While potato is a frost vulnerable crop, simulation studies indicate there is little potato acreage in the United States where application of INA- bacteria would be economically feasible. Our analysis is based on a comparison of maximum potential gain and reasonable estimated costs. Maximum potential gains were calculated by simulating yield loss from frost induced defoliation with a computer model and estimating probability distribution functions for yield loss from historical frost records. Expected losses from these two data sets were calculated and equated with maximum potential gains. Reasonable values of cost were determined from analogous pesticides. We conclude that perhaps less than 5% of United States potato acreage will ever receive applications of INA- bacteria.