USA CUN11 SOIL Strawberry Fruit Open Field Page 1 of 14 

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 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 2009 for 2011 Use Season)

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

QUANTITY OF METHYL BROMIDE REQUESTED: 

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

Year NOMINATION AMOUNT 

2011 1,023,471 kilograms 

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Hodayah Finman 

Title: Foreign Affairs Officer 

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) 647-1123 

Fax: (202) 647-5947 

E-mail: finmanhh@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 CUN11 SOIL Strawberry Fruit Open Field Page 2 of 14 

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Jack Housenger 

Title: Director (Acting) 

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 CUN11 SOIL STRAWBERRY FRUIT Open Field 14 

 

 

 

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 CUN11 SOIL STRAWBERRY FRUIT Open Field 

 

 

 

* Identical to paper documents 
USA CUN11 SOIL Strawberry Fruit Open Field Page 3 of 14 

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 eastern 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. 

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 is likely to 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. Until sufficient experience is gained with iodomethane, methyl 

bromide is considered critical for a portion of land for the 2011 use season. 

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 high barrier 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 
USA CUN11 SOIL Strawberry Fruit Open Field Page 4 of 14 

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 the eastern U.S. have reduced their use of methyl bromide from 

previous years. Continuing research and extension (e.g., Welker et al., 2008) suggests that 

growers will transition to alternatives as rates and application methodologies are optimized. For 

2011, 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 de-centralized 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 

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, 
USA CUN11 SOIL Strawberry Fruit Open Field Page 5 of 14 

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 

2010 (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 2010 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. 

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. 
USA CUN11 SOIL Strawberry Fruit Open Field Page 6 of 14 

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 

high barrier films 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 

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. If use rates, formulation, 

and availability issues are resolved iodomethane could expand in 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. 

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 
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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 

counties either prohibit them or restrict their rates (in Ventura County they will allow only 125 

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

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. 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 metam-sodium. However, weed control was highly dependent on optimal fumigant 

placement, which has not always been applied. 

Fennimore et al. (2008) reported: 

• High barrier tarps improve efficacy at reduced rates of drip-applied 1,3-D, iodomethane, 

and methyl bromide. This effect did not appear to occur with chloropicrin used alone. 

• Drip applied 1,3-D/chloropicrin (InLine), iodomethane/chloropicrin, and methyl 

bromide/chloropicrin resulted in comparable yields in two locations. 

• Totally impermeable films glued well and enhanced retention of 1,3-D, iodomethane, and 

methyl bromide compared to standard films. 

• Test plots that were treated with steam and Brassica meal provided good yields in two 

locations. 
USA CUN11 SOIL Strawberry Fruit Open Field Page 8 of 14 

• Test plots treated with steam also provided good weed control. 

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

bromide, although 2008 is the first year where it can be used commercially. Consequently, 

certain 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 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." 

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. 

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).” 

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. 
USA CUN11 SOIL Strawberry Fruit Open Field Page 9 of 14 

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 methyl bromide critical use application 

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. 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. 

Summary of Economic Feasibility 

The economic analysis of the strawberry fruit application 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 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: 

(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 
USA CUN11 SOIL Strawberry Fruit Open Field Page 10 of 14 

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 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 that 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 that 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 year estimates 

as iodomethane is under registration review but registration is not expected 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 CUN11 SOIL Strawberry Fruit Open Field Page 11 of 14 

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 CUN11 SOIL Strawberry Fruit Open Field Page 12 of 14 

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. 

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: 2011 Methyl Bromide Usage Newer Numerical 

 Index (BUNNI) – Transition Use Reduction Description Spreadsheet.

 California 

Strawberry 

Commission 

 Eastern Strawberry Florida Strawberry Sector Total / Average 

Quantity Requested for 2010: Amount (kgs) 47,862 952,543 103,017 1,103,422 

Quantity Recommended by 

MBTOC/TEAP for 2010 : Amount (kgs) 47,862 856,598 103,017 1,007,477 

Amount (kgs) 47,862 856,598 103,017 1,007,477 

Area (ha) 299 4,370 644 5,313 

Rate 160 196 160 190 

Transition from 2010 

Baseline Adjusted Value Percentage (%) 0% -52% -53% -7%

Amount (kgs) 22,848 952,543 48,080 1,023,471 

Area (ha) 5443 143 300 5886

Rate 160 175 160 174 

SECTOR

STRAWBERRY FRUIT

Quantity Approved by Parties 

for 2010:

Quantity Required for 

2011 Nomination:
USA CUN11 SOIL Strawberry Fruit Open Field Page 13 of 14 

CITATIONS

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

bromide on strawberries for the 2011 use season. 

Fennimore, S., Ajwa, H., Subbarao, K., Martin, F., Browne, G., Klose, S. 2008. Facilitating 

adoption of alternatives to methyl bromide in California strawberries. Annual International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008). 

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 

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). 

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

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). 

[Provided by author] 

SE Regional Strawberry Integrated Management Guide. 2008. 

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

ideDec10.pdf
USA CUN11 SOIL Strawberry Fruit Open Field Page 14 of 14 

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. 

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 alteratives: an area wide initiative 

update. Annual International Research Conference on Methyl Bromide Alternatives and 

Emissions Reductions (2008). 

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.