1.

The
applicant,
International
Paper,
grows
bareroot
pine
SuperTree
seedlings
at
nine
(
9)
nurseries
in
the
Arkansas
(
1
nursery)
Alabama
(
2)
Georgia
(
2)
South
Carolina
(
2)
Texas
(
2)

2.

3.

4.

Light
X
Medium
Heavy
0
to
2%
X
2
to
5
%
over
5%

5.

6.
Specialty
(
check
one)

7.
agronomic
8.
economic
X
9.
Daytime
phone
10.
FAX
11.
912­
238­
6131
Savannah,
Georgia
31402
richard.
barham@
ipaper.
com
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
The
following
information
will
be
used
to
determine
the
amount
of
methyl
bromide
requested
and
the
contact
person
for
this
request.
It
is
important
that
we
know
whom
to
contact
in
case
we
need
additional
information
during
the
review
of
the
application.

Other
geographic
factors
that
may
affect
crop/
commodity
yield
(
e.
g.,
water
table).

International
Paper
Soil
Type:
Organic
Matter:
Soil
type
Check
the
boxes)
for
the
soil
types
and
percent
organic
matter
that
apply
to
your
area.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
soil
type.
International
Paper
is
the
world's
largest
seedling
grower
producing
over
350MM
bareroot
pine
SuperTree
seedlings
in
the
southeast.
To
date
we
have
produced
nearly
8
billion
forest
tree
seedlings
in
the
U.
S.
alone,
and
last
year
we
planted
our
6
millionth
acre
of
forestland
in
the
U.
S.
SuperTree
seedling
customers
consist
of
private
non­
industrial
land
owners,
forest
industry,
and
various
government
agencies.
Our
customers
use
SuperTree
seedlings
for
reforestation,
wildlife
enhancement,
and
aesthetic
and
ecosystem
regeneration.
Greater
than
95%
of
our
southeastern
nursery
production
consists
of
bareroot
loblolly
(
Pinus
taeda
),
slash
(
Pinus
elliotti
i),
sand
(
Pinus
clausa
),
and
virginia
(
Pinus
virginiana
)
pines.

None
regions
7,
and
8.
Crop/
commodity
(
Include
all
crops/
commodities
that
benefit
from
the
application
of
methyl
bromide
in
a
fumigation
cycle.
A
fumigation
cycle
is
the
period
of
time
between
methyl
bromide
fumigations.)

Climate
(
Individual
users
should
enter
their
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
climate
zone.
This
map
is
located
at
the
end
of
this
workbook
or
it
can
be
reviewed
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html).
International
Paper's
SuperTree
seedlings
represent
a
diverse
array
of
genetic
adaptability
and
can
be
planted
throughout
Consortium
name
E­
mail
Address
912­
238­
7595
P.
O.
Box
1391
For
EPA
Use
Only
ID#

Location
(
Enter
the
state,
region,
or
county.
Provide
more
detail
about
the
location
if
relevant
to
the
feasibility
of
alternatives
to
methyl
bromide.)

following
southeastern
states:

regions
6,
7,
and
8
as
defined
by
the
U.
S.
climate
zone
map.
Bareroot
SuperTree
seedling
nurseries
are
located
in
Contact
name
Mr.
Richard
Barham
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
List
an
additional
contact
person
if
available.
Specialty
(
check
one)

12.
agronomic
X
13.
economic
14.
15.
FAX
16.
17.
92,000
lbs.

17a.
Acres
units
18.
Yes
X
No
18a.
Are
you
requesting
methyl
bromide
for
additional
years
beyond
2005?
912­
739­
4721
912­
739­
9409
For
EPA
Use
Only
ID#

P.
O.
Box
56
Dr.
George
Lowerts
Acres
If
a
consortium
is
submitting
this
application,
the
data
for
question
17
and
17a.
should
be
the
total
for
the
consortium.
In
the
question
below,
area
is
defined
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post
harvest
operations,
and
square
feet
for
structural
applications.

2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
92,000
Area
to
be
Treated
270
If
yes,
please
list
year
and
quantity
active
ingredient
(
ai)
of
methyl
bromide
requested
in
the
table
below
and
explain
why
you
need
authorization
for
multiple
years.

A
portion
of
all
International
Paper
SuperTree
seedling
nurseries
are
fumigated
each
year.
The
request
for
a
Critical
Use
Exemption
is
based
on
this
annual
application
requirement.

2006
92,000
lbs
If
a
consortium
is
submitting
this
application,
the
data
below
should
be
the
total
for
the
consortium.

270
Requests
beyond
2005
How
much
active
ingredient
(
ai)
of
methyl
bromide
are
you
requesting
for
2005?
Contact
name
Address
Daytime
phone
E­
mail
2007
Unit
of
Area
Treated
92,000
Year
Acres
2007
92,000
lbs
Bellville,
Georgia
30414
george.
lowerts@
ipaper.
com
How
much
area
will
this
be
applied
to?
Please
list
units.
270
In
the
table
below,
area
is
defined
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post
harvest
operations,
and
square
feet
for
structural
applications.
19.

20.

20a.

OMB
Control
#
2060­
0482
destruction
of
pine
seedling
crops.
Seedling
quality
is
also
reduced
by
nematodes
which
attack
pine
seedlings.
Fumigation
with
methyl
bromide
has
been
demonstrated
to
effectively
control
the
following
genera:
Criconemoides,
and
Helicotylenchus.
There
is
no
other
product
or
control
method
available
that
will
economically
and
practically
control
all
of
the
above
pathogens
and
pests
as
does
a
single
methyl
bromide
fumigation.
After
many
years
of
investigating
integrated
pest
management
alternatives
including
solarization,
organic
amendments,
and
cultural
controls,
Weyerhaeuser
has
concluded
no
single
alternative
has
the
broad
spectrum
biocidal
efficacy
of
methyl
bromide
(
EPA,
2002).
A
description
of
the
economic
and
environmental
impact
associated
with
a
withdrawal
of
methyl
bromide
on
International
Paper
and
on
southeastern
forestry
can
be
found
in
appendix
4.
Target
Pest(
s)
or
Pest
Problem(
s):
(
Be
as
specific
as
possible
about
the
species
or
classes
of
pests
relevant
to
the
feasibility
of
alternatives.)

Explain
why
this
user
represents
the
typical
user
in
the
consortium.
At
all
International
Paper
SuperTree
nurseries,
methyl
bromide
fumigation
is
a
cost
effective
and
essential
treatment
for
the
production
of
bareroot
pine
seedlings.
Methyl
bromide
fumigation
is
critical
for
the
control
of
weed
(
broadleaf
and
grasses)
seed,
particularly
yellow
and
purple
(
Cyperus
spp.
)
nutgrass
since
there
is
no
other
control
product
or
economically
feasible
control
method
available.
Both
yellow
and
purple
nutsedge
are
included
in
the
United
Nations
list
of
the
world's
top
ten
worst
weeds.
Without
methyl
bromide
fumigation,
nutgrass
will
rapidly
dominate
seedling
production
areas
reducing
seedling
quality
to
such
an
extent
that
the
crop
may
not
be
suitable
for
reforestation
and
ecosystem
regeneration.
As
a
quarantine
measure,
the
USDA
requires
all
shipments
of
seedlings
to
be
free
of
fire
ants
(
Solenopsis
invicta
).
Methyl
bromide
fumigation
is
the
only
practical
method
for
controlling
fire
ants
over
large
areas.
In
addition,
many
soil
fungal
pathogens
(
ex.
Macraphomia
spp.,
Cylindrocaldium
spp.,
Fusarium
spp.,
Pythium
spp.,
Rhizoctonia
spp.
)
are
effectively
controlled.
These
root
rot
pathogens
have
the
ability
to
literally
result
in
the
Representative
User
For
EPA
Use
Only
ID#

Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
International
Paper
has
nine
(
9)
SuperTree
seedling
nurseries
in
the
southeast
that
range
in
size
from
100
to
200
plantable
acres.
A
typical
International
Paper
nursery
has
about
140
acres
available
for
growing
bareroot
seedlings
in
any
given
year.
Of
these
140
acres,
only
70
acres
are
used
each
year
for
growing
seedlings.
Our
nurseries
operate
with
a
2:
2
crop
rotation
consisting
of
two
years
in
seedlings
and
two
years
in
cover
crop
with
methyl
bromide
fumigation
applied
to
the
soil
just
before
sowing
the
seedling
crop.
Of
the
total
amount
of
land
used
to
grow
seedlings
every
year
approximately
one­
half
is
fumigated
each
year,
thus,
our
typical
International
Paper
nursery
would
fumigate
35
of
the
70
acres
available
for
growing
seedlings
each
year.
Across
all
nine
SuperTree
nurseries,
we
expect
to
fumigate
approximately
270
acres
each
year.
If
applying
as
a
consortium
for
many
users
of
methyl
bromide,
please
define
a
representative
user
.
Define
exactly,
issues
such
as
size
of
the
operation
(
acres
treated
with
methyl
bromide
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications),
whether
the
representative
user
owns
or
rents
the
land
or
operation,
intensity
of
methyl
bromide
use
(
treat
regularly
or
only
when
pest
reaches
a
threshold),
pest
pressure,
etc.
Col
A:
Formulation
of
Methyl
Bromide
Col
B,
E,
H,
K:
Actual
Area
Treated
Col
C,
F,
I,
L:
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Col
D,
G,
J,
M:
Actual
Average
lbs.
ai
Applied
per
Area
A
B
C
D
E
F
G
H
I
J
K
L
M
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
over
95%
methyl
bromide
334
126,144
378
193
70,170
364
413
151,775
367
143
52,336
366
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
10
2,350
235
24
5,640
235
39
9,165
235
17
4,053
238
50%
methyl
bromide,
50%
chloropicrin
90%
methyl
bromide,
10%
chloropicrin
4
1,253
313
136
40,785
313
57%
methyl
bromide,
43%
chloropicrin
2
456
228
All
formulations
of
methyl
bromide
344
128,494
374
217
75,810
349
456
162,193
356
298
97,630
328
Comments:

OMB
Control
#
2060­
0482
The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
area
are
automatically
calculated
from
the
previous
2
columns.
2000
Enter
the
total
actual
area
treated.
Note:
This
number
should
be
the
total
actual
area
treated
by
the
individual
user
or
total
actual
area
for
the
entire
consortium,
for
the
year
indicated.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Formulation
of
Methyl
Bromide
Enter
the
actual
total
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied.
Note:
This
number
should
be
the
total
pounds
ai
applied
by
the
individual
user
or
the
entire
consortium,
for
the
year
indicated.

1997
1998
1999
For
EPA
Use
Only
ID#

Worksheet
2­
A.
Methyl
Bromide
­
Use
1997­
2000
Enter
the
appropriate
data
in
Col
B­
M
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations.
If
you
enter
only
the
total
and
averages
for
all
formulations
in
the
last
row
of
the
table,
please
describe
in
the
comments
section
the
formulations
typically
used,
or
the
approximate
proportions
of
the
formulations
used.

If
a
consortium
is
submitting
this
application,
all
data
should
reflect
the
actual
data
for
the
consortium.
For
EPA
Use
Only
ID#

A
C
D
E
F
Year
Methyl
Bromide
was
Applied
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
acres
Price
(
per
unit
of
crop/
commodity)

thousand
seedling
Revenue
(
per
area)
acres
1997
per
thousand
trees
658
$
34
$
22,372
1998
per
thousand
trees
658
$
36
$
23,688
1999
per
thousand
trees
658
$
37
$
24,017
2000
per
thousand
trees
658
$
39
$
25,662
Total
Revenue
for
1997
$
22,372
Total
Revenue
for
1998
$
23,688
Total
Revenue
for
1999
$
24,017
Total
Revenue
for
2000
$
25,662
Average
Revenue
Per
Year
$
23,935
Comments:
The
last
two
years
of
the
four
year
cycle
are
in
cover
crop
which
does
not
generate
revenue.

OMB
Control
#
2060­
0482
Worksheet
2­
B.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
1997­
2000
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
actual
averages
for
the
consortium.

Enter
the
average
prices
received
by
the
users
for
the
year
and
crop/
commodity
indicated
(
1997­
2000).

This
number
is
calculated
automatically
using
the
values
you
entered
in
Cols.
D
and
E.
You
may
override
the
formula
to
enter
a
different
revenue.
Please
explain
why
the
revenue
amount
is
different
in
the
comment
section
below.

Enter
the
unit
of
measurement
for
each
crop/
commodity.

Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
commodities
in
the
fumigation
cycles
from
1997
to
2000.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
each
fumigation
cycle.
(
For
example,
if
normally
methyl
bromide
is
applied
and
tomatoes
are
grown
and
harvested
followed
by
peppers
without
an
additional
treatment
of
methyl
bromide,
then
both
tomatoes
and
peppers
would
be
part
of
the
same
fumigation
cycle.)
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

Enter
the
number
of
units
of
crop/
commodities
produced
per
area.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
1997
­
2000
when
using
methyl
bromide.
Post­
harvest
and
structural
users
may
work
with
EPA
to
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.

Col.
A:
Year
2000
Col.
B:
Crop/
Commodity
Forest
Tree
Seedlings
Pine
&
Hardwoods
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
B
Col.
E:
Price
Col.
F:
Revenue
Crop/
Commodity
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Average
Revenue
per
Year:
The
average
revenue
per
year
is
calculated
automatically
using
the
summary
data
you
enter
for
each
year.

Total
Revenue
for
1997­
2000
Enter
the
total
revenue
per
year
by
adding
the
revenue
for
all
crops
for
that
year.

1st
year
after
fumigation
seedlings
1st
year
after
fumigation
seedlings
1st
year
after
fumigation
seedlings
1st
year
after
fumigation
seedlings
Revenue
is
only
generated
in
years
that
seedlings
are
grown.
In
a
2:
2
rotation,
the
first
two
years
are
in
seedlings
and
generate
revenue.

Crop/
Commodity
Yield
and
Gross
Revenue
1997­
2000
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
acre
Price
(
per
unit
of
crop/
commodity)

thousand
seedlings
Revenue
(
per
area)
acres
Bareroot
Seedlings
Pine
seedling
quality,
genetic
gain,
market
per
thousand
trees
675
$
40.00
$
27,000.00
fluctuations
Total
Revenue
27,000.00
$

Comments:

OMB
Control
#
2060­
0482
Enter
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

Revenue
is
automatically
calculated
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
the
comment
section
below.

Enter
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,

grade,
market
(
e.
g.
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
row.
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
in
making
the
case
that
the
use
of
methyl
bromide
affects
these
price
factors.

Enter
the
unit
of
measurement
for
each
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor.

Note:
revenue
is
only
generated
during
the
first
two
years
following
fumigation
when
the
land
is
growing
bareroot
seedlings.

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
2001when
using
methyl
bromide.
Post­
harvest
users
may
modify
this
form
to
accommodate
differences
when
providing
gross
revenue
data.
If
2001
was
not
a
typical
year
for
the
individual
or
for
the
representative
user
of
a
consortium,
the
applicant
may
provide
additional
data
for
a
different
year.
However,
all
applicants
must
complete
this
worksheet
for
the
year
2001
regardless.
Please
explain
in
the
comment
section
at
the
bottom
of
the
worksheet
why
2001
is
not
considered
a
typical
year,
if
that
is
the
case.
Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
the
fumigation
cycle
(
interval
between
fumigations)
beginning
with
the
treatment
of
methyl
bromide
in
2001.
If
multiple
crops
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
crops
during
the
entire
interval.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Col.
A:
Crop/
Commodity
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Area
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Area
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Area
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
(
acres)
Cost
per
Area
over
95%
methyl
bromide
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
90%
methyl
bromide,
10%
chloropicrin
_
80_%
methyl
bromide,
20__%
chloropicrin
280
$
2.70
$
300
270
$
1,795.00
All
formulations
of
methyl
bromide
280
$
2.70
$
300
270
$
1,795.00
Comments:

OMB
Control
#
2060­
0482
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Enter
the
appropriate
data
in
Col
B­
G
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations
of
methyl
bromide.
If
you
just
enter
data
in
the
bottom
row
in
the
table
(
All
formulations
of
methyl
bromide),
please
describe
in
the
comments,
the
relative
usage
of
the
various
formulations,
to
the
extent
known.

Enter
the
average
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied
per
area.

Enter
the
average
price
per
pound
active
ingredient
(
ai)
of
methyl
bromide
in
Col.
C
and
the
average
cost
of
applying
methyl
bromide
per
area
treated
in
Col.
D.
In
Col.
E,
enter
the
average
other
costs
per
area
associated
with
applying
methyl
bromide
(
e.
g.,
tarps).
Column
G
will
be
calculated
automatically
using
the
values
you
entered
in
columns
B­
E.
If
methyl
bromide
is
custom
applied,
enter
the
cost
per
area
in
Col.
G
and
fill
in
Cols.
B
and
F.

Enter
the
actual
area
treated.
Note:
This
number
should
be
the
total
area
treated
by
all
users
in
the
consortium.

For
EPA
Use
Only
ID#

If
2001
was
not
a
typical
year
for
the
individual
or
for
the
representative
user
of
a
consortium,
the
applicant
may
provide
additional
data
for
a
different
year.
However,
all
applicants
must
complete
this
worksheet
for
the
year
2001
regardless.
If
you
provide
an
additional
year's
data,
please
explain
in
the
comment
section
at
the
bottom
of
the
worksheet
why
2001
is
not
considered
a
typical
year.

If
the
methyl
bromide
is
custom
applied
then
put
the
cost
per
area
in
Column
G
and
fill
in
the
average
lb
ai
of
methyl
bromide
applied
per
area
(
Col
B)
and
the
Total
Actual
Area
Treated
(
Col
F).

Worksheet
2­
D.
Methyl
Bromide
­
Use
and
Costs
for
2001
If
a
consortium
is
submitting
this
application,
the
data
in
Cols.
B,
C,
D,
and
E
should
reflect
the
representative
user
in
the
consortium.
The
data
in
Col.
F
should
reflect
the
actual
area
treated
by
all
users
in
the
consortium.
For
EPA
Use
Only
ID#

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
Soil
Preparation
for
Sowing
Seeds
$
592.42
$
573.48
$
1,165.90
Sowing
Pine
Seeds
$
4,457.98
$
549.68
$
5,007.66
Crop
Cultural
Activities
$
1,061.36
$
1,412.02
$
2,473.38
Lifting,
packing,
shipping
crop
to
$
3,682.85
$
897.27
$
4,580.12
customers
Total
Custom
per
Area
User
Total
per
area
$
13,227.06
Soil
Preparation:
Typical
farm
tractor
and
implements
Sowing:
Highly
specialized
machine
sowers
are
used
to
sow
genetically
improved
seed.
Power
supplied
by
farm
tractor.

Maintenance
Standard
tractor
drawn
boom
sprayers.
Implements
for
fertilization,
top
and
root
pruning
are
specially
designed
for
forest
tree
nurseries.

Harvest
OMB
Control
#
2060­
0482
If
you
do
not
incur
custom
operation
costs,
enter
the
labor
cost
per
area.

Enter
all
operating
costs
except
methyl
bromide
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Enter
these
costs
in
Col
B
for
custom
operations,
or
in
Col
C
and
D
for
operations
done
by
user.

Identify
in
Col
A
the
operations
(
except
methyl
bromide)
to
which
the
costs
apply.
For
growers,
these
operations
should
include
but
are
not
limited
to
(
1)
prepare
soil,
(
2)
fertilize,
(
3)
irrigate,
(
4)
plant,
(
5)
harvest,
(
6)
other
pest
controls,
etc.
You
must
include
all
other
operating
costs.

If
you
incur
custom
operation
costs,
enter
those
costs
in
Col.
B.

Submit
crop
budgets
for
each
crop,
if
available.
You
may
submit
crop
budgets
electronically
or
in
hard
copy.
If
your
costs
are
significantly
different
than
the
crop
budgets,

please
explain
in
the
comments.
Operation
Done
by
User
Worksheet
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Custom
Operation
Cost
per
Area
Operation
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Do
not
include
methyl
bromide
costs.

Identify
the
typical
equipment
used
for
operations
done
by
user.
Please
be
specific,
such
as
tractor
horsepower.
No
cost
data
is
required
in
this
column.

If
you
do
not
incur
custom
operation
costs,
enter
the
material
cost
per
area.

The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.

Note:
The
operations
listed
are
typical
for
each
International
Paper
SuperTree
seedling
nursery
Operations
Details:
Highly
mechanized
harvesting
operation
using
specially
designed
seedling
lifters.
Seedlings
placed
in
cold
storage
until
shipped
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Cost
Item
Description
Allocation
Method
Cost
per
Area
Labor
and
Labor
Related
Managerial
and
Administrative
salaries
and
benefits
$
2,442.99
Travel
Travel
Expenses,
Business
Meals,
Conferences
$
199.49
Advertising
$
92.56
Postage
FedEx,
UPS,
and
regular
mail
charges
$
65.10
Communications
Telephones,
Cellular
Phones
$
201.30
Data
Processing
$
44.12
Computer
Hardware
Computers,
printers,
etc.
$
31.16
Rentals­
Tangible
Properties
Machine
Rentals
$
49.06
Rentals­
Real
Property
Office
Rental
$
177.94
Vehicle
Lease
Expenses
Auto
Lease
and
Heavy
Equipment
$
870.48
Dues
and
Assessments
Trade
Association
Dues
and
Contributions
$
14.08
Publications
Trade
Magazine
Subscriptions
$
1.97
Meetings
$
22.93
Taxes
Sales
and
Property
Taxes
$
398.37
Depreciation
Capitalized
Interest
and
Plant
Depreciation
$
1,759.79
Gain/
Loss
on
Sale
of
Assets
Usually
a
one
time
loss
or
gain
­$
435.21
Legal
Settlements
Company
Legal
Bill
$
207.96
Rental
Income
From
home
on
nursery
site
­$
62.69
Supplies
and
Equipment
Managerial
and
Administrative
Supplies
$
517.87
Other
Income/
Expenses
$
148.05
Utilities
Water
and
Electricity
$
553.89
Allocations
and
Transfers
Corporate
and
Division
Overhead
$
282.35
Total
$
7,583.56
Comments:
Data
represent
costs
from
a
typical
International
Paper
SuperTree
seedling
nursery
growing
bareroot
pines.

OMB
Control
#
2060­
0482
Worksheet
2­
F.
Methyl
Bromide
Fixed
and
Overhead
Costs
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.

Enter
all
fixed
and
overhead
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?
1a.
Full
use
permitted
Yes
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
See
Appendix
3
for
list.
All
articles
are
part
of
the
public
domain
and
can
be
used
freely.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
stu
Yes
x
No
(
seedling
size,
bed
density)
7.
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
BACKGROUND
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
Basamid
Various
see
Appendix
3
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
See
Appendix
3
for
list.
Primary
investigating
agency
is
the
staff
of
the
Auburn
University
Nursery
Cooperative,
Drs.
Ken
McNabb
and
Bill
Carey
See
Appendix
3
Various
forest
tree
seedling
nurseries
in
the
southeastern
US
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Basamid
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Nutsedge
(
Cyperus
spp.
)
populations
are
not
controlled
to
any
great
extent
by
Basamid
as
indicated
in
many
research
studies
(
Carey,
1994b,
1996;
Conn,
2002;
Dwinell
and
Fraedrich,
1997).
Also,
a
1997
survey
of
southern
forest
nursery
managers
indicated
that
Basamid
was
less
effective
in
weed
control
than
methyl
bromide
(
Cram,
1996).
The
population
of
nutsedge
plants
on
a
nursery
bed
can
quickly
expand
to
epidemic
proportions
literally
covering
the
developing
pine
and
seedlings
(
Figure
1,
8.
Basamid
studies
have
been
conducted
at
nurseries
similar
to
those
of
International
Paper
and
on
similar
nursery
soils.
We
do
not
expect
results
different
from
those
observed
in
the
various
research
studies.
At
best,
Basamid
effects
are
inconsistent.
The
lack
of
nutsedge
control
is
a
serious
threat
to
the
efficient
and
economical
production
of
quality
pine
seedlings.

OMB
Control
#
2060­
0482
nurseries
will
have
to
resort
to
handweeding
which
increases
cost
(
approximately
$
662/
acre;
see
section
3­
D
Basamid).

Paper,
a
reduction
in
bed
density
by
just
2
plantable
seedlings/
sq
ft
would
result
in
a
per
acre
nursery
bed
loss
of
$
2.2M.
Appendix
2).
As
can
be
expected,
the
size
of
the
pine
seedlings
will
be
dramatically
reduced
from
grade
one
seedlings
to
grade
2
or
cull
seedlings
(
i.
e.
unusable)
when
in
competition
with
nutsedge.
South,
et
al.
(
2001)
demonstrated
that
a
reduction
in
seedling
size
by
2mm
can
result
in
a
net
present
value
loss
of
$
0.10
per
seedling.
With
an
annual
crop
exceeding
350MM
seedlings,
International
Paper
can
expect
to
incur
an
annual
loss
$
35MM
just
from
increased
weed
competition
primarily
from
nutsedge.
Unfortunately,
no
herbicides
are
available
that
will
control
nutsedge
without
damaging
the
i
dli
Th
I
t
ti
l
P
S
T
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Seedling
size
is
an
important
indicator
of
seedling
quality
since
size
at
time
of
field
planting
is
directly
related
to
survival
and
future
tree
growth
(
South,
et
al,
2001).
Basamid
has
not
demonstrated
consistent
seedling
size
effects
at
many
study
locations
and
in
operational
use
(
Auburn
Nursery
Cooperative,
2002).
Some
studies
indicate
soil
treated
with
Basamid
can
produce
seedlings
that
have
the
same
average
root
collar
diameter
as
those
seedlings
grown
in
soil
treated
with
methyl
bromide
fumigation
(
Carey,
1996).
However,
several
studies
clearly
demonstrate
that
Basamid
treated
soil
produces
smaller
seedlings
than
soil
treated
with
methyl
bromide
(
Carey,
1994b,
1995,
Cary
and
McNabb,
1996;
Dwinell
and
Fraedrich,
1997).
Weed
pressure
was
not
a
factor
in
these
studies
and
did
not
contribute
to
the
reduction
in
seedling
size
(
Auburn
Nursery
Cooperative,
2002).
Further,
Basamid
has
consistently
produced
2.2
fewer
seedlings
per
sq.
ft.
of
nursery
bed
compared
to
methyl
bromide
(
A
b
N
C
ti
2002)
At
I
t
ti
l
Many
different
soil
fungi
are
beneficial
to
pine
seedling
growth.
Low
populations
of
these
fungi
will
result
in
erratic
seedling
growth
patterns
in
the
nursery
bed
and
a
reduction
in
seedling
size.
Basamid
treatment
has
been
demonstrated
to
prolong
the
recovery
of
Trichoderma
(
one
of
the
most
beneficial
fungi)
compared
to
methyl
bromide
fumigation
(
South,
et.
al.
1997;
Lyer
and
White,
1969).
The
long
term
effect
of
repeated
use
of
Basamid
on
the
soil
population
of
Trichoderma
is
unknown.
However,
Auburn
Nursery
Cooperative
(
2002)
is
very
concerned
that
the
populations
of
beneficial
soil
fungi
may
be
comprised
with
Basamid
use
Outgassing
is
a
potentially
serious
problem
with
Basamid.
At
least
one
case
of
outgassing
from
Basamid
treated
fields
has
been
reported
(
Auburn
Nursery
Cooperative,
2002).
Methylisothiciocyanate
(
MITC)
gas
is
the
active
ingredient
in
Basamid.
This
gas
is
released
upon
the
exposure
of
Basamid
to
water.
Seedling
damage
from
outgassing
of
fumigation
alternatives
has
also
been
documented
by
the
J.
Herbert
Stone
Nursery
(
Scholtes,
1989)
Outgassing
poses
a
risk
to
the
health
of
adjacent
seedlings
(
see
Figure
2;
Appendix
3)
as
well
as
those
individuals
in
residences
adjacent
to
International
Paper
SuperTree
nurseries
Col.
B:
Target
Pests
Col.
C:
Active
Ingredi
Col.
D:
Formul
ation
Col.
E,
F,
G:
Applica
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applica
Col.
M:
Cost
per
Nonchemic
al
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Applicati
on
Units
of
product
per
Area
per
Applicati
on
Product
Unit
(
e.
g.,
lbs.,
gals)

Basamid
Weeds
MITC
98%
343
acre
350
lbs/
a
lbs
#########
$
2,000.00
Soil
Fungi
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
emical
Pest
Target
Pest
Description
Cost/
area
Total
$
2,000.00
Comments:
If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
Worksheet
3­
B.
Alternatives
­
Pest
Control
Reg
Basamid
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
Col.
A:
Name
Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.
B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regarding
the
same
product.
Enter
the
formulation
or
the
%
of
active
ingredient.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Col.
I.
Enter
any
other
costs
associated
with
applying
this
product
in
Col.
J,
specifying
what
they
are
in
the
comments
section
at
the
bottom
of
this
sheet.

Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied.

Cost
per
Area
(
2001$)
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Target
Pests
Active
Ingredien
ts
(
ai)
in
Product
Formulati
on
of
Product
Application
Rate
Price
per
Unit
of
the
Product
Area
Treated
at
Least
Once
#
of
Applicati
ons
per
Year
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Applicati
on
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
thousand/
acre
Price
(
per
unit
of
crop/
commodity)
per
thousand
Revenue
(
per
area)
acre
Pine
seedlings
seedling
quality,
genetic
gain,
market
1000
trees
621
$
40
$
24,840
fluctuations
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Total
Revenue
$
24,840.00
Comments:

OMB
Control
#
2060­
0482
Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternati
Basamid
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
the
comment
i
b
l
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
row.
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
in
making
the
case
that
the
use
of
alternatives
affects
these
price
factors.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

Note:
revenue
is
only
generated
during
the
first
two
years
following
fumigation
when
the
land
is
growing
bareroot
seedlings.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.

Postharvest
and
structural
users
may
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.

Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Gross
Revenue
of
Alternatives
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
(
acre)
Total
Cost
per
Area
(
acre)

Hand
Weeding
0
$
60/
acre/
application
$
360.00
Hand
labor
Increased
Herbicide
Use
cover
crop
/
fallow
$
24.50
$
59.40
$
83.90
Tractor
/
Spray
Rig
seedling
crop
$
98.50
$
120.00
$
218.50
Tractor
/
Spray
Rig
Total
Custom
per
Area
User
Total
per
area
$
662.40
Comments:

Assumes
increase
in
weed
populations
(
ex.
Nutsedge)
will
require
one
hand
weedings
per
acre
per
month
from
May
through
October.
Cost
per
acre
is
estimated
to
be
$
60
which
represents
a
hand
weeding
crew
of
5
plus
one
supervisor.

Additional
herbicide
use
will
be
needed
when
growing
seedlings
the
first
two
years
of
the
fumigation
cycle
and
also
during
the
second
two
years
when
the
soil
is
fallow
or
in
cover
crop.

Additional
indirect
costs
per
acre
at
listed
in
3­
A
Typical
Equipment
Used
Operation
Done
by
User
Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Basamid
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operation
costs,
or
in
Col.
C
and
D
for
operations
done
by
user.

Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
See
Comment
Comments:

See
appendix
3
for
list
of
research
publications.

OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

Basamid
See
"
comments"
below
Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,

etc.).

Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
should
directly
compare
methyl
bromide
and
the
alternative
regimen.

List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
over
the
words
"
Rating
Interval
1"
with
"
pre­
treatment",
type
over
"
Rating
Interval
2"
with
"
3
weeks",
and
type
over
"
Rating
Interval
3"
with
"
6
weeks."
If
you
are
completing
the
printed
version,
please
define
Rating
Interval
in
the
comments
below.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?
1a.
Full
use
permitted
Yes
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
See
Appendix
3
for
list.
All
articles
are
part
of
the
public
domain
and
can
be
used
freely.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
stu
Yes
x
No
(
seedling
size,
bed
density)
7.
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
Metham­
sodium
Various
see
Appendix
3
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
See
Appendix
3
for
list.
Primary
investigating
agency
is
the
staff
of
the
Auburn
University
Nursery
Cooperative,
Drs.
Ken
McNabb
and
Bill
Carey
See
Appendix
3
Various
forest
tree
seedling
nurseries
in
the
southeastern
United
States
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Metham­
sodium
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Metham­
sodium
cannot
be
safely
used
at
International
Paper
SuperTree
seedling
nurseries.
In
2000,
International
Paper's
Texas
nursery
at
Bullard
installed
an
operational
pilot
study
to
evaluate
metham­
sodium
effectiveness
on
a
large
scale.
The
Metham­
sodium
was
applied
to
the
soil
during
the
day.
That
evening
the
chemical
outgassed
from
the
soil
and
drifted
on
the
wind.
As
can
be
seen
in
Figure
2
(
Appendix
2),
the
outgassed
Metham­
sodium
killed
over
20
million
pine
seedlings.
An
even
more
distressing
event
occurred
with
Some
early
studies
(
Carey,
1994a,
1996,
1999,
2000a,
b,
c,
Cram,
1996)
with
Metham­
sodium
showed
promising
results
when
Metham­
sodium
was
combined
with
chloropicrin
or
the
herbicide
EPTC.
Weed
control
and
seedling
size
were
similar
to
the
results
obtained
with
methyl
bromide
fumigation
(
Carey,
2000d).
Metham­
sodium/
chloropicrin
fumigated
soil
tends
to
produce
seedlings
with
less
biomass
than
methyl
bromide
fumigation
(
Carey,
et
al.,
2001).
Like
Basamid,
a
reduction
in
the
number
of
seedlings
in
the
nursery
bed
sometimes
occurs.
Fewer
seedlings
available
in
the
nursery
translates
to
less
potential
revenue.

Metham­
sodium
application
to
the
soil
requires
additional
soil
cultural
treatments
compared
to
methyl
bromide.
A
tractor
mounted
rototiller
is
needed
to
incorporate
the
Metham­
sodium
into
the
soil.
Each
time
any
vehicle
travels
over
the
soil
a
serious
soil
compaction
risk
occurs.
A
"
plow
pan"
or
compaction
layer
will
form
in
the
soil
just
below
the
level
of
the
rototiller.
This
compacted
layer
retards
water
infiltration
through
the
soil,
reduces
aeration,
and
forms
a
barrier
to
root
growth.
As
a
consequence,
seedling
quality
can
be
reduced
due
to
excessive
soil
moisture
and
poor
pine
seedling
growth.
The
Auburn
University
Nursery
Cooperative
(
2002)
has
documented
nursery
soil
damage
from
Metham­
sodium
application.
Application
time
for
Metham­
sodium
fumigation
is
two
to
three
times
as
long
as
methyl
bromide
(
Parker,
2002).
International
Paper
SuperTree
nurseries
have
a
short
period
when
environmental
conditions
are
favorable
for
fumigation.
It
is
doubtful,
that
Metham­
sodium
applications
can
be
completed
before
adverse
soil
temperature
conditions
occur.

8.
Metham­
sodium
has
been
applied
directly
to
some
of
our
nurseries.
The
outgassing
associated
with
Metham­
sodium
cannot
be
practically
avoided.
Due
to
this
experience
and
the
outgassing
seen
at
other
forest
tree
nurseries,
International
Paper
cannot
safely
use
Metham­
sodium
as
an
alternative
to
methyl
bromide
fumigation.

OMB
Control
#
2060­
0482
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
this
outgassing.
The
Metham­
sodium
drifted
to
the
property
of
several
people
living
adjacent
to
the
nursery.
Since
this
event,
these
individuals
have
alleged
to
have
health
problems
related
to
the
outgassing
and
they
are
now
in
litigation
with
the
contract
applicator.
Outgassing
of
Metham­
sodium
from
forest
tree
nurseries
has
been
reported
in
Louisiana,
Mississippi,
Arkansas,
Oregon,
and
Montana
(
Carey,
00).
Because
of
the
risk
of
outgassing
and
the
threat
to
health
of
those
living
downwind,
Metham­
sodium
is
not
a
suitable
alternative
to
methyl
bromide
fumigation.

Nutsedge
(
Cyperus
spp.
)
populations
are
not
controlled
to
any
great
extent
by
Metham­
sodium
(
when
used
as
a
stand
alone
treatment)
as
indicated
in
several
research
studies
(
Carey
1996,
Fraedrich
and
Dwinell,
1997).
The
population
of
nutsedge
plants
on
a
nursery
bed
can
quickly
expand
to
epidemic
proportions
literally
covering
the
developing
pine
seedlings
(
Figure
1,
Appendix
2).
As
can
be
expected,
the
size
of
the
pine
seedlings
will
be
dramatically
reduced
from
grade
one
seedlings
to
grade
2
seedlings
when
in
competition
with
nutsedge.
South,
et
al,
(
2001)
demonstrated
that
a
reduction
in
seedling
size
by
2mm
can
result
in
a
net
present
value
loss
of
$
0.10
per
seedling.
With
an
annual
crop
exceeding
350MM
seedlings,
International
Paper
can
expect
to
incur
an
annual
loss
of
$
35MM
just
from
increased
weed
competition
primarily
from
nutsedge.
Unfortunately,
no
herbicides
are
available
that
will
control
nutsedge
without
damaging
the
pine
seedlings.
Thus,
International
Paper
SuperTree
nurseries
will
have
to
resort
to
handweeding
which
increases
seedling
cost.
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)

Tarped
Metham­
sodium
weeds/
fungi
MITC
42%
210
lbs
60
gallons
1
$
2,000.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
2,000.00
Comments:

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.

B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regarding
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
per
area
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Metham­
sodium
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Col.
I.
Enter
any
other
costs
associated
with
applying
this
product
in
Col.
J,
specifying
what
they
are
in
the
comments
section
at
the
bottom
of
this
sheet.

Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
thousand/
acre
Price
(
per
unit
of
crop/
commodity)
per
thousand
Revenue
(
per
area)
acre
Pine
seedlings
seedling
quality,
genetic
g
1000
trees
621
40
$
24,848
fluctuations
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Total
Revenue
$
24,848.00
Comments:

The
reduction
in
the
number
of
seedlings
per
bed
is
comparable
for
both
Basamid
and
Metham­
sodium;
therefore,
the
revenue
numbers
OMB
Control
#
2060­
0482
Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Metham­
sodium
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
Col.
A:
Crop/
Commodity
Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.
In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
expressed
here
are
the
same
as
for
Basamid.
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Gross
Revenue
of
Alternatives
Note:
revenue
is
only
generated
during
the
first
two
years
following
fumigation
when
the
land
is
growing
bareroot
seedlings.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
(
acre)
Total
Cost
per
Area
(
acre)

Hand
Weeding
0
$
60/
acre/
application
$
360.00
Hand
labor
Increased
Herbicide
Use
seedling
crop
$
98.50
$
120.00
$
218.50
Tractor/
Spray
Rig
cover
crop/
fallow
$
24.50
$
59.40
$
83.90
Tractor/
Spray
Rig
Total
Custom
per
Area
User
Total
per
area
$
662.40
Comments:
Assumes
increase
in
weed
populations
(
ex.
Nutsedge)
will
require
one
hand
weedings
per
acre
per
month
from
May
through
October.
Cost
per
acre
is
estimated
to
be
$
60
which
represents
a
hand
weeding
crew
of
5
plus
one
supervisor.

Additional
herbicide
use
will
be
needed
when
growing
seedlings
the
first
two
years
of
the
fumigation
cycle
and
also
during
the
second
two
years
when
the
soil
is
fallow
or
in
cover
crop.

Additional
indirect
costs
per
acre
at
listed
in
3­
A
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:
Metham­
sodium
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Operation
or
Cost
Item
Custom
Operation
Cost
per
Area
Operation
Done
by
User
Typical
Equipment
Used
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:
Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:
Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
See
Comment
Comments:
See
appendix
3
for
list
of
research
publications.

OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
Metham­
sodium
See
"
comments"
below
Provide
one
summary
table
for
each
study
being
described.
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.
Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.
Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).
Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,
etc.).
Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Treatment
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)
Yield
(
units/
are
a)
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?
1a.
Full
use
permitted
Yes
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
See
Appendix
3
for
list.
All
articles
are
part
of
the
public
domain
and
can
be
used
freely.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
stu
Yes
x
No
(
seedling
size,
bed
density)
7.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Organic
amendments
have
been
tested
as
an
alternative
to
methyl
bromide
fumigation.
Known
advantages
of
organic
amendments
include
increased
soil
organic
matter
levels
resulting
in
improved
soil
structure
and
cation
exchange
capacity
(
Davey
and
Krause,
1980).
In
fact,
International
Paper
SuperTree
nurseries
include
the
addition
of
organic
amendments
(
ex.
sawdust,
cotton
gin
waste,
etc.)
as
a
routine
measure
to
maintain
the
productivity
of
nursery
soils.
The
effect
of
organic
amendments
Various
with
several
different
organic
amendments
See
Appendix
3
Various
forest
tree
seedling
nurseries
in
the
United
States
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
See
Appendix
3
for
list.
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
Organic
Amendments
Various
see
Appendix
3
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
BACKGROUND
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
loss
in
the
number
of
seedlings
per
square
foot
will
result
in
less
revenue
since
fewer
seedlings
will
be
available
for
sale.

8.
At
present,
we
expect
similar
results
since
both
the
Florida
and
South
Carolina
nurseries
have
soil
types
typical
for
all
International
Paper
SuperTree
nurseries.
In
fact,
the
South
Carolina
nursery
is
a
member
of
International
Paper's
SuperTree
nursery
family.
Additional
research
may
show
a
role
for
organic
amendments,
most
likely
when
used
as
part
of
an
integrated
pest
management
program.

OMB
Control
#
2060­
0482
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Seedlings
were
generally
larger
when
grown
in
fumigated
soil
than
in
soil
treated
with
organic
amendments
in
both
Florida
and
South
Carolina
after
several
consecutive
seedling
crops
(
Kannwischer­
Mitchell,
et
al,
1995,
1997;
Barnard,
et
al.,
1996).
However,
some
pine
bark
or
compost
treatments
did
have
greater
average
root
collar
diameter
than
fumigated
soil.
Similarly,
average
root
collar
diameter
in
fumigated
soil
in
the
pacific
northwest
was
equal,
greater,
or
smaller
than
the
root
collar
diameter
seen
in
soil
treated
with
organic
amendments
or
crop
rotations
(
Stone,
et
al,
1997).
Evidently
the
effect
of
soil
organic
amendments
on
seedling
size
has
been
inconsistent.
A
small
reduction
in
root
collar
diameter
of
only
2mm
can
seriously
affect
the
revenue
from
seedling
sales
(
see
discussion
in
3­
A
B
id)
Organic
amendments
may
affect
the
populations
of
plant
pathogenic
fungi;
however,
weeds
are
not
controlled.
In
fact,
careful
consideration
must
be
given
to
the
source
of
organic
amendments
in
order
to
prevent
the
introduction
of
additional
weeds
into
the
nursery
(
Lantz,
1997).
Nutsedge
(
Cyperus
spp.
)
populations
could
prosper
with
the
use
of
organic
amendments.
As
explained
in
section
3­
A
Basamid
and
3­
A
Metham­
sodium,
nutsedge
control
is
very
difficult
without
methyl
bromide
fumigation.
Decreased
seedling
quality
and
increased
nursery
costs
associated
with
more
hand
weeding
and
herbicide
use
are
inevitable
without
methyl
bromide
fumigation.
Seedling
health
has
not
been
affected
after
several
consecutive
crops
in
soil
treated
with
organic
amendments
at
forest
tree
nurseries
in
the
southeast
(
Kannwischer­
Mitchell,
et
al,
1995,
1997;
Barnard,
et
al.,
1996)
and
the
pacific
northwest
(
James,
et
al,
1997;
Stone,
et
al,
1997).
In
fact,
there
was
no
significant
difference
in
disease
incidence
between
soil
treated
with
various
fumigants
(
e.
g.
Basamid,
methyl
bromide)
and
soil
organic
amendments
even
after
four
consecutive
seedling
crops.
However,
seedling
survival
and
seedling
size
were
typically
greater
on
fumigated
soil
than
on
soil
treated
with
organic
amendments.
Nursery
bed
densities
at
the
end
of
the
growing
season
indicated
soil
treated
with
methyl
bromide
generally
had
1
to
3
more
seedlings
per
sq.
ft.
than
did
soil
treated
with
pine
bark
or
compost
(
Kannwischer­
Mitchell,
et
al,
1995;
Barnard,
et
al,
1996).
In
the
pacific
northwest,
the
two­
year
old
seed
bed
densities
of
douglas
fir
(
Pseudotsuga
menziesii)
and
ponderosa
pine
(
Pinus
ponderosa
)
were
variable
(+/­)
depending
on
the
organic
amendment,
cropping
technique,
and
soil
fumigant
(
Stone,
on
the
population
of
soil
pathogens
and
parasites,
and
the
effect
on
seedling
quality
have
been
evaluated
in
several
recent
studies.
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Applicati
on
Units
of
product
per
Area
per
Applicati
on
Product
Unit
(
e.
g.,
lbs.,
gals)

Organic
Soil
Fungi
none
100%
540
cu.
Yrds
lbs
$
7.50
$
4,050.00
Matter
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pest
Description
Cost/
area
Total
$
4,050.00
Comments:
Organic
amendments
when
used
as
an
alternative
to
methyl
bromide
fumigation
should
be
applied
from
1
to
4
inches
thick
(
Carey
and
McNabb,
1996).
For
EPA
Use
Only
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
A
Organic
Amendments
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
Col.
A:
Name
of
Product
and
Non­
chemical
Control
Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.
Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
Enter
the
formulation
or
the
%
of
active
ingredient.
As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied.

Cost
per
Area
(
2001$)
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Target
Pests
Active
Ingredien
ts
(
ai)
in
Product
Formulati
on
of
Product
Application
Rate
Price
per
Unit
of
the
Product
Area
Treated
at
Least
Once
#
of
Applicati
ons
per
Year
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Applicati
on
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
thousand/
acre
Price
(
per
unit
of
crop/
commodity)
per
thousand
Revenue
(
per
area)
acre
Pine
seedlings
seedling
quality,
genetic
gain1000
trees
621
40
$
24,848
fluctuations
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Total
Revenue
$
24,848.00
Comments:

Assumes
loss
of
2.2
seedlings
per
sq.
ft.
of
nursery
bed.

OMB
Control
#
2060­
0482
Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenu
Organic
Amendments
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
Col.
A:
Crop/
Commodity
Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.
In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Gross
Revenue
of
Alternatives
Note:
revenue
is
only
generated
during
the
first
two
years
following
fumigation
when
the
land
is
growing
bareroot
seedlings.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
(
acre)
Total
Cost
per
Area
(
acre)

Hand
Weeding
0
$
60/
acre/
application
$
360.00
Hand
labor
Increased
Herbicide
Use
seedling
crop
$
98.50
$
120.00
$
218.50
Tractor/
Spray
Rig
cover
crop/
fallow
$
24.50
$
59.40
$
83.90
Tractor/
Spray
Rig
Total
Custom
per
Area
User
Total
per
area
$
662.40
Comments:
Assumes
increase
in
weed
populations
(
ex.
Nutsedge)
will
require
one
hand
weedings
per
acre
per
month
from
May
through
October.
Cost
per
acre
is
estimated
to
be
$
60
which
represents
a
hand
weeding
crew
of
5
plus
one
supervisor.

Weed
control
is
not
available
with
organic
amendments.
More
herbicides
will
be
needed
during
the
growing
season
and
in
the
fallow
period.

Additional
indirect
costs
per
acre
at
listed
in
3­
A
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative
Organic
Amendments
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Operation
or
Cost
Item
Custom
Operation
Cost
per
Area
Operation
Done
by
User
Typical
Equipment
Used
Alternative:
Study:

Col.
A:
Treatm
ent
Number
Col.
B:
Treatm
ent
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:
Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval
:
Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
ee
Comment
Comments:
See
appendix
3
for
list
of
research
publications.

OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
For
EPA
Use
Only
Research
Summary
Organic
Amendments
See
"
comments"
below
Provide
one
summary
table
for
each
study
being
described.
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quali
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
over
the
words
"
Rating
Interval
1"
with
"
pre­
treatment",
type
over
"
Rating
Interval
2"
with
"
3
weeks",
and
type
over
"
Rating
Interval
3"
with
"
6
weeks."
If
you
are
completing
the
printed
version,
please
define
Rating
Interval
in
the
comments
below.

For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,
etc.).

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Treatmen
t
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)
Yield
(
units/
are
a)
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?
1a.
Full
use
permitted
Yes
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
See
Appendix
3
for
list.
All
articles
are
part
of
the
public
domain
and
can
be
used
freely.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
stu
Yes
No
X
7.

Flooding
is
not
feasible
at
International
Paper
SuperTree
nurseries.
Our
nursery
soils
are
well
drained
and
would
require
an
excessive
volume
of
water
to
keep
the
fields
flooded.
The
fields
are
also
designed
to
promote
water
drainage.
A
slope
at
least
one
percent
is
built
into
all
fields
to
prevent
water
from
standing.
Flooding
can
only
be
used
in
flat,
low­
lying
areas
with
high
seasonal
water
tables
(
EPA,
2002).
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
Flooding/
Solarization
Various
see
Appendix
3
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
See
Appendix
3
for
list
See
Appendix
3
Various
forest
tree
seedling
nurseries
in
the
United
States
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Flooding
Solarization
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Flooding
is
not
feasible
due
to
soil
drainage
and
slope.
We
would
expect
similar
solarization
results
if
we
could
successfully
employ
solarization
during
the
summer
months
and
economically
control
weeds.
More
research
is
needed
to
confirm
affect
of
solarization
on
soil
pathogens
and
parasites
deep
(
about
10"­
12")
in
nursery
soils.

8.

OMB
Control
#
2060­
0482
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Solarization
is
a
method
in
which
clear
plastic
is
placed
on
top
of
the
soil
in
order
to
trap
solar
radiation
which
raises
soil
temperature
(
Carey
and
McNabb,
1996;
EPA,
2002).
Soil
temperatures
above
98F
are
required
to
kill
or
disable
soil
pathogens
and
parasites.
With
increasing
soil
temperature,
the
time
needed
to
kill
soil
pathogens
and
parasites
decreases.
At
98F,
up
to
4
weeks
exposure
is
needed
to
adversely
affect
soil
pathogens
and
parasites.
In
contrast,
only
1
to
6
hrs
are
needed
if
soil
temperature
is
117F
(
Katan
and
DeVay,
1991).
As
expected
soil
temperature
decreases
with
soil
depth.
A
solarization
study
in
Florida
found
soil
temperatures
of
121,
116,
and
107F
at
soil
depths
of
2,
6,
and
10
inches,
respectively
(
Chellemi,
et
al,
1994).
Weyerhaeuser
(
EPA,
2002)
has
found
similar
soil
temperatures
of
122­
140F
at
a
depth
of
3
inches
in
Arkansas.
The
efficiency
of
solarization
is
dependent
on
air
temperature,
day
length,
and
other
factors.
The
time
for
optimum
solarization
is
during
the
summer
months.

Normally,
nursery
fields
are
fumigated
in
the
late
fall
or
early
spring.
Both
periods
are
not
suitable
for
solarization.
A
summer
solarization
would
require
clear
plastic
mulch
to
be
laid
on
the
soil
for
many
months
to
achieve
adequate
soil
temperatures
deep
in
the
soil
profile
and
prevent
erosion
and
re­
contamination
from
soil
outside
the
treated
area
(
Carey
and
McNabb,
1996).
Although
forest
tree
nursery
soils
are
usually
uniform,
most
fields
contain
areas
that
have
soil
textural
and
drainage
differences.
These
areas
would
not
be
treated
to
the
same
degree
with
soil
solarization
as
the
majority
of
the
field.
The
quality
of
the
seedlings
produced
in
these
areas
would
be
different
than
the
rest
of
the
field.
Unfortunately,
many
weed
seeds
are
resistant
to
high
temperatures
and
would
not
be
affected.
Nutsedge
(
Cyperus
spp)
is
not
affected
by
the
soil
temperatures
produced
by
solarization.

Although
not
currently
feasible,
solarization
may
play
an
important
role
in
an
integrated
pest
management
system.
Additional
research
is
needed
to
combine
several
alternatives
(
including
organic
matter,
solarization,
etc.)
into
one
crop
rotation
package.
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Applicati
on
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,
gals)

Solarization
Soil
Fungi
none
none
none
tarp/
acre
sq.
ft.
$
500.00
$
500.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
ControTarget
Pest
Description
Cost/
area
Total
$
500.00
Comments:
Flooding
not
possible.
Estimated
labor,
tarp
installation
and
removal
costs
For
EPA
Use
Only
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
f
Flooding;
Solarization
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
Col.
A:
Name
of
Product
and
Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.
Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.
B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regarding
the
same
product.
Enter
the
formulation
or
the
%
of
active
ingredient.
As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.
Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Col.
I.
Enter
any
other
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied.

Cost
per
Area
(
2001$)
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Target
Pests
Active
Ingredien
ts
(
ai)
in
Product
Formulati
on
of
Product
Application
Rate
Price
per
Unit
of
the
Product
Area
Treated
at
Least
Once
#
of
Applicati
ons
per
Year
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Applicati
on
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
Units
per
area)
thousand/
acre
Price
(
per
unit
of
crop/
commodity)
per
Revenue
(
per
area)
acre
Pine
seedlings
seedling
quality,
genetic
gain1000
trees
621
40
$
24,848
fluctuations
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Total
Revenue
$
24,848.00
Comments:

The
number
of
seedlings
per
acre
will
decrease
due
to
greater
weed
competition.

OMB
Control
#
2060­
0482
Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Reven
Flooding;
Solarization
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.
The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
Col.
A:
Crop/
Commodity
Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.
In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Gross
Revenue
of
Alternatives
Note:
revenue
is
only
generated
during
the
first
two
years
following
fumigation
when
the
land
is
growing
bareroot
seedlings.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
(
acre)
Total
Cost
per
Area
(
acre)

Hand
Weeding
0
$
60/
acre/
application
$
360.00
Hand
labor
Increased
Herbicide
Use
seedling
crop
$
98.50
$
120.00
$
218.50
Tractor/
Spray
Rig
cover
crop/
fallow
$
24.50
$
59.40
$
83.90
Tractor/
Spray
Rig
Apply
soil
organic
matter
$
4,050
$
40
$
4,090
Tractor/
spreader
(
e.
g.
sawdust)

Total
Custom
per
Area
User
Total
per
area
$
4,752.40
Comments:
Assumes
increase
in
weed
populations
(
ex.
Nutsedge)
will
require
one
hand
weedings
per
acre
per
month
from
May
through
October.
Cost
per
acre
is
estimated
to
be
$
60
which
represents
a
hand
weeding
crew
of
5
plus
one
supervisor.

Weed
control
is
limited
with
solarization.
More
herbicides
and
hand
weeding
required.
Since
cover
crop
is
not
grown
the
summer
before
sowing
a
large
volume
of
organic
matter
is
needed.

Flooding
not
possible.
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:
Flooding;
Solarization
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Operation
or
Cost
Item
Custom
Operation
Cost
per
Area
Operation
Done
by
User
Typical
Equipment
Used
Alternative:
Study:

Col.
A:
Treatm
ent
Number
Col.
B:
Treatm
ent
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:
Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval
:
Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
ee
Comment
Comments:
See
appendix
3
for
list
of
research
publications.

OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
For
EPA
Use
Only
Research
Summary
Flooding;
Solarization
See
"
comments"
below
Provide
one
summary
table
for
each
study
being
described.
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quali
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
over
the
words
"
Rating
Interval
1"
with
"
pre­
treatment",
type
over
"
Rating
Interval
2"
with
"
3
weeks",
and
type
over
"
Rating
Interval
3"
with
"
6
weeks."
If
you
are
completing
the
printed
version,
please
define
Rating
Interval
in
the
comments
below.

For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,
etc.).

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Treatmen
t
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)
Yield
(
units/
are
a)
1.
Name
of
study:
alternatives
to
methyl
bromide
fumigation.

2.
Researcher(
s):

alternatives.

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
X
No
Includes
seedling
quality,
size,
survival
7.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

International
Paper
is
very
concerned
about
health,
safety,
and
environmental
quality.
We
will
implement
any
methyl
bromide
alternative
that
is
safe
to
use
and
promotes
production
of
high
quality
SuperTree
seedlings
in
a
cost
effective
manner.
Worksheet
4.
Alternatives
­
Future
Research
Plans
Will
crop
yield
be
measured
in
the
study?
Also,
integrated
pest
management
techniques
including
crop
rotations,
fallow
field
soil
management,
selected
use
of
herbicides,
solarization,
and
allopathic
interactions
of
crops
and
weeds
such
as
the
reduction
in
number
and
size
of
nutsedge
tubers
associated
with
allopathic
substances
produced
by
sweet
potatoes
(
Ipomea
spp
).

International
Paper
will
be
exploring
all
suitable
alternatives
similar
to
that
done
by
Weyerhaeuser
(
EPA,
2002)
Several
studies
that
will
evaluate
potential
chemical
and
integrated
pest
management
International
Paper
is
a
strong
contributing
member
of
the
Auburn
University
Nursery
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
(
All
available
methyl
bromide
alternatives
from
the
alternatives
list
should
have
been
tested
or
have
future
tests
planned.)
There
is
no
need
to
complete
a
separate
worksheet
for
future
research
plans
for
each
alternative
­
you
may
use
this
worksheet
to
describe
all
future
research
plans.

If
additional
testing
is
not
planned,
please
explain
why.
(
For
example,
the
available
alternatives
have
been
tested
and
found
unsuitable,
an
alternative
has
been
identified
but
is
not
yet
registered
for
this
crop,
available
alternatives
are
too
expensive
for
this
crop,
etc.)
installing
at
our
nurseries
appropriate
methyl
bromide
alternative
research
studies.

Nine
International
Paper
nurseries
are
available
for
research
studies.
2002
and
as
needed
Cooperative.
As
a
consequence,
we
eagerly
support
Cooperative
research
activities
by
Various
potential
fumigants
such
as:
methyl
iodide,
chloropicrin,
eptc,
azides.
In
addition,
we
will
be
installing
in­
house
research
for
further
evaluation
of
methyl
bromide
1.

1a.
Check
all
methods
you
will
use
Nothing
X
Tarpaulin
(
high
density
polyethylene)

Virtually
impermeable
film
(
VIF)

Cultural
practices
(
please
specify)

1b.
Will
you
use
other
pesticides
to
reduce
use
of
methyl
bromide?
Yes
X
No
If
yes
please
specify.

1c.
Other
non­
chemical
methods:
(
please
specify):

2.
Yes
No
X
If
yes,
how
many
pounds?
lbs.

3.
Yes
No
X
If
yes,
how
many
pounds?
lbs.

4.

$

5.

6.

When
do
you
expect
these
to
occur?

7.

0­
10
acres
10­
25
acres
trial
at
Texas
is
included.
In­
house
research
costs
not
borne
by
the
Cooperative
are
also
included.

numbers
so
that
total
revenues
are
not
affected.
The
cost
associated
with
the
alternative
must
not
reduce
our
ability
to
earn
an
acceptable
ROI.
Further,
any
alternative
must
meet
International
Paper's
requirements
for
health,
safety,
and
environmental
stewardship.
1,005,000.00
Range
of
acres
farmed
by
growers
included
in
this
application?
(
insert
number
of
users
in
each
category)
Other
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide.
Describe
each
investment
and
its
associated
cost.

This
money
helps
to
support
herbicide
and
nursery
cultural
research
that
may
help
reduce
the
need
for
methyl
bromide.

An
effective
methyl
bromide
fumigation
alternative
must
be
able
to
produce
seedlings
of
sufficient
quality,
size,
and
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Allopathic
effects
of
cover
crops
on
weed
seeds
is
a
promising
area.

Do
you
have
access
to
recycled
methyl
bromide?
Increased
use
of
herbicides
in
cover
crops
and
during
seedling
crop
production
Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
on
January
1,
2005?

As
soon
as
possible
but
in
reality
we
do
not
know.
Annual
dues
for
International
Paper's
membership
in
the
Auburn
University
Nursery
Cooperative
are
$
8,300
per
year.

Identify
what
factors
would
allow
you
to
stop
or
reduce
your
use
of
methyl
bromide
(
e.
g.
registration
of
particular
pesticide;
completion
of
research
plan;
capital
outlay).
What
is
the
cumulative
amount
spent
to
date
by
the
user
or
consortium
on
research
to
develop
alternatives
to
methyl
bromide
(
beginning
in
1992)?

The
figure
above
includes
International
Paper's
annual
dues
which
helps
support
all
Auburn
University
Nursery
Cooperative
research.
Also,
the
revenue
loss
from
seedlings
damaged
by
Metham­
sodium
operational
scale
research
Worksheet
5.
Additional
Information
For
EPA
Use
Only
ID#
25­
50
acres
50­
100
acres
100­
200
acres
note:
acres
suitable
for
growing
pine
and
seedlings
200­
400
acres
nine
International
Paper
SuperTree
nurseries
over
400
acres
Worksheet
5.
Additional
Information
(
continued)

8.

0
­
5,000
sq.
ft.
5,001
­
10,000
sq.
ft.
10,001
­
20,000
sq.
ft.
20,001
­
40,000
sq.
ft.
40,001
­
80,000
sq.
ft.
80,001
­
160,000
sq.
ft.
X
over
160,000
sq.
ft.
At
each
of
nine
International
Paper
SuperTree
nurseries
was
obtained
from
the
Auburn
University
Nursery
Management
Cooperative
methyl
bromide
CUE
application.
For
EPA
Use
Only
ID#
X
The
contribution
of
Hendrix
and
Dail
to
our
research
effort
is
calculated
as
$
39,
061.
This
figure
would
not
purchase
the
materials
and
labor
on
the
open
market.
No
commercial
company
would
haul
materials
to
Texas,
2,000
mile
round
trip,
to
treat
half
an
acre
for
$
3,000.
Range
of
square
feet
of
the
area
to
which
applicants
included
in
this
application
will
apply
methyl
bromide?
(
insert
number
of
users
in
each
category)

The
following
is
a
description
of
the
research
effort
conducted
by
the
Auburn
University
Nursery
Cooperative
and
The
Coop.
estimates
that
efforts
to
find
alternatives
to
MBr
have
occupied
a
third
of
our
research
effort
since
1993.
With
an
annual
operating
budget
of
$
200,000
this
would
be
$
666,000.
This
includes
about
50%
of
the
time
for
one
Research
Fellow
and
10%
and
25%
respectively
of
two
Technicians
that
are
full
time
employees
of
the
Coop
but
does
not
include
the
time
of
Auburn
faculty
associated
with
the
Coop.
The
Contribution
of
Auburn
University
through
faculty
salaries
of
those
three
members
closely
associated
with
the
Nursery
Coop.
during
this
period
should
add
approximately
$
150,000.

A
substantial
contribution
to
research
but
not
funded
by
the
Auburn
Coop
has
been
the
efforts
by
Dr.
Scott
Enebak
into
potential
biological
methods
(
primarily
PGPR
research)
to
offset
the
loss
of
MBr.
Since
1996,
Dr.
Enebak
has
generated
$
300,792
in
grants
for
his
PGPR
research.
To
those
grants,
Auburn
has
contributed
$
108,000
for
a
full
time
technician
and
student
workers
who
have
been
employed
in
this
research
for
a
total
of
$
411,612
for
PGPR
and
fumigation
research.
I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.

Signature
Date
Print
Name
Title
International
Paper
Corporation
Signature
Date
Print
Name
Title
and
Orchards
International
Paper
Corporation
OMB
Control
#
2060­
0482
Information
in
this
application
may
be
aggregated
with
information
from
other
applications
and
used
by
the
United
States
government
to
justify
claims
in
the
national
nomination
package
that
a
particular
use
of
methyl
bromide
be
considered
"
critical"
and
authorized
for
an
exemption
beyond
the
2005
phase
out.
Use
of
aggregate
data
will
be
crucial
to
making
compelling
arguments
in
favor
of
critical
use
exemptions.
By
signing
below,
you
agree
not
to
assert
any
claim
of
confidentiality
that
would
affect
the
disclosure
by
EPA
of
aggregate
information
based
in
part
on
information
contained
in
this
application.

Manager,
Nurseries
6­
Sep­
02
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
Richard
O.
Barham
Manager;
Nurseries
Richard
O.
Barham
9­
Sep­
02
Worksheet
5.
Additional
Information
The
research
within
the
Coop
is
highly
cooperative.
Nothing
can
be
done
without
the
cooperation
of
the
nursery
that
agrees
to
allow
the
study
to
be
placed
on
its
production
beds.
It
is
very
difficult
to
estimate
the
dollar
contributions
of
these
cooperating
nurseries.
For
several
studies
the
host
nursery
has
just
set
the
study
area
aside
and
not
included
it
in
its
inventory
of
sold
seedlings
from
treatment
plots.
In
several
studies
seedlings
from
treatment
plots
have
not
been
salable.
The
fate
of
seedlings
within
a
study
area
often
depends
on
market
demands.
In
all
instances
we
have
received
labor
help
from
the
host
nursery.
It
is
certain
that
the
dollar
value
for
this
contribution
is
not
zero,
but
very
difficult
to
estimate.

We
estimate
cost
of
MBr
replacement
research
associated
with
the
Auburn
Nursery
Coop
figures
to
have
been
$
1,266,673
between
1993
and
2002.
B67
For
EPA
Use
Only
and
Orchards
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
92,000
5.
Area
Treated
with
Methyl
Bromide
2005
270
acre
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

2006
92,000
lbs.
Area
Treated
270
acres
units
2007
92,000
lbs.
Area
Treated
270
acres
units
Not
Technically
Feasible
Not
Economically
Feasible
X
X
X
X
X
X
X
X
X
X
X
Metham­
Sodium
The
population
of
soil
pathogens
and
parasites
can
be
affected
by
organic
amendments.
However,
the
population
of
weeds
is
not
influenced
and
could
even
increased
depending
on
the
source
of
the
organic
amendment.
Effects
on
seedling
size
have
been
variable.
This
alternative
may
be
effective
in
a
comprehensive
IPM/
crop
rotation
At
present
a
workable
program
to
control
weeds
and
soil
pathogens
and
parasites
has
not
be
devised.
This
is
the
most
promising
area
of
research.

Place
an
"
X"
in
the
column(
s)
labeled
"
Not
Technically
Feasible"
and/
or
"
Not
Economically
Feasible"
where
appropriate.
Use
the
"
Reasons"
column
to
describe
why
the
potential
alternative
is
not
feasible.

Organic
Amendments
General
IPM
/
Crop
Rotations
Solarization
Physical
Removal
Ploughing
Flooding
Potential
Alternatives
Reasons
Potential
human
and
environmental
risks,
lack
of
consistently
demonstrable
effectiveness,
loss
in
crop
quantity
and
quality.
The
ability
to
return
a
ROI
of
sufficient
magnitude
to
warrant
seedling
production
is
doubtful.

Basamid
Proven
human
and
environmental
risks,
lack
of
consistently
demonstrable
effectiveness,
loss
in
crop
quantity
and
quality.
The
ability
to
return
a
ROI
of
sufficient
magnitude
to
warrant
seedling
production
is
doubtful.

Not
feasible
due
to
sandy
well
drained
soils.
Further,
nursery
fields
are
designed
to
promote
water
movement
from
the
fields.

Our
nursery
cycle
(
see
Appendix
1
Crop
Profile
for
details)
requires
fumigation
to
occur
just
after
cover
crop
removal.
This
occurs
in
the
late
fall
to
early
spring.
This
period
is
characterized
by
low
air/
soil
temperatures
and
increased
clouds.
However,
this
method
may
have
potential
when
included
in
a
comprehensive
IPM/
crop
rotation
No
practical
method
to
physically
remove
nutsedge
tubers.
Handweeding
is
possible
but
prohibitively
expensive
on
a
large
scale.

Traffic
over
nursery
soils
increases
soil
compaction.
Repeated
ploughing
creates
a
"
plow
layer"
which
inhibits
root
growth
and
decreases
soil
aeration.

International
Paper
SuperTree
nurseries
grow
pine
bareroot
seedlings
on
a
2:
2
rotation.
For
a
given
acre,
two
years
produce
seedlings
and
two
years
produce
cover
crop.

Prior
to
producing
seedlings
the
land
is
fumigated.
Fumigation
is
needed
every
year
for
those
acres
just
beginning
a
new
rotation
cycle.

Savannah,
Georgia;
Headquarters
of
the
Nursery
and
Orchard
Group
Pine
SuperTree
Seedlings
Name
of
Applicant:

Location:

Crop:
International
Paper
For
EPA
Use
Only
ID#

Worksheet
6.
Application
Summary
This
worksheet
will
be
posted
on
the
web
to
notify
the
public
of
requests
for
critical
use
exemptions
beyond
the
2005
phase
out
for
methyl
bromide.
Therefore,
this
worksheet
cannot
be
claimed
as
CBI.
General
Production
Information
 
Forestry
in
the
United
States,
with
an
annual
harvest
of
$
24
billion
and
an
employment
of
1.6
million
directly,
3.8
million
indirectly
(
Pait,
2001),
is
dependent
on
a
continuous
supply
of
high
quality
seedlings.
Tree
planting
in
the
United
States
has
been
on
a
steady
upward
trend
since
the
mid
1930'
s,
when
about
140,000
acres
were
planted
to
the
current
(
1998)
level
of
over
2,600,000
acres
(
Moulton
and
Hernandez,
1999).

 
According
to
Moulton
and
Hernandez
(
1999),
ninety
percent
of
the
1,642,089,000
seedlings
produced
in
1998
were
planted
on
private
lands.
Non­
industrial
private
forests
landowners
planted
more
acres
than
any
other
group
of
owners,
48%
of
the
U.
S.
total.
Forest
industry
planted
42%
of
the
total.
More
trees
are
planted
on
State
forest
than
on
any
other
category
of
State
and
local
government
lands.
Tree
planting
on
the
National
forest
are
declining;
acres
planted
in
1998
falling
to
the
lowest
level
since
1960.
The
Southern
states
planted
more
acreage
in
trees
than
any
other
region
(
2,065,779),
accounting
for
79%
of
the
U.
S.
total.
More
seedlings
were
planted
in
Georgia
than
any
other
state.

 
Over
1.6
billion
forest
tree
seedlings
are
grown
annually
on
about
2,000
nursery
acres
in
the
U.
S.
Forest
tree
nurseries
are
located
nationwide
with
78%
in
the
South,
17%
in
the
West
and
5%
in
the
North.
Each
acre
of
loblolly
pine
nursery
in
the
Southern
U.
S.
has
been
calculated
to
be
worth
about
$
23,000.00
(
South,
1999).
Total
value
of
the
1,560
acres
of
southern
forest
tree
nurseries,
the
majority
of
which
are
loblolly
nurseries,
would
then
be
approximately
$
35.8
million.

 
The
seed
required
to
plant
the
nursery
acres
are
provided
from
intensively
managed
Seed
Orchards
and
are
valued
from
$
65
to
$
85
per
pound.
Approximately
45
pounds
of
seed
are
planted
per
acre
of
nursery
for
a
seed
cost
per
acre
of
$
3300.

 
Forest
tree
nurseries
in
the
U.
S.
use
a
very
small
percentage
of
the
herbicides,
fungicides,
insecticides,
and
fumigants
used
in
the
U.
S.
With
the
benefits
provided
by
pesticides,
seedlings
can
be
produced
for
less
than
4
cents.
Without
pesticides,
seedlings
would
likely
cost
more
than
15
cents
each.

 
The
most
effective
pesticide
used
in
pest
management
strategies
is
the
fumigation
of
the
nursery
beds
with
methyl
bromide.
The
pending
loss
of
this
option
will
likely
increases
reliance
on
more
Appendix
2.
Figures
Figure
1.
Heavy
yellow
nutsedge
infestation
in
non­
fumigated
soil.

Photograph
of
heavy
yellow
nutsedge
infestation
on
pine
seedling
beds.
Nutsedge
is
bright
green.
Pine
seedlings
are
lighter
green
and
can
barely
be
seen.
Appendix
2.
Figures
Figure
2.
Metham­
sodium
Outgassing
Damage
Metham­
sodium
outgassing
damage
at
International
Paper's
SuperTree
Seedling
nursery
at
Bullard,
Texas.
Soil
fumigated
with
Metham­
sodium
can
be
seen
at
the
top
of
the
photograph.
During
the
night,
metham­
sodium
outgassed
from
the
soil
and
drifted
downwind
over
the
pine
seedling
beds.
Trees
killed
from
the
Metham­
sodium
are
brownish­
red.
Trees
not
in
the
Metham­
sodium
plume
remain
green
and
alive.
Appendix
3
List
of
References
Auburn
University
Southern
Forest
Nursery
Management
Cooperative.
2002.
Application
for
Critical
Use
Exemption
of
Methyl
Bromide.
(
Submitted
to
EPA,
September
9,
2002)

Barnard,
E.
L.,
M.
E.
Kannwischer­
Mitchell,
D.
J.
Mitchell,
and
S.
W.
Fraedrich.
1997.
Development
and
field
performance
of
slash
and
loblolly
pine
seedlings
produced
in
fumigated
nursery
seedbeds
and
seedbeds
amended
with
organic
residues.
Pp.
32­
37
Carey,
W.
A.
1994a.
Chemical
alternatives
to
methyl
bromide.
In:
Landis,
T.
D.
andR.
K.
Dumrose,
Tech.
Coord.,
National
Proceedings:
Forest
and
Conservation
Nursery
Association,
pp4­
11
Carey,
W.
A.
1994b.
Chemical
alternatives
to
methyl
bromide.
In:
Proceedings
of
the
combined
Southern/
Northeastern
Forest
Nursery
Conference,
Williamsburg,
Va,
pp.
4­
11
Carey,
W.
A.
1995.
Testing
alternatives
to
methyl
bromide
fumigation
at
New
Kentnursery.
Auburn
University
Nursery
Cooperative
Research
Rpt.
95­
1,
4p.

Carey,
W.
A.
1996.
Testing
alternatives
to
methyl
bromide
fumigation
at
the
Winona
Nursery.
Auburn
University
Nursery
Cooperative
Research
Rpt.
96­
2,
4p
Carey,
W.
A.
1997.
A
single
test
of
hot
water,
1,3­
D,
and
metham­
sodium
as
alternatives
to
methyl
bromide.
Auburn
University
Nursery
Cooperative
Research
Rep.
97­
7.
6p.

Carey,
W.
A.
1998.
Alternatives
to
methyl
bromide
in
forest
tree
nurseries.
In:
Landis,
T.
D.;
Barnett,
J.
P.,
Tech.
Coord.
National
Proceedings:
forest
and
conservation
nursery
associations.
Gen.
Tech.
Rep.
SRS­
25.
Ashville,
NC,
USDA,
pp
69­
70.

Carey,
W.
A.
1999.
A
comparison
of
chloropicrin,
metham­
sodium,
and
EPTC
combinations
as
methyl
bromide
alternatives
at
three
nurseries.
Auburn
University
Nursery
Cooperative
Research
Rpt.
99­
2,
4p
.
Carey,
W.
A.
2000a.
Seedling
production
and
weed
control
by
a
potential
replacement
for
methyl
bromide
at
the
Flint
River
Nursery.
Auburn
University
Nursery
Cooperative
Research
Rpt.
00­
3,
3p.

Carey,
W.
A.
2000b.
Seedling
production
by
alternative
fumigants,
application.
techniques
and
EPTC
at
the
Glenville
Regeneration
Center.
Auburn
University
Nursery
Cooperative
Research
Rpt.
00­
6,
4p.
Appendix
4.
Effect
of
methyl
bromide
fumigation
on
nursery
and
pine
plantation
revenue
and
growth
for
both
International
Paper
and
southeastern
forestry.

Benefits
of
methyl
bromide
fumigation
accrue
to
both
pine
nurseries
and
plantations
throughout
the
southeast.
In
the
nursery,
the
effects
of
a
single
methyl
bromide
fumigation
last
for
two
consecutive
pine
seedling
crops.
At
International
Paper,
one
acre
of
fumigated
nursery
soil
will
produce
over
1.3
million
pine
seedlings
in
two
years.
Only
215lbs
of
fumigant
(
80/
20
methyl
bromide
@
350lbs/
acre)
are
needed
to
produce
1
million
SuperTree
seedlings
or
0.21lbs
per
1000
seedlings.
The
potential
revenue
for
each
nursery
acre
can
approach
nearly
$
55M
over
two
years.

All
chemical
fumigation
alternatives
evaluated
to
date
have
lower
seedling
survival
in
the
nursery
bed
compared
to
methyl
bromide.
The
reduction
can
range
from
2
to
9
seedlings
per
square
foot
(
South
and
Carey,
2000).
A
reduction
by
2
to
9
seedlings
per
square
foot
in
each
nursery
acre
will
result
in
lower
annual
revenues
by
$
2.2M
or
$
9.7M,
respectively.
Without
methyl
bromide
fumigation,
the
potential
annual
revenue
from
all
nine
International
Paper
SuperTree
nurseries
could
be
reduced
by
$
1.1MM
to
more
than
$
5.0MM.
Annual
pine
seedling
production
in
the
southeast
is
approximately
900MM
(
Moulton,
et
al.,
1995).
A
similar
2
to
9
seedling
reduction
per
square
foot
could
result
in
an
annual
revenue
loss
of
up
to
$
10.8MM
across
all
pine
seedling
nurseries
in
the
southeast.

Methyl
bromide
alternatives
do
not
control
weeds
to
any
great
extent.
Weed
competition
in
the
nursery
beds
will
result
in
lower
seedling
quality,
particularly
smaller
seedling
size,
since
the
weeds
are
competing
for
the
same
nutrients
and
water
as
pine
seedlings.
With
methyl
bromide
fumigation,
International
Paper
SuperTree
nurseries
produce
grade
one
(
Root
Collar
Diameter
>
4.8mm)
seedling
crops
that
are
sold
at
an
average
price
of
$
40/
1000
seedlings.
Grade
1
seedlings
grow
faster
in
the
field
and
have
increased
survival
once
planted
than
smaller
seedlings
(
South,
et
al,
2001).
Many
customers
demand
these
larger
seedlings
so
that
their
reforestation
or
ecosystem
regeneration
efforts
are
successful.
A
loss
of
methyl
bromide
fumigation
will
produce
more
grade
2
(
RCD
>
3.8
<
4.7mm)
seedlings
and
cull
seedlings
that
are
too
small
to
be
planted.
Seedling
crops
with
a
high
proportion
of
grade
2
and
cull
seedlings
cannot
be
sold
at
the
current
average
selling
price.
A
reduction
in
the
average
selling
price
of
just
$
5/
1000
seedlings
would
result
in
an
additional
loss
of
nearly
$
5.3M
per
acre
per
year.

The
effects
of
one
methyl
bromide
fumigation
at
a
seedling
nursery
can
still
be
seen
at
the
end
of
a
25­
year
pine
plantation
rotation.
Pine
plantations
established
with
grade
one
seedlings
have
greater
stocking
(
i.
e.
number
of
