USA CUN13 SOIL Orchard Replant Open Field Page 1 of 17

-NOMINATING PARTY: The United States of America

FILE NAME: USA CUN13 SOIL ORCHARD REPLANT Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Orchard Replant in Open 

Fields (Submitted in 2011 for the 2013 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Orchard Replant Open Field

QUANTITY OF METHYL BROMIDE NOMINATED:

Year NOMINATION AMOUNT

2013 6,230 kg

NOMINATING PARTY CONTACT DETAILS:

Contact Person: John Thompson

Title: Division Director

Address: Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2658

Washington, D.C. 20520

U.S.A.

Telephone: (202) 647-9799

Fax: (202) 647-5947

E-mail: thompsonje2@state.gov

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

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

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

Signature Name Date

Title: 

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

Decision Ex. I/4(8).) 

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 CUN13 SOIL Orchard Replant Open Field Page 2 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

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 CUN13 SOIL ORCHARD REPLANT Open Field 

* Identical to paper documents
USA CUN13 SOIL Orchard Replant Open Field Page 3 of 17

METHYL BROMIDE CRITICAL USE RENOMINATION FOR 

PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT)

ORCHARD REPLANT

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

The U.S. nomination for critical use of methyl bromide for orchard replant in 2013 is for a 

portion of replant sites in California where alternatives are not suitable, either because of 

regulatory restrictions or physical characteristics, such as unacceptable soil type or moisture or 

topography. For 2013, five requests for critical use exemptions were received—stone fruit, table 

& raisin grapes, wine grapes, almonds, and walnuts. These areas represent a small portion of the 

entire orchard replant in California. 

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.

Methyl bromide continues to be a critical tool for sites that are not amenable to other treatments 

due to features such as soil type or soil moisture, or regulatory restrictions, or activity against 

certain pests, such as Armillaria root rot (e.g., Zasada et al., 2010; UC Pest Management 

Guidelines, 2008). In addition, new regulations to reduce volatile organic compound emissions 

may cause a delay of fumigation beyond October into November and December in some 

locations (e.g. San Joaquin Valley) when soils are colder. This may result in reduced efficacy of 

the primary alternative 1,3-D. Township caps also limit the use of 1,3-D. Iodomethane 

registration is pending in California. DMDS is not currently registered in California and does 

not have a label for orchard replant.

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. 

There is a critical need for methyl bromide where there are legally mandated township caps for 

1,3-D, or because surface moisture requirements cannot be met (e.g., soils cannot be adequately 

dried prior to use of 1,3-D). New regulations to reduce volatile organic compound emissions 

may reduce the efficacy of 1,3-D by requiring a delay in fumigation to November or December 

when soils are colder. The best alternatives currently registered for orchard replant are 1,3-D or 
USA CUN13 SOIL Orchard Replant Open Field Page 4 of 17

1,3-D with chloropicrin, and/or metam-sodium, especially in coarse-textured soils (e.g., Browne 

et al., 2010; Wang et al., 2010; Beede et al., 2010). Under certain soil and moisture conditions 

(less than 12% to 1.5 meters) 1,3-D is an effective management tool for replant disease and is 

currently used to replant the majority of orchard and vineyard sites. Preliminary results with

steam to disinfest soils for replant (e.g., Browne et al., 2010; Fennimore and Goodhue, 2009) and 

other non-chemical treatments are undergoing multi-year trials to assess efficacy and costs. 

Iodomethane, which may be an effective alternative, was registered in December 2010in 

California but at lower use rates than the rest of the U.S. and with buffer distances up to 10 fold 

greater (e.g., Browne et al., 2010; Cabrera et al., 2010). DMDS is not registered in California 

and the federal label does not include orchard replant at this time.

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

STANDARD?

Methyl bromide is not covered by a certification standard for orchard replant.

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

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

AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO 

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL 

BROMIDE THERE.

The current best alternatives for orchard replant are formulations of 1,3-D or 1,3-D with 

chloropicrin, and/or metam-sodium, especially in light soils (e.g., Browne et al., 2010; Wang et 

al., 2010; Beede et al., 2010; B Caprile and McKenry, 2006; Wang et al., 2009). These 

alternatives are used effectively under optimal soil temperature and moisture conditions (high 

moisture at surface and less than 12% at depths to 1.5 meters) and methyl bromide is not critical. 

There is a critical need for methyl bromide in orchards in California where alternatives cannot be 

used, either because of township caps for 1,3-D, local permit requirements for chloropicrin, 

buffer zone limitations, or surface moisture requirements cannot be met. If rain does not occur, 

growers without sprinkler systems have difficulty applying water for 1,3-D application.

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?

According to Browne et al. (2010) orchardists have shifted heavily towards use of 1,3-

dichloropropene instead of methyl bromide, but this transition does not apply to orchards with 

high clay content and orchards with township cap restrictions. Previously, McKenry et al. (2007, 

2006) and Caprile and McKenry (2006) have reported on methods that can help to replant many

orchard sites without methyl bromide. One requirement is the use of nematode-tolerant 

rootstocks, which are currently being tested (e.g., Zasada et al., 2010; Beede et al., 2010; 

McKenry and Buzo, 2009).
USA CUN13 SOIL Orchard Replant Open Field Page 5 of 17

Regulations to meet air quality standards for ground level ozone are likely to change fumigation 

practices. Pesticides that have been identified as volatile organic compounds (VOC) react with 

nitrous oxides (NOx) to form ozone. In California, the most at-risk period for fumigation has 

been identified as May 1 through October 31. 

Several areas in California, including the San Joaquin Valley and some areas of Ventura County, 

will be subject to new regulations. The San Joaquin Valley contains about two-thirds of the 

almond and stone fruit land, and about one-half of the walnut land. All sources of NOx and 

VOCs are being evaluated by the California Department of Pesticide Regulation (CDPR), which 

has the authority to regulate the use of soil fumigants. CDPR has issued a rule to reduce the 

emissions, including restrictions on timing and methods of fumigation. For example, for orchard 

replant, the only method of application allowed for methyl bromide or chloropicrin is HDPEtarped, deep-shank, broadcast fumigation. Strip applications are not allowed in the May-October 

period. In the past, most orchard replant fumigations occurred during this period. Use of 1,3 D, 

however, may not be impacted as much as other soil treatments.

6. SUMMARY OF RECENT RESEARCH 

Research in California continues to highlight methods for orchard replant to improve tree 

survival and orchard health. Future nematode control (one of the most important pests in replant 

situations) without methyl bromide will depend on integrating various techniques including 

cultural practices, genetic resistance, and alternative pesticides (Zasada et al., 2010). Recent 

research results for this sector were outlined in presentations to the 2010 Annual International 

Research Conferences on Methyl Bromide Alternatives and Emissions Reductions (Browne et 

al., 2010; Klonsky et al., 2010; Wang et al., 2010; Cabrera et al., 2010; Beede et al., 2010). In 

addition, presentations to the 2009 research conferences provided results in ongoing projects 

(Beede et al., 2009; Browne et al., 2009; McKenry and Buzo, 2009; Klonsky et al., 2009; 

Fennimore and Goodhue, 2009; Wang et al., 2009). 

Almonds and Stone Fruit: Research including USDA Pacific Area-wide Pest Management 

Program for Integrated Alternatives to Methyl Bromide has been ongoing for stone fruit and 

almond (Browne et al., 2010; Browne et al., 2009; Browne et al., 2008; Fennimore and 

Goodhue, 2009; Klonsky et al., 2009; McKenry and Buzo, 2009). Objectives of the area-wide 

research are 1) To develop and demonstrate optimized integrated pest management (IPM) 

strategies for control of almond and stone fruit replant disease without MB; 2) To provide 

comprehensive economic assessments of alternatives replant management strategies; 3) Conduct 

educational outreach facilitation adoption of effective methyl bromide alternatives in almond and 

stone fruit industries. Stone fruit and almond replant trials continue since their establishment in 

2006. 

Research in 2010 included two new almond replant trials and continued monitoring of tree 

growth, yield, and pest data from six almond and peach trials (Browne et al., 2010). Among the 

results of the research were: 1) Prunus replant disease (PRD) was prevented by soil treatments of 

chloropicrin with 1,3-D, PicClor 60, or iodomethane; 2) These treatments were more effective 
USA CUN13 SOIL Orchard Replant Open Field Page 6 of 17

than methyl bromide or 1,3-D without chloropicrin; 3) Adequate to optimal PRD management 

was achieved with spot treatments requiring treating only 10-17% of the orchard area; 4) GPScontrolled spot fumigation is available for commercial use; 5) Drip spot treatments have shown 

promise, but may require different formulations to incorporate into current irrigation systems; 6) 

Crop rotations with sudan grass can improve replanted orchard growth, but this may not be an 

economical strategy; 7) There is a great need for improved rootstocks that will help reduce or 

eliminate the need for pre-plant fumigation; 8) Alternatives that resulted in at least comparable 

yield to methyl bromide generally cost less (Klonsky et al., 2010).

Fennimore and Goodhue (2009) estimated costs of steam disinfestation of soils for almond 

replant with a commercial steam applicator from Italy and steam injection. The machine can 

disinfest an 8 x 1.5 m plot per heating, which could treat up to 0.66 ha per day. In addition, 

researchers are planning to test a tractor-pulled augur and a system to inject steam into soils. If 

research supports acceptable efficacy, costs of the sterilizing machine are estimated to be $2196 

per acre ($5425 per ha) compared to $2500 per acre ($6175 per ha) for methyl bromide 

treatment. The steam augur system was estimated to cost $341 per acre ($842 per ha) for 

planting 90 trees. Experiments to measure efficacy of steam disinfestation are planned.

McKenry and Buzo (2009) studied the possibilities of a “starve and switch” approach to almond 

replant and management of Prunus replant disease. Herbicides are used to kill remnant roots of 

previous plantings to destroy nematode nutrients and switch to a tolerant or resistant rootstock. 

While costs appear to be acceptable, the availability of acceptable rootstocks for almond replant 

is lacking.

Grapes: Multi-season field trials, as part of the USDA Pacific Area-wide Pest Management 

Program, continue to identify methods to manage vineyard pests (Wang et al., 2010; Wang et al., 

2009; Wang et al., 2008; Wang et al., 2007). Trials conducted to identify effective fumigation 

for nematode control revealed that various treatments with 1,3-D + chloropicrin were at least 

comparable to methyl bromide-treated soil (Wang et al., 2010). No nematodes were found in 

any of the fumigated plots over a year after fumigation. Unfumigated plots had populations of 

ring, pin, stubby-root and dagger nematodes. 

Trials targeting citrus nematode were conducted 1) to determine nematode sensitivity to DMDS, 

2) to evaluate the effect of time of exposure, soil moisture, and temperature on DMDS efficacy, 

and 3) to compare the effectiveness of DMDS in two different soil types (Cabrera et al., 2010). 

Results of experiments suggest that at higher doses soil type and soil temperature were not 

important factors for DMDS efficacy. At higher doses nematodes were killed after short 

exposure. The experiments did not appear to combine DMDS with chloropicrin, which will be 

the commercially available formulation. 

Recent treatments were mustard cover crop, methyl bromide shanked at 448 kg/ha under HDPE, 

1,3-D + 35% chloropicrin shanked with no tarp at 610 and at 305 kg/ha with no tarp or with VIF, 

and InLine drip at 305 kg/ha with no tarp or VIF. Preliminary results indicated that control of 

total Pythium spp. was successful in all fumigated plots except InLine without tarps. Total 

Fusarium was significantly reduced on by methyl bromide. Live citrus nematodes were only

found in the untreated plots. No other species of nematodes were found alive in any fumigated 
USA CUN13 SOIL Orchard Replant Open Field Page 7 of 17

plot. Pruning weight (a measure of plant health) was highest in the soils treated with methyl

bromide, 1,3-D + 35% chloropicrin (high rate), 1,3-D + 35% chloropicrin (low rate with VIF), 

and InLine with VIF. In addition, VIF significantly reduced fumigant emissions.

Walnuts: According to the request from the California Walnut Commission, “walnut growers 

appear to be shifting to tree site or strip applications, a short-sighted change driven by economic 

pressure.” 

Results of research on walnut was recently reported (Beede et al., 2010; Beede et al., 2009; 

Beede et al., 2008) and is an ongoing attempt to: 1) identify cost-effective commercial fumigant 

alternatives to methyl bromide including nematode control, 2) test new application technologies, 

and 3) initiate outreach to growers for walnut production, and 4) test clonal vs. seedling plant 

material. Soils treated with 1,3-D with and without chloropicrin gave effective nematode 

control. Clonal rootstocks were larger than the Paradox trees (Beede et al., 2010). 

Research continues to indicate that the continued use of the common rootstock Paradox is not 

advisable. Research continues to search for resistance to ring and lesion nematode pests. 

Various treatments (different rates and application methods) with 1,3-D, chloropicrin, and 

methyl bromide were evaluated. Conclusions from recent research (Beede et al., 2010; Beede et 

al., 2009) confirm previous findings that 1,3-D and chloropicrin show comparable pathogenic 

nematode management potential to methyl bromide. 

New trials were set-up in 2010 to compare rootstocks against the rejection and nematode 

components of the replant disease. Research toward a better rootstock is annually summarized in 

Annual Walnut Research Reports (available at http://walnutresearch.ucdavis.edu/).

7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

In this study net revenue is calculated as gross revenue minus operating costs. This is a measure 

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

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

an operation 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.

The economic analysis of the orchard replant application compares data on yields, crop prices, 

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

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

technically feasible - in cases of low pest infestation1– are different combinations of 

chloropicrin, metam sodium and 1,3- D. 

 

1

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.
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The critical use nomination (CUN) for this sector does not include areas where soil conditions 

are ideal and township caps do not restrict the use of 1,3-D. This CUN only applies to areas 

where township caps or certain soil types do not permit the use or effective use of 1,3-D. Where 

1,3-D is not permitted there are no effective nematicide alternatives to methyl bromide. Trees 

that survive are not likely to be as healthy and could suffer yield losses. If a nematode 

infestation causes the death of trees, then replacement trees would also suffer the same 

infestation unless there use of an effective nematicide, or possibly several years of fallow.

Without effective fumigation growers who replant orchards can face losses from:

• Delayed planting

• Fallow

• Additional use of herbicides

• Tree loss

• Replant costs to replace tree losses

• Loss of trees replanted

• Yield loss of fruit or nuts

• Delayed achievement of full yield potential

• Earlier loss of productivity of whole orchard

If the alternatives do not work as effectively as methyl bromide, then it is possible that other 

losses could occur, such as additional replanting, higher yield losses, and shorter lifespan of the 

whole orchard or vineyard reducing the ability to amortize the initial investment costs.

The benefits of fumigation for orchard or vineyard replant can be measured by future yields 

(orchard crops require several years to begin bearing) when production may be adversely 

affected by poor tree growth and high pest populations. In addition, fumigant treatments result 

in healthier young plants. Other fumigants besides methyl bromide are used for fumigation, but 

in some cases, such as where there are heavy soils or township caps on 1,3-D, these alternatives 

may not be available. 

The effects of orchard replant disease and nematode damage to young seedlings are experienced 

within the first three years of orchard establishment, and are commonly observed within the first 

year. Costs associated with individual tree replacement include delayed production as newly 

replanted trees lag behind previously planted ones. In more severe cases, when replant disorder 

or high nematode populations are not properly managed at the time of orchard establishment, the 

entire orchard or vineyard might be lost. Because of the long life of these perennial crops, 

optimal soil preparation, along with appropriate rootstocks, is a priority for successful 

production.
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Typically, the alternatives to methyl bromide would be evaluated using a partial budget analysis 

to estimate the impacts of changes in production practices. That is, the consequences on a 

typical hectare of the crop grown are evaluated, rather than attempt to assess the impacts in the 

context of a whole enterprise, which could include multiple crops under cultivation. This 

approach allows the Agency to compare estimated losses to net operating revenue, which is 

defined as the difference between gross revenue and variable operating costs, on a per-hectare 

basis. The analysis ignores fixed costs, which are highly dependent on land ownership and the 

size and diversity of the grower’s operation, and therefore difficult to define on a per-hectare 

basis. As such, this analysis may understate the impacts as a percentage of the grower’s income.

An analysis of a single year, however, does not capture the full benefit of fumigation. 

Establishing an orchard involves considerable costs, including the maintenance of the orchard 

during the non-bearing years. The returns to this investment occur in the future. Therefore, 

another approach to evaluating the benefits fumigation is to calculate the net present value of the 

orchard under different streams of costs and returns. Net present value (NPV) is a way of 

comparing different investments by summing the discounted costs and returns over time to 

calculate the value of the investment. The formula for NPV is:









T

t

t

t t

r

NPV

0

(1 )

Revenue Cost

where t is the time period (year), T is the last year the orchard is in production and r is the 

discount rate. This analysis uses a rate of 7% to represent a private discount rate or an 

individual’s trade-off of money between time periods2. Since revenues and costs are not adjusted 

for future inflation, all measures are in real terms.

Since the choice of discount rate is somewhat arbitrary, BEAD also presents the internal rate of 

return (IRR), which is the discount rate that makes NPV = 0. One interpretation of this value is 

that it represents the maximum rate of return on an investment that an individual must be willing 

to accept before the investment would be considered. That is, if the IRR is 5%, only individuals 

willing to accept a rate of return less than 5% would find the investment worthwhile.

California Walnuts and Almonds

The current practice for walnut replant is to fumigate with methyl bromide and chloropicrin. An 

alternative is to use 1,3-D with chloropicrin, but 1,3-D does not penetrate heavier soils as well as 

methyl bromide and may not provide as effective control of nematodes and soil pathogens. 

Some growers may not be able to obtain permission to use 1,3-D under California township caps, 

but in this case that possibility is not considered. Comparing methyl bromide and 1,3-D, both 

with chloropicrin, for establishing an orchard will be the basis for evaluating the benefits of 

methyl bromide. 

 

2 The United States Office of Management and Budget suggests using a 3% and 7% rate when evaluating 

the cost and benefits of government regulation, where 7% is an estimate of the before-tax rate of return to 

private capital (OMB, 2003).
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Replacing methyl bromide with 1,3-D, is estimated to result in a 4% decrease in yields during 

production (Carpenter et al., 2000). Yield losses are due to soil pathogens that infect the trees at 

an early age, stunting their growth. Table 1 presents the expected differences in production and 

revenue for California walnut, where operating costs are taken from Buchner et al. (2002). 

Elements of harvest costs are assumed to be directly proportional to yield and we adjust costs 

accordingly.

Table 1. Gross revenue, operating costs, and net operating revenues, California walnuts 

orchard at full production.

Methyl bromide + 

Chloropicrin

1,3-D + Chloropicrin

(% change) 1

Yield (kg/hectare) 1,505 1,445

(-4.0%)

Price ($/kg) 1.43 1.43

Gross Revenue ($/hectare) 5,315 5,101

(-4.0%)

Operating Costs ($/hectare) 1,403 1,403

Harvest Costs ($/hectare) 895 867

(-2.8%)

Net Operating Revenue ($/hectare) 3,018 2,660

(-11.9%)

Sources: USDA NASS (2002-2006), Buchner et al. (2002), BEAD calculations. Figures may not sum 

due to rounding.

1 Percent change in comparison to methyl bromide with chloropicrin.

The analysis from Table 1 indicates that even relatively minor changes in yield can have large 

effects on net operating revenue. A 4% change in yield results in a 12% change in net operating 

revenue. The analysis suggests that methyl bromide is worth about $150/hectare each year in 

terms of improved yield during the lifespan of the walnut orchard. If growers did not have access 

to methyl bromide or 1,3-D (because of township caps, for example), the consequences would be 

far more dire. 

The analysis in Table 1 does not consider the investment producers must make in establishing an 

orchard and maintaining it through several non-bearing years. Table 2 presents the information 

on the net operating revenues, NPV and IRR for a walnut orchard under the four treatment 

options. Field preparation costs are similar for any type of fumigation, but fumigation costs 

differ according to the mix of chemicals and the cost of application. Chemical costs are average 

per-hectare cost of products, which incorporates typical application rates. Tree planting costs are 

identical regardless of fumigant. BEAD assumes that some trees must be replanted the following 

year. We assume that 4%, or two trees, are replanted following fumigation with methyl bromide 

and chloropicrin (Buchner et al., 2002) but 6% are replanted with 1,3-D and chloropicrin. The 

higher replant rates represent the lower survival rate if nematodes are controlled but orchard 

replant disorder or pathogens are not. Trees begin to produce in the fourth year, initially at 10% 

of production, climbing to full production in the eighth year (Buchner et al., 2002). Returns 

during full production are shown in Table 2. 
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Table 2. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a walnut orchard.

Year Stage

Methyl 

bromide + 

chloropicrin

1,3-D + 

chloropicrin

1

Field Preparation -585 -585

Fumigation 1-3,127 -1,855

Establishment -3,789 -3,789

2 Non-bearing 2-978 -1,018

3 Non-bearing -897 -897

4 Initial production 3-637 -657

5 Partial production 5-417 -457

6 Partial production 6-106 -165

7 Partial production 61,331 1,213

8 Full production 73,018 2,660

9-25 Full production 73,018 2,660

NPV (7% discount rate) 9,495 9,495

Internal Rate of Return 13.8% 13.9%

Sources: Buchner et al. (2002), and BEAD calculations. Net operating revenues are not discounted; 

negative numbers represent costs greater than income. Net present value is calculated assuming 7% 

discount rate.

1 Fumigation costs include chemical costs and application costs. 

2 In addition to operating costs, non-bearing costs include replanting trees.

3 Initial production is 10% of full production. 

4 Production in the fifth year is 20% of full for combination treatments. 

5 Production in the sixth year is 30% of full for combination treatments. 

6 Production in the seventh year is 60% of full production for combination treatments. 

Assuming a 7% discount rate, establishing a walnut orchard, fumigating with methyl bromide 

and chloropicrin, yields future returns valued at almost $9,500/hectare today. This is about $530 

more per hectare than an hectare treated with 1,3-D and chloropicrin, although the lower initial 

cost of fumigating with 1,3-D and chloropicrin means that the internal rate of return on the two 

investments are approximately equal. The IRR for an orchards treated with methyl bromide or 

1,3-D are similar, and close to 14%. 

These results would also apply almonds grown on heavier soils. Where almonds are replanted 

after an existing almond orchard, poor vegetative growth has been observed and tree mortality

has been estimated as high as 50% (Browne et al., 2006). This would be the case where no 

fumigant is used on replant sites. With a one year fallow, but no fumigant treatment, a 25-40% 

yield loss might be experienced (depending on rootstock) with a 24-35% reduction compared to 

methyl bromide treatment (Carpenter et al., 2000).

BEAD estimates that nearly 43% of almond hectares planted and 86% of walnut plantings are 

currently treated with methyl bromide. The benefits of methyl bromide would eventually accrue 

to almost 97,000 bearing hectares of almonds and 74,000 hectares of walnut. At full production, 

additional yield is valued at about $370/hectare, therefore methyl bromide adds about $63.3 

million annually to the value of California nut production. Currently, metam sodium provides 

little benefit to producers on heavy soils. However, if chloropicrin and methyl bromide were not 

available, control of soil pathogens would depend on metam sodium. Without these fumigations, 
USA CUN13 SOIL Orchard Replant Open Field Page 12 of 17

some orchards would probably not be established at all; thus these figures may understate the full 

value of the methyl bromide. 

California Stone Fruit

Planting orchards with stone fruit trees requires a large investment of resources as well as 

numerous choices to establish a long-bearing and productive orchard. Many of the pests 

associated with these crops and fumigation requirements are similar from crop to crop and 

location to location. However, management of these pests differs depending on particular crop, 

soil type, climatic region, availability and cost of orchard land, availability of resistant rootstock 

to specific key pests, and local regulatory restrictions of some fumigants. In general, when 

fumigation is deemed necessary, few choices are available to the orchard manager.

We assess the benefits of fumigation with methyl bromide by comparing production under 

alternative approaches for controlling orchard replant disease. In this case, we focus on prune 

production in California that is broadly representative of stone fruit production with high 

fumigant use. This represents a heavy soil environment where methyl bromide and chloropicrin 

are used. We compare this use to fumigation with 1,3-D and chloropicrin, 1,3-D and metam 

sodium, and 1,3-D alone to evaluate the benefits of methyl bromide and chloropicrin. This result 

would also apply to cherry, peach and nectarine, and plum grown on heavier soils. We assume 

in this analysis that 1,3-D is available for use as a fumigant, which will not necessarily be the 

case, due to township caps in California. If neither methyl bromide or 1,3-D are available, the 

consequences are expected to be more dire. 

Replacing methyl bromide with 1,3-D, while maintaining the use of chloropicrin, is estimated to 

result in a 4% decrease in prune yields during production (Carpenter et al., 2000). Yield losses 

are due to soil pathogens that infect the trees at an early age, stunting their growth. Table 3 

presents the expected differences in production and revenue for California prune, where 

operating costs are taken from Buchner et al. (2001). Harvest costs are assumed to be directly 

proportional to yield. Differences in net operating revenue for even small changes in yield can 

be substantial. This analysis suggests that the benefits of methyl bromide alone are 

approximately $125/hectare. 
USA CUN13 SOIL Orchard Replant Open Field Page 13 of 17

Table 3. Gross revenue, operating costs, and net operating revenues, California prune 

orchard at full production.

Methyl bromide + 

chloropicrin

1,3-D + 

chloropicrin

(% change) 1

Yield (dried ton/hectare) 4.4 4.2

(-4.0%)

Price ($/ton) 1,125 1,125

Gross Revenue ($/hectare) 5,002 4,802

(-4.0%)

Operating Costs ($/hectare) 2,080 2,080

Harvest Costs ($/hectare) 1,894 1,818

(-4.0%)

Net Operating Revenue ($/hectare) 1,028 904

(-12.1%)

Sources: USDA NASS (2002-2006), Buchner et al. (2001), BEAD calculations. Figures may not sum 

due to rounding.

1 Percent change in comparison to methyl bromide with chloropicrin.

The analysis in Table 3 does not consider the investment producers must make in establishing an 

orchard and maintaining it through several non-bearing years. Table 4 presents the information 

on net operating revenue, NPV, and IRR for a prune orchard under the treatment options. Field 

preparation costs are similar for any type of fumigation, but fumigation costs differ according to 

the mix of chemicals and the cost of application. Chemical costs are average per-hectare cost of 

products, which incorporates typical application rates. Trees are planted the following spring 

and costs are identical regardless of fumigant. BEAD assumes that some trees must be replanted 

the following year. We assume that 2% are replanted following fumigation with methyl bromide 

an chloropicrin (Buchner et al., 2001); 3% are replanted with 1,3-D and chloropicrin; The higher 

replant rate represents the lower survival rate if nematodes are controlled but soil pathogens are 

not and amount to two or four trees. Trees begin to produce in the fourth year, initially at 20% of 

production, climbing to full production in the seventh year (Buchner et al., 2001). Returns 

during full production are shown in Table 4. 
USA CUN13 SOIL Orchard Replant Open Field Page 14 of 17

Table 4. Net operating revenue, net present value (NPV), and internal rate of return (IRR) 

of a prune orchard.

Year Stage

Methyl 

bromide + 

chloropicrin

1,3-D + 

chloropicrin

0 Field Preparation -618 -618

Fumigation 1-2,519 -2,025

1 Establishment -3,137 -3,137

2 Non-bearing 2-995 -1,018

3 Non-bearing -1,294 -1,294

4 Initial production 3-1,336 -1,361

5 Partial production 5-1,023 -1,072

6 Partial production 2 -82

7 Full production 1,028 904

8-40 Full production 1,028 904

NPV (7% discount rate) -874 -1,529

Internal Rate of Return 6.3% 5.7%

Sources: Buchner et al. (2001), and BEAD calculations. Net operating revenues are not discounted; 

negative numbers represent costs greater than income. Net present value is calculated assuming 7% 

discount rate.

1 Fumigation costs include chemical costs and application costs. 

2 In addition to operating costs, non-bearing costs include replanting trees.

3 Initial production is 20% of full production. On-set of production is delayed one year if 1,3-D is used 

alone.

4 Production in the fifth year is 40% of full for combination treatments. 

5

Production in the sixth year is 67% of full for combination treatments. 

Assuming a 7% rate of interest, prune production does not appear to be a good investment using 

any of the fumigation options. It may be that the information we have on production costs are 

somewhat high. Relatively speaking, however, methyl bromide provides substantial benefits 

over 1,3-D. Failure to adequately control soil pathogens substantially reduces the return to

investing in a prune orchard. This result would also apply to cherry, peach and nectarine, and 

plum grown on heavier soils. 
USA CUN13 SOIL Orchard Replant Open Field Page 15 of 17

8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

TABLE 5. NOMINATION AMOUNT:

 CA G&TFL - 

Stone Fruit 

 CA G&TFL - Raisin 

Grape

 CA Walnut

Commission 

 Almond

Hullers & 

Processors 

 CA Wine 

Grapes Replant

 Sector Total / 

Average

Quantity Requested for 2012: Amount (kgs) 12,700 626 1,844 1,660 1,494 18,324

Quantity Recommended by 

MBTOC/TEAP for 2012 :

Amount (kgs) 12,700 626 1,844 1,660 1,494 18,324

Amount (kgs) 12,700 626 1,844 1,660 1,494 18,324

Area (ha) 635 31 92 83 75 916

Rate 20 20 20 20 20 20

Transition from 2012 Baseline 

Adjusted Value

Percentage 

(%) -66% -66% -66% -66% -66% -66%

Amount (kgs)

 4,318 213 627 564 508 6,230

Area (ha) 22 1 3 3 3 31

Rate 200 200 200 200 200 200

ORCHARD REPLANT

SECTOR

Quantity Approved by Parties 

for 2012:

Quantity Required for

2013 Nomination:

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