areas even within a single state (e.g., coastal, mountain, piedmont) prevent a uniform 

description of an “eastern strawberry production” region. This strawberry industry is decentralized and outside of North Carolina consists of small family farms that directly market 

strawberries through “U-pick”, “ready-pick”, roadside stands, and farmers markets (Sydorovych 

et al., 2006). In the eastern U.S, many of the farms contend with yellow and purple nutsedges, 

which are significant problems in some areas more than others. Farmers with a low incidence of 

nutsedge use other chemicals, such as chloropicrin, 1,3-D, and metam-sodium to manage 

diseases such as black root rot, nematodes, and other weeds (Sydorovych et al., 2006). 

Iodomethane will likely have increased use as growers gain experience with its application. 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE 

Alternatives are considered not feasible where 1) they have not been sufficiently tested or 

protocols have not been sufficiently developed for their use, 2) costs are excessive, 3) application 

difficulties exist due to such factors as hilly terrain or equipment requirements, 4) areas of 

environmental sensitivity or characteristics reduce their efficacy, 5) regulatory restrictions 

prevent their use, 6) pest pressure is to such an extent that alternatives are not effective. 

Approximately two-thirds of strawberry land in California use alternatives to methyl bromide 

(Table 2). In California, township caps currently restrict the use of 1,3-D on approximately 40-

62% of total strawberry land (California Strawberry Commission, 2008). High rates of 

chloropicrin (greater than 225 kg/ha) are restricted by regulation and lower rates are not 

optimally effective against plant pathogens. One alternative, iodomethane, is not registered for 

use in California. 

In Florida, based on the 2010 nomination, approximately one-third of strawberry production land 

has been considered critical for methyl bromide (Table 1). In eastern U.S. production areas, 

based on the 2010 nomination, approximately 18% of strawberry production land has been 

considered critical for methyl bromide (Table 1). Iodomethane has recently been registered in all 

of the strawberry production states, except California. Its use will likely replace a significant 

USA CUN12 SOIL Strawberry Fruit Open Field Page 4 of 17 
portion of the critical use area for methyl bromide. However, because its registration is new it is 

not known how rapidly a transition to iodomethane will take place by commercial operations 

(Toth, 2008). High-percent iodomethane formulations (98:2) have not been tested rigorously to 

support research findings. Identifying effective use rates and effective formulation ratios are 

only beginning to be addressed after the 2008 registration. Equipment adaptation and product 

availability are concerns for growers who have no experience with the product. Consequently, 

while iodomethane may be a promising soil treatment, there remains a critical need for methyl 

bromide until issues of concern are satisfactorily resolved for iodomethane. 

As previously stated, some production areas in Florida are located above karst geological 

formations and there are restrictions on the use of 1,3-D. Sting nematode problems require either 

methyl bromide or 1,3-D. Some fields with key disease problems have achieved good control 

with chloropicrin, although there may be regulatory restrictions on its use at high rates. 

Alternative strategies for pest managment where weed pressure is strong include additional 

herbicides to provide acceptable weed management. However, this may require a 30-day period 

prior to planting (Noling and Botts, 2007a). Additional technical problems may be encountered, 

such as proper distribution of low rates of methyl bromide, which relies on back pressure 

measured at the flow divider (Noling and Botts, 2007a; Gilreath et al., 2005c). Noling and Botts 

(2007a) pointed out that taller and narrower beds required significantly more hand labor to lay 

VIF film due to slippage during the laying operation. Newer formulations of VIF films may help 

adjust for this problem. 

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a certification standard for strawberry fruit production. 

4. PROPORTION OF CROP USING METHYL BROMIDE 

TABLE 2. PROPORTION OF CROP USING METHYL BROMIDE

REGION WHERE METHYL 

BROMIDE USE IS REQUESTED

TOTAL CROP 

AREA (HA) 

AREA NOMINATED 

FOR METHYL 

BROMIDE USE IN 

2012 (HA) 

PROPORTION1 OF TOTAL 

CROP AREA TO BE TREATED 

WITH METHYL BROMIDE (%) 

California 14,5002 4,856 33 

Eastern U.S. (15 states) 2,6003 474 18 

Florida 3,0002 1,022 34 1

 Based on the amount of methyl bromide nominated for the 2012 use season for strawberry fruit production. 

2

 NASS, 2007. 2006-season data. 

3

 Based on estimates from various recent extension publications of states associated with the requesting consortium.

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

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

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE. 

USA CUN12 SOIL Strawberry Fruit Open Field Page 5 of 17 
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. 

Pest problems vary, and therefore, no one strategy is appropriate for the variety of pests and 

growing conditions in strawberry production. Alternatives are used on two-thirds of strawberry 

production land in California. For example, “Methyl bromide is often being used in rotation 

with alternative fumigants. Many growers will use alternative fumigants for 2-3 years then 

rotate back to methyl bromide to clean up emerging weed and disease problems. While, in some 

locations, local permit conditions may not allow the use of methyl bromide due to the proximity 

of sensitive sites such as schools or housing, thus alternative fumigants such a s Inline are used. 

In these locations, growers may accept lower returns over time due to higher weeding costs and 

reduced yields or they will cease growing strawberries in those fields if soil borne disease losses 

and weed density gets too high” (California Strawberry Commission, 2008). 

Furthermore, in California, the choice of fumigant “is influenced by a number of factors 

including the regulatory situation for a particular ranch, their financial situation—can they 

afford methyl bromide, the type of crop they are producing (summer plantings typically do not 

use methyl bromide because they have a short production season while growers in the northern 

district are more likely to use methyl bromide since they have a very long season), the 

prevalence of disease or weed problems, etc...” (Legard, personal communication, 2008). 

In the Florida and the eastern U.S., an area-wide research program (Welker et al., 2008; Welker 

et al., 2007) has highlighted successes with alternatives (e.g., InLine®, chloropicrin) and reduced 

rates of methyl bromide (150 kg ai/ha). Based on the 2010 U.S. nomination for methyl bromide, 

alternatives are used on two-thirds of strawberry land in Florida and approximately 82% of 

strawberry land in the eastern U.S. (Table 2). Preliminary research conducted on a commercial 

farm in North Carolina where black root rot and winter weeds were the key pests (with low 

nutsedge pressure) indicated that in some situations the efficacy of alternative treatments with a 

low permeable film was similar to a treatment of 300 kg methyl bromide/ha with a standard film. 

The nomination for 2011 is for areas where pest pressure is moderate to high and alternatives 

have not been sufficiently adapted to the areas of concern. 

6. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO 

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

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE 

THIS? 

In California, expansion of alternative methods to critical areas “does not appear to be likely due 

to the emergence of two new soil borne disease problems and the persistence of the yellow 

nutsedge weed problem. An alarming number of fields in Santa Maria, Oxnard and Orange 

County, that have not been fumigated with methyl bromide for more than two years, are 

USA CUN12 SOIL Strawberry Fruit Open Field Page 6 of 17 
experiencing increasing losses to charcoal rot (Macrophominia phaseolina) and Fusarium wilt 

(F. oxysporum)” (California Strawberry Commission, 2008). In addition restrictions on the use 

of 1,3-D in California and Florida limit its expansion to other areas. Research with virtually and 

totally impermeable films in California suggest that iodomethane (not registered) and 1,3-D and 

metam potassium sequential treatments could provide effective pest management and acceptable 

yields (Othman et al., 2009). If use rates, formulation, and availability issues are resolved 

iodomethane use could provide effective soil treatment for Florida and eastern U.S. strawberry 

growing areas where it is registered. 

Nevertheless, the California Strawberry Commission has funded Farming Without Fumigants 

Initiative whose goal is to develop strawberry fruit production methods that can avoid the 

complexities of highly regulated fumigants. This research includes collaboration with the 

University of California and USDA (see section “Summary of Recent Research” below). 

In Florida, iodomethane may be used in 2008 for the first time and could be a replacement for 

methyl bromide if use this season proves to be acceptable. A transition period is likely to be 

necessary to allow protocols for iodomethane to be developed for commercial production of 

strawberries in Florida. The adoption of VIF over the past two years has increased the efficacy 

of fumigants such that lower use rates are effective. 

In the eastern U.S. adoption of VIF-type films is also occurring and alternatives are being used. 

However, for some areas methyl bromide has allowed production on marginal land or in the case 

of the many small farms, land that is not able to be rotated out of strawberries due to the 

economic situation of the farmer. Iodomethane will likely present a feasible alternative with 

excellent efficacy (SE Regional Strawberry Integrated Management Guide, 2008), but as is the 

case in Florida, a transition period for adoption of iodomethane is necessary for production areas 

in the eastern U.S. to allow protocols for iodomethane to be developed for commercial 

strawberry production (Toth, 2008). 

7. SUMMARY OF RECENT RESEARCH 

California. According to Legard (personal communication, 2008) with regard to Macrophomina

and Fusarium oxysporum, “...neither disease was a problem before growers started using 

alternative fumigants, although we have not seen these disease problems in fields that have been 

strip/bed fumigated with methyl bromide (this method is used about 20% of the time in Santa 

Maria). The key consideration may be the shift from broadcast fumigation to drip fumigation. 

We are conducting studies this fall to see if high rates of fumigants applied through the drip tape 

can control these diseases. We have seen Macrophomina occur in fields that were drip 

fumigated with 100% Pic. However, growers are restricted from applying rates above 200 lbs/a, 

so we are testing higher rates to see if they are efficacious. If so, we would then need to find a 

way to convince local regulators to allow drip applications at those rates. Another reason for 

the increase in disease problems on fields not treated with methyl bromide may be related to the 

fact that MB disperses better and has a longer half-life than Pic. Straight MB does have 

fungicidal properties. Broadcast applications of straight Pic are strictly regulated and many 

USA CUN12 SOIL Strawberry Fruit Open Field Page 7 of 17 
counties either prohibit them or restrict their rates (in Ventura County they will allow only 125 

lbs/a) to levels that are not efficacious.”

Additional work has been conducted to confirm the observations from recent years that 

outbreaks of both pathogens were associated with wilting, stunting, and dying plants in coastal 

and inland strawberry production areas (Koike et al., 2009). In an attempt to address the 

problem, some growers have returned to using a methyl bromide treatment after two years 

treatment with alternatives in order to “clean-up” the soil contaminated with both emerging 

pathogens and weeds. In addition, Koike et al. (2009) found cultivar differences in susceptibility 

to the two diseases. Norton (2008) reported that excellent weed and disease control have been 

achieved with drip-applied 1,3-D/chloropicrin (InLine) followed 5-8 days later by metamsodium. However, weed control was highly dependent on optimal fumigant placement, which 

has not always been applied. 

Research continues regarding steam treatment of soils (Gilbert et al., 2009; Daugovish et al., 

2009; Fennimore et al., 2009; Fennimore and Goodhue, 2009). Results suggest that some 

treatments with steam manage various weed populations comparably to methyl bromide soil 

treatments and yields after steam treatments are similar to yields after methyl bromide. Field 

demonstrations were used to demonstrate the latest in experiments in fumigation and nonfumigation methods for strawberry production (Fennimore et al., 2009). Treatments also 

included various low- or non-permeable tarps. Steam was the only non-chemical fumigant that 

had comparable weed control compared to methyl bromide. Costs of steam treatments were 

discussed by Fennimore and Goodhue (2009) with regard to orchard replant and ornamental 

nursery beds. Yellow nutsedge was more successfully managed with steam in fall treatments 

(Daugovish et al., 2009). Physical barriers (paper and plastic mulches) appeared to reduce 

populations of nutsedge. A combination of steam and physical barriers may be effective. Work 

is continuing on steam treatment for strawberry production. 

Inovative methods of strawberry production continue with experiments to test the efficacy of 

soilless production (Gabriel et al., 2009; Wang et al., 2009; Gerik et al., 2009). Small-scale plots 

tested various substrates including peat and peat with perlite or rice hulls, and coconut coir used 

with green mulch or skunk mulch (Gabriel et al., 2009; Wang et al., 2009). Initial results 

indicated that most of the soilless treatments provided greater yields than the field soil-grown 

strawberry plants and water use, while variable, might be within acceptable parameters. 

Pathogen populations of Verticillium dahliae, Phytophthora cactorum, and Colletotrichum spp. 

were apparently affected by various treatments, but results were inconclusive at the early stages 

of testing. There was no discussion of the costs associated with this type of system for 

strawberry production or the overall feasibility of the system for California-scale production 

requirements. 

Florida and the Eastern Region. Iodomethane may offer an effective alternative to methyl 

bromide, although 2008 was the first year that it was available for use commercially. 

Consequently, uncertainties must be resolved and necessitate a critical need for methyl bromide 

for a portion of strawberry land until a transition can be complete. According to the Florida 

request for the critical use of methyl bromide, "Iodomethane has been trialed extensively in 

replicated small plot research across the crop needs and soil types currently treated with methyl 

USA CUN12 SOIL Strawberry Fruit Open Field Page 8 of 17 
bromide in Florida. We have been working with Arysta LifeSciences in evaluating various 

cropping and efficacy components of iodomethane. Midas received a registration in the state of 

Florida on July 7, 2008. We anticipate additional grower use and trial work this fall with 

further acreage of Florida strawberries, tomatoes and peppers receiving treatment. A major 

impediment to adoption of this alternative is the extensive risk mitigation and management 

requirements associated with its use. The expense of the product and complexity of 

implementing these requirements have significantly reduced the enthusiam of growers for this 

alternative." 

At a research station in North Carolina, various rates of iodomethane were tested (Poling et al., 

2009). MIDAS (iodomethane:chloropicrin) at 200 kg/ha of 50:50 with standard tarps and at 135 

kg/ha with virtually impermeable film had the highest marketable yields in the study and 

statistically similar to methyl bromide at 196 kg/ha with virtually impermeable film. The 

MIDAS rate of 135 kg/ha provided greater yields than higher rates of the product under virtually 

impermeable film. Researchers concluded that “the net benefit of using Midas 50:50 at 120 lb/A 

[135 kg/ha] with VIF could easily exceed $10,000 per acre in extra profits for the grower 

compared to no fumigation. This much economic benefit from fumigation would not likely be 

observed on sites where good crop rotation is possible, but on sites where rotation is not possible, 

a serious crop reduction may occur for growers who do not fumigate.” 

In Florida, trials were conducted that assessed iodomethane (either drip- or chisel-applied). 

Iodomethane (and various 1,3-D/chloropicrin treatments) resulted in yields that were comparable 

to methyl bromide treated plots (Noling, 2008). However, variability between test sites were 

said to be a result of application problems. These will have to be resolved prior to optimal 

commercial use of these alternatives. 

In the southeast area-wide USDA-funded trials, researchers reported (Welker et al., 2009) “we 

have had great success with the alternatives and yield data has shown comparable yields to 

methyl bromide fumigation from at least one alternative.” However, the trials showed that 

“alternatives are not nearly as forgiving as methyl bromide under less than ideal environmental 

conditions.” 

Iodomethane is also registered in the eastern strawberry-growing states comprising this 

consortium. North Carolina State University extension rated iodomethane:chloropicrin (50:50) 

as providing excellent control of diseases nematodes and good to excellent control of weeds, 

including nutsedge (Welker, 2008). A formulation of 98:2 (iodomethane:chloropicrin) has been 

marketed but not well-studied. Poling and Schiavone (2008) found that a 50:50 formulation of 

iodomethane resulted in the highest numerical total and marketable yield of any treatment, 

although not significantly different than methyl bromide. According to the researchers, “Total 

and marketable yields were significantly greater for fumigated soil than the untreated control 

treatments. Midas 50:50 at the 180 lb/A broadcast rate with standard plastic, and Midas 50:50 

at the 120 lb/A broadcast rate with VIF had the highest yields in the study, but were not 

significantly different from methyl bromide at 175 lb/A with VIF. It is very interesting that the 

lower rate of Midas 50:50 (120 lb/A with VIF) was significantly higher in total and marketable 

yield than Midas 50:50 at the 140 and 160 rates with VIF. Also, the 180 lb/A rate (with VIF) 

was 7,272 lb/A lower in marketable yield than the 120 lb/A rate of Midas 50:50 (with VIF).” 

USA CUN12 SOIL Strawberry Fruit Open Field Page 9 of 17 
Welker et al. (2008) found that in South Carolina trials weed control was achieved under VIF 

with 1,3-D/chloropicrin (35 gal Telone C35), iodomethane/chloropicrin (168 kg/ha 50:50), and 

methyl bromide/chloropicrin (146 kg/ha, 50:50). However yield was significantly reduced with 

the 1,3-D/chloropicrin. Researchers suspected that under VIF, that rate was too high stunted 

plants. In North Carolina trials, drip applied 1,3-D/chloropicrin (InLine) and PicClor 60 resulted 

in excellent annual weed control under VIF, where previous data had indicated unacceptable 

weed control. Extension conducted an on-farm field day, which provided information on methyl 

bromide alternatives to growers. 

Norton (2008) reported that use of 1,3-D/chloropicrin followed by metam-sodium with 

appropriate water moisture could achieve excellent disease and weed control. A 21-d waiting 

period was required prior to transplanting. As with the situation in Florida, use experience, 

availability, and equipment and rate adjustments for the new product may require a period of 

transition for a portion of strawberry land making some methyl bromide critical for 2011. 

8. ECONOMIC FEASIBILITY OF ALTERNATIVES 

The following economic analysis is organized by regions. In this study net revenue is calculated 

as gross revenue minus operating costs. This is a good measure to describe the direct losses of 

income that may be suffered by the users. The 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. Fixed costs were not included because it is often difficult to measure and 

verify. 

Summary of Economic Feasibility 

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

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

estimate the loss of methyl bromide availability. The alternatives identified as technically 

feasible in cases of low pest infestation for Florida and the eastern U.S. states are: (a) 

iodomethane/chloropicrin and (b) 1,3-D/chloropicrin followed by metam sodium. For 

California, the primary alternative is 1,3-D/chloropicrin followed by metam sodium. 

Iodomethane is not registered for use in California. 

The economic factors that drive the feasibility analysis for fresh market strawberry fruit use of 

methyl bromide are increased production costs, which may be due to the higher-cost of using an 

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

harvesting practices and yield losses. 

Crop budgets were analyzed for pre-plant sectors to determine the likely economic impact if 

methyl bromide were unavailable. Various measures were used to quantify the impacts, 

including the following: 

USA CUN12 SOIL Strawberry Fruit Open Field Page 10 of 17 
(1) Loss per Hectare. For crops, this measure is closely tied to income. It is relatively easy to 

measure, but may be difficult to interpret in isolation. 

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

bromide to crop production. 

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

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

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

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

impacts on the profitability of the activity. 

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

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

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

be difficult to measure and verify. 

(5) Operating Profit Margin. Operating profit margin is defined as net operating revenue 

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

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

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

in the analysis. 

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

alternatives for strawberry fruit producers. Because producers (suppliers) represent an integral 

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

a significant impact on commodity suppliers using methyl bromide. The economic measures 

provide the basis for making that determination. 

In the case of strawberry fruit production, for the eastern growers who have access to 

iodomethane, an impact of 1-4% in gross revenue is expected in the first year of use due to 

increased costs to retrofit application equipment (hoses, nozzles, flow meters) that will allow the 

use of iodomethane. This cost is estimated to be approximately $600-$700 per acre based on 

USG estimates. Southeastern and Florida strawberry growers who use iodomethane are expected 

to experience no change in yield or quality (see tables 3 and 4 below). 

For California strawberry producers, there is no change in impacts from previous years’ 

estimates as iodomethane is not expected to be registered in the near future. The loss to gross 

revenue for growers using alternatives to methyl bromide is estimated to remain about 14% as 

compared to the use of methyl bromide. Table 5 illustrates the 2008 economic impact 

assessment for California strawberry fruit growers. 

USA CUN12 SOIL Strawberry Fruit Open Field Page 11 of 17 
TABLE 3. FLORIDA FRUIT AND VEGETABLE GROWERS ASSOCIATION : ECONOMIC IMPACTS OF METHYL 

BROMIDE ALTERNATIVES

FLORIDA FVGA METHYL BROMIDE IODOMETHANE 1,3 D + PIC 

PRODUCTION LOSS (%) 0% 0% 14% 

 PRODUCTION PER HECTARE 2,989 2,989 2,559 

* PRICE PER UNIT (US$) $ 32.80 $ 32.80 $ 32.8 

= GROSS REVENUE PER HECTARE (US$) $ 98,064 $ 98,064 $ 83,942 

- OPERATING COSTS PER HECTARE (US$)** $ 52,571 $ 56,525 $ 51,586 

= NET REVENUE PER HECTARE (US$) $ 45,493 $ 41,538 $ 32,086 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $ 0 $ 3,955 $ 13,407 

2. LOSS PER KILOGRAM OF METHYL BROMIDE 

(US$) $ 0 $ 16.8 $ 56.96 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE 

(%) 0% 4% 14% 

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0% 9% 29% 

5. OPERATING PROFIT MARGIN (%) 46% 42% 38% 

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

costs and net revenue equals gross revenue minus operating costs. 

TABLE 4. SOUTH EASTERN STRAWBERRY COMMISSION : ECONOMIC IMPACTS OF METHYL BROMIDE 

ALTERNATIVES

South Eastern Strawberry Commission METHYL BROMIDE IODOMETHANE 1,3 D + PIC 

PRODUCTION LOSS (%) 0% 0% 0% 

 PRODUCTION PER HECTARE 14,011 14,011 12,044 

* PRICE PER UNIT (US$) $ 2.89 $ 2.89 $ 2.89 

= GROSS REVENUE PER HECTARE (US$) 40,463 $ 40,463 $ 34,784 

- OPERATING COSTS PER HECTARE (US$)** $ 33,175 $ 33,611 $ 32,744 

= NET REVENUE PER HECTARE (US$) $ 7,288 $ 6,853 $2,039 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $ 0 $ 436 $ 5,249 

2. LOSS PER KILOGRAM OF METHYL BROMIDE 

(US$) $ 0 $ 2.88 $ 34.69 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE 

(%) 0% 1% 13% 

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0% 6% 72% 

5. OPERATING PROFIT MARGIN (%) 18% 17% 6% 

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

costs and net revenue equals gross revenue minus operating costs. 

USA CUN12 SOIL Strawberry Fruit Open Field Page 12 of 17 
TABLE 5. CALIFORNIA : ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES

CALIFORNIA METHYL BROMIDE PIC + MB 1,3 D + PIC 

PRODUCTION LOSS (%) 0% 15% 14% 

 PRODUCTION PER HECTARE 49,410 41,999 42,475 

* PRICE PER UNIT (US$) $ 1.37 $ 1.37 $ 1.37 

= GROSS REVENUE PER HECTARE (US$) $ 67,537 $ 66,020 $ 58,057 

- OPERATING COSTS PER HECTARE (US$)** $ 66,849 $ 57,432 $ 66,100 

= NET REVENUE PER HECTARE (US$) $ 688 ($ 8,614) ($ 8,042) 

LOSS MEASURES * 

1. LOSS PER HECTARE (US$) $ 0 $ 9,302 $ 8730 

2. LOSS PER KILOGRAM OF METHYL BROMIDE 

(US$) $ 0 $ 46.36 $ 43.51 

3. LOSS AS A PERCENTAGE OF GROSS REVENUE 

(%) 0% 14% 13% 

4. LOSS AS A PERCENTAGE OF NET OPERATING 

REVENUE (%) 0% `1352% 1269% 

5. OPERATING PROFIT MARGIN (%) 4% -15% -14% 

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

costs and net revenue equals gross revenue minus operating costs. 

USA CUN12 SOIL Strawberry Fruit Open Field Page 13 of 17 
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 6. 

TABLE 6. NOMINATION AMOUNT: 

USA CUN12 SOIL Strawberry Fruit Open Field Page 14 of 17 
CITATIONS

California Strawberry Commission. 2008. Request for a critical use exemption for methyl 

bromide on strawberries for the 2011 use season. 

Daugovish, O., Mochizuki, M., and Fennimore, S. 2009. Yellow nutsedge management with 

chemical, physical and thermal treatments. International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/014DaugovishOSummaryNutsedge.pdf

Fennimore, S., Ajwa, H., Subbarao, K., Martin, F., Browne, G., and Samtani, J. 2009. 

Facilitating adoption of alternatives to methyl bromide in California strawberries. 

International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions (2009). 

http://www.mbao.org/2009/Proceedings/016FennimoreSprogressreportstrawberryAWP8170

9.pdf

Fennimore, S. and Goodhue, R. 2009. Estimated costs to disinfest soil with steam. Annual 

International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions (2009). 

http://www.mbao.org/2009/Proceedings/003FennimoreSMBAOAbstractSteambusiness.pdf

Gabriel, M. Z., Wang, D., Gerik, J., and Gartung, J. 2009. Strawberry production in soil-less 

substrate troughs—plant growth. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/098GabrielMMBAO2009MagdalenaRaBetplants.p

df

Gerik, J., Wang, d., Gabriel, M. Z., and Gartung, J. 2009. Strawberry production in soil-less 

substrate troughs—pathology. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/099GerikJMBAO2009Pathology.pdf

Gilbert, C., Fennimore, S., Subbarao, K., Hanson, B., Rainbolt, C., Goodhue, R., Weber, J. B., 

and Samtani, J. 2009. Systems to disinfest soil with heat for strawberry and flower 

production. Annual International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/015FennimoreSMBAOAbstractSteamSolar82809.p

df

Gilreath, J., Santos, B., Mirusso, J., Noling, J., and Gilreath, P. 2005c. Application 

considerations for successful use of VIF and metalized mulches with reduced fumigant rates 

in tomato. U. Florida Extension publ. HS287. 

http://edis.ifas.ufl.edu/pdffiles/HS/HS27000.pdf

USA CUN12 SOIL Strawberry Fruit Open Field Page 15 of 17 
Koike, S., Gordon, T., Ajwa, H., Daugovish, O., Bolda, M., Legard, D. 2009. Fumigant and 

strawberry variety evaluations in Macrophomina and Fusarium fields. 

http://www.mbao.org/2009/Proceedings/013DaugovishOSummaryPathogens.pdf

Legard, D. 2008. Personal communication, email 24 September, 2008. 

NASS (National Agriculture Statistics Service), 2007. Agricultural Chemical Usage 2006 

Vegetable Summary. 

http://usda.mannlib.cornell.edu/usda/current/AgriChemUsVeg/AgriChemUsVeg-07-25-

2007_revision.pdf) 

Noling, J. W. 2008. Large scale demonstration trialing of methyl bromide alternatives in Florida 

strawberry. Annual International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions (2008). 

http://www.mbao.org/2008/Proceedings/010NolingJMBAO2008USDAAreaWide.pdf

Noling, J. W. and Botts, D. A. 2007a. The Vegetable Production Handbook for Florida, 2007. 

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

Noling, J. W. and Botts, D. A. 2007b. Grower field demonstration trials of methyl bromide 

alternatives in Florida strawberry. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2007). 

http://www.mbao.org/2007/Proceedings/052NolingMBAO2007CSREES.pdf

Norton, J. A. 2008. Metam combinations as alternatives to methyl bromide in US-grown 

strawberries and mulched vegetables. Annual International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2008). 

http://www.mbao.org/2008/046Norton.pdf

Othman, M., Ajwa, H. A., Fennimore, S., Martin, F., Subbarao, K., Browne, G., and Hunzie, J. 

2009. Strawberry production with reduced rates of methyl bromide alternatives applied 

under retentive film. Annual International Research Conference on Methyl Bromide 

Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/055OthmanMAbstract2009Strawberryproductionwi

thReducedRatesofMethylBromideAlternatives.pdf

Poling, E. B., Schiavone, R., and Franck, C. T. 2009. Influence of MIDAS 50:50 and MIDAS 

98:2 on strawberry plasticulture yields in North Carolina. Annual International Research 

Conference on Methyl Bromide Alternatives and Emissions Reductions (2009). 

http://mbao.org/2009/Proceedings/113PolingBsummary.pdf

Poling, E. B. and Schiavone, R. 2008. Strawberry plasticulture research with MIDAS 50:50 and 

MIDAS 98:2 in North Carolina, 2007-2008 (Central Crops Research Station, Clayton). 

http://ncsu.edu/enterprises/strawberries/files/2009/09/poling-report2007_2008.pdf

USA CUN12 SOIL Strawberry Fruit Open Field Page 16 of 17 
USA CUN12 SOIL Strawberry Fruit Open Field Page 17 of 17 

SE Regional Strawberry Integrated Management Guide. 2008. 

http://www.smallfruits.org/SmallFruitsRegGuide/Guides/2008/08StrawberryIntegMgmtGu

ideDec10.pdf

Sydorovych, O., Safley, C. D., Ferguson, L. M., Poling, E. B., Fernandez, G. E., Brannen, P. M., 

Monks, D. M., and Louws, F. J. 2006. Economic evaluation of methyl bromide alternatives 

for the production of strawberries in the Southeastern United States. 

http://www.ncsu.edu/project/berries/extension/FINAL%20strawberry%20MB%20budget.pdf

Toth, S. 2008. Personal communication, email to C. Augustyniak, November 4, 2008. 

Wang, Gartung, J., Vaughan, P., Gerik, J., Gabriel, M. Z., and Legard, D. 2009. Strawberry 

production in soilless substrate troughs—water management. Annual International Research 

Conference on Methyl Bromide Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/017WangDMBAO2009RaBetwater.pdf

Welker, R. M., Driver, Rivard, C. L., and Louws, F. J. 2009. Research and extension efforts to 

enable successful transition away from methyl bromide fumigation. Annual International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2009). 

http://www.mbao.org/2009/Proceedings/041WelkerRMBAOProceedings2009.pdf

Welker, R. 2008. Choosing alternatives to methyl bromide for strawberries. North Carolina Pest 

News vol 23, number 12, June 27, 2008. Stephen Toth, ed. 

http://ipm.ncsu.edu/current_ipm/08PestNews/08News12/pestnews.html

Welker, R. M., Driver, J. G., Smith, J. P., Schiemann, C. A., and Louws, F. J. 2008. On-farm 

research and extension activities to implement MB alternatives: an area wide initiative 

update. Annual International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions (2008). 

http://www.mbao.org/2008/Proceedings/009WelkerRMBAOAREAWIDEFJL.pdf

Welker, R. M., Driver, J. G., Smith, J. P., Brannen, P. M., Schiemann, C. A., and Louws, F. J. 

2007. On-farm research to implement MB alternatives: an area wide initiative. Annual 

International Research Conference on Methyl Bromide Alternatives and Emissions 

Reductions (2007). 

http://www.mbao.org/2007/Proceedings/022LOUWSareaWideMBAO07.pdf.