UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
Under
the
Clean
Air
Act
and
the
international
treaty
to
protect
the
ozone
layer
(
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer),
the
production
and
import
of
methyl
bromide
will
be
phased
out
in
the
United
States
on
January
1,
2005.
This
application
seeks
information
to
support
a
U.
S.
request
to
produce
and
import
methyl
bromide
for
certain
critical
uses
and
circumstances
beyond
this
2005
phaseout
date.

The
information
in
this
application
will
be
used
to
review
whether
your
use
of
methyl
bromide
is
"
critical"
because
no
technically
and
economically
feasible
alternatives
are
available.
In
order
to
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available,
EPA
needs
to
compare
data
(
yields,
crop/
commodity
prices,
revenues
and
costs)
for
your
use
of
methyl
bromide
with
uses
of
alternative
pest
control
regimens.

If
you
submit
a
well
documented
application
with
sound
reasons
why
alternatives
are
not
technically
and
economically
feasible,
the
U.
S.
government
can
be
a
better
advocate
for
your
exemption
request
internationally.

OMB
Control
#
2060­
0482
WHY
IS
THIS
INFORMATION
NEEDED?
Application
for
Critical
Use
Exemption
of
Methyl
Bromide
for
Use
in
2005
in
the
United
States
Click
on
the
Instructions
tab
located
at
the
bottom
of
the
screen
for
additional
information.

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.
STATE
CONTACTS
HOW
DO
I
APPLY?

OMB
Control
#
2060­
0482
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
2­
A.
Methyl
Bromide
Use
1997­
2000
(
i)
The
specific
use
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
that
use
would
result
in
a
significant
market
disruption;
and
(
ii)
There
are
no
technically
and
economically
feasible
alternatives
available
to
the
user
that
are
acceptable
from
the
standpoint
of
environment
and
health
and
are
suitable
to
the
crops
and
circumstances
of
the
nomination
 "

WHO
APPLIES?

SECTIONS
OF
WORKBOOK
The
information
provided
by
you
in
this
application
will
be
used
to
evaluate
the
requested
methyl
bromide
use.
The
U.
S.
and
other
countries
that
are
parties
to
the
Montreal
Protocol
On
Substances
That
Deplete
The
Ozone
Layer
decided
that:
"
a
use
of
methyl
bromide
should
qualify
as
"
critical"
only
if
the
nominating
Party
determines
that:
INSTRUCTIONS
Each
worksheet
number
corresponds
to
the
tab
number
in
the
electronic
version
of
the
application.
Instructions
specific
to
each
worksheet
are
provided
at
the
top
of
each
sheet.
A
header
row
is
included
on
each
worksheet
to
include
an
application
ID
number
that
EPA
will
assign.
You
may
either
complete
an
electronic
(
Microsoft
Excel)
or
a
printed
version
of
the
application.
Please
fill
out
each
form
or
worksheet
in
the
application
as
completely
as
possible.
If
you
are
completing
the
printed
version
and
need
extra
space
you
may
attach
additional
sheets
as
needed.
Additional
information
may
be
available
from
your
local
state
department
of
agriculture
or
at
the
sites
listed
below
or
by
calling
1­
800­
296­
1996.

Instructions
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
Worksheet
2.
Methyl
Bromide
­
Historical
Data
If
you
anticipate
that
you
will
need
methyl
bromide
in
2005
because
you
believe
there
are
no
technically
and
economically
feasible
alternatives,
then
you
should
apply
for
the
critical
use
exemption.
This
application
may
be
submitted
either
by
a
consortium
representing
multiple
users
or
by
individual
users.
We
encourage
users
with
similar
circumstances
of
use
to
submit
a
single
application
(
for
example,
any
number
of
pre­
plant
users
with
similar
soil,
pest,
and
climactic
conditions
can
submit
a
single
application.)

If
a
consortium
is
applying
for
multiple
methyl
bromide
users,
the
economic
data
should
be
for
a
representative
or
typical
user
within
the
consortium
unless
otherwise
noted.
If
economic
or
technical
factors
(
such
as
size
of
the
farm)
affecting
the
ability
of
this
"
representative
user"
to
use
alternatives
are
significantly
different
than
other
users
in
the
consortium,
more
than
one
application
should
be
submitted
to
reflect
these
differences.

Please
contact
your
local,
state,
regional
or
national
commodity
association
and/
or
state
representative
agency
to
find
out
if
they
plan
on
submitting
an
application
on
behalf
of
your
commodity
group.

2­
B.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Revenue
1997­
2000
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Revenue
2001
2­
D.
Methyl
Bromide
Use
and
Costs
for
2001
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
2­
F.
Methyl
Bromide
­
Fixed
and
Overhead
Costs
Worksheet
3.
Alternatives
­
Feasibility
of
Alternatives
to
Methyl
Bromide
3­
A.
Alternatives
­
Technical
Feasibility
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Revenue
3­
D.
Alternatives
­
Other
Operating
Costs
Research
Summary
Worksheet
Example
Research
Sum
(
Summary)
Worksheet
Worksheet
4.
Alternatives
­
Research
Plans
Worksheet
5.
Additional
Information
Fumigation
Cycle
Climate
Zone
Map
Worksheet
6.
Application
Summary
States
that
have
agreed
to
participate
in
the
exemption
process
are
listed
on
EPA's
website
at
www.
epa.
gov/
ozone/
mbr/
cueqa.
html
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
IS
MY
INFORMATION
CONFIDENTIAL?

WHEN
IS
THE
INFORMATION
NEEDED?

HOW
CAN
I
RECEIVE
ADDITIONAL
INFORMATION?
WHERE
DO
I
SUBMIT
THE
APPLICATION?
The
applicant
may
assert
a
business
confidentiality
claim
covering
part
or
all
of
the
information
in
the
application
by
placing
on
(
or
attaching
to)
the
information,
at
the
time
it
is
submitted
to
EPA,
a
cover
sheet,
stamped
or
typed
legend,
or
other
suitable
form
of
notice
employing
language
such
as
trade
secret,
proprietary,
or
company
confidential.
Allegedly
confidential
portions
of
otherwise
non­
confidential
documents
should
be
clearly
identified
by
the
applicant,
and
may
be
submitted
separately
to
facilitate
identification
and
handling
by
EPA.
If
the
applicant
desires
confidential
treatment
only
until
a
certain
date
or
until
the
occurrence
of
a
certain
event,
the
notice
should
so
state.
Information
covered
by
a
claim
of
confidentiality
will
be
disclosed
by
EPA
only
to
the
extent,
and
by
means
of
the
procedures
set
forth
under
40
CFR
Part
2
Subpart
B;
41
FR
36902,
43
FR
400000.
50
FR
51661.
If
no
claim
of
confidentiality
accompanies
the
information
when
it
is
received
by
EPA,
it
may
be
made
available
to
the
public
by
EPA
without
further
notice
to
the
applicant.
Applicants
submitting
their
application
via
e­
mail
assume
responsibility
for
the
confidentiality
of
the
electronic
me
This
application
must
be
postmarked
to
the
EPA
address
below
no
later
than
120
days
after
the
Notice
was
published
in
the
Federal
Register
requesting
critical
use
exemption
applications.

Electronic
Address
for
applications:
methyl.
bromide@
epa.
gov
(
When
submitting
an
application
electronically,
you
should
also
print
a
hard
copy,
sign
the
copy,
and
submit
it
by
mail)

Mailing
Address
for
applications
being
submitted
by
mail
directly
to
the
EPA:
US
Environmental
Protection
Agency
Methyl
Bromide
Critical
Use
Exemption
Global
Programs
Division,
Mail
Code
6205J
1200
Pennsylvania
Ave,
NW
501
3rd
St.
NW
Washington,
DC
20001
Washington,
DC
20460­
0001
Address
for
applications
being
sent
by
courier
or
non­
U.
S.
Postal
overnight
express
delivery
to
EPA:
US
Environmental
Protection
Agency
1­
800­
296­
1996
phone:
(
202)
564­
9410
If
you
have
general
questions
about
this
application
call:

Stratospheric
Ozone
Hotline
Methyl
Bromide
Critical
Use
Exemption
Global
Programs
Division
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
1
To
add
additional
blank
worksheets
in
the
Excel
file,
go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Insert"
then
"
worksheet"

2
A
tab
with
the
name
"
Sheet
1"
will
appear
at
the
bottom
of
the
worksheet
and
will
be
highlighted
in
white.
Take
the
cursor
and
double
click
the
"
new
tab"

3
By
double
clicking
in
the
tab
you
can
now
rename
the
worksheet
to
the
appropriate
number
letter
designation
(
e.
g.,
3­
A(
1),
3­
A(
1)(
a),
etc.)

4
To
move
a
newly
inserted
worksheet,
simply
drag
the
worksheet
with
your
mouse
to
the
desired
location.

5
Once
you
add
a
new
worksheet,
Excel
will
automatically
name
each
subsequently
added
worksheet
as
Sheet
2,
Sheet
3,
Sheet
4,
etc 
Follow
the
instructions
above
to
rename
the
new
blank
worksheets
as
appropriate.

1
Select
the
worksheet
to
be
copied
by
clicking
on
the
worksheet
tab
at
the
bottom
of
the
screen.
The
tab
will
turn
white
in
color
when
it
has
been
selected.

2
Select
the
top
left
corner
of
the
worksheet
(
this
is
the
space
to
the
left
of
the
column
A
and
above
the
row
1.
You
will
know
that
the
entire
worksheet
has
been
selected
because
the
row
and
column
marks
as
well
as
the
worksheet
itself
will
change
to
a
different
color.

3
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Copy".

4
Go
to
the
blank
worksheet
where
you
want
the
copied
information
to
be
pasted.

5
Again,
select
the
top
left
corner
of
the
worksheet
(
left
of
column
A
and
above
row
1)
to
select
the
entire
worksheet.

6
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Paste"

7
Change
the
title
row
of
the
newly
pasted
worksheet
from
the
old
worksheet
number
to
be
consistent
with
the
worksheet
tab.

If
you
would
like
to
print
all
worksheets
that
are
contained
in
this
workbook,
go
to
the
menu
bar
at
the
top
of
the
screen
and
select
"
File"
and
then
"
Print."
Then
in
the
section
of
the
menu
that
appears
called
"
Print
what,"
select
"
Entire
Workbook."
EXCEL
USER
TIPS
The
two
arrows
on
the
bottom
right
of
the
screen
allow
you
to
move
the
worksheet
that
you
are
viewing
to
the
right
or
to
the
left.
This
is
useful
if
the
viewable
area
of
on
the
screen
is
smaller
than
the
entire
page
that
is
in
the
worksheet.
Worksheets
are
best
viewed
in
"
Page
Break
Preview."
To
select
the
view
of
the
worksheet,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Page
Break
Preview."
Page
break
preview
shows
only
the
printable
area
of
the
worksheet,
with
the
blue
lines
that
surround
the
screen
indicating
the
edges
of
each
page.

To
increase
or
decrease
the
size
of
the
page
that
is
viewable
on
the
screen,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Zoom".

Navigating
between
worksheets
Printing
worksheets
Note:
This
is
the
only
way
you
can
copy
a
worksheet
and
not
lose
portions
of
the
text
instructions.

Viewing
worksheets
The
set
of
four
arrows
on
the
bottom
left
of
the
screen
will
help
you
navigate
between
worksheets.
This
is
necessary
to
access
the
remaining
worksheet
tabs
in
the
workbook
that
are
not
viewable.
The
two
arrows
with
vertical
lines
to
either
the
left
or
right
will
take
you
to
the
first
worksheet
and
to
the
last
worksheet
respectively
in
the
workbook.
The
inner
two
arrows
allow
you
move
the
worksheet
tabs
to
the
right
or
to
the
left
incrementally.
Copying
and
pasting
an
entire
worksheet's
contents
into
a
blank
worksheet:
Inserting
a
blank
worksheet:
1.

2.

3.

4.

Light
Medium
X
Heavy
0
to
2%
2
to
5
%
100
over
5%

5.

6.
Specialty
(
check
one)

7.
Lee
E.
Riley
agronomic
X
8.
economic
9.
Daytime
phone
10.
FAX
11.

List
an
additional
contact
person
if
available.
Specialty
(
check
one)

12.
agronomic
X
13.
economic
14.
15.
FAX
16.
Cottage
Grove,
OR
97424
leriley@
fs.
fed.
us
None
(
541)
767­
5709
Contact
name
Address
(
541)
767­
5723
E­
mail
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).

Western
Forest
and
Conservation
Public
Nursery
Association
The
Western
States,
specifically
the
public
nurseries
in
the
states
of
California,
Idaho,
Kansas,
Nebraska,
Oregon,
Utah,
Washington
Nursery
grown
conifer
and
hardwood
(
deciduous)
bareroot
tree
seedlings
and
transplants
used
for
reforestation.
Conifer
species
include
Pseudotsuga
menziesii
,
Larix
occidentalis
,
Pinus
spp.,
Abies
spp.,
Picea
spp.
Hardwood
species
include
Quercus
,
Populus,
Acer.
In
addition
to
tree
seedlings,
a
variety
of
shrub,
grass,
and
forb
species
are
grown.
The
conifer
and
hardwood
species
are
used
to
reestablish
timber
species
in
logged
areas.
These
species,
along
with
the
sh+
B32rub,
forb,
and
grass
species,
are
also
used
in
ecosystem
restoration
following
catastrophic
events,
such
as
fire,
floods,
etc.
The
latter
are
most
commonly
planted
for
wildlife,
fisheries,
aesthetic,
and
ecosystem
restoration
objectives
.

Soil
Type:

Organic
Matter:
Soil
type
Check
the
box(
es)
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.

Consortium
name
JH
Stone
Nursery,
2606
Old
Stage
Rd
Location
(
Enter
the
state,
region,
or
county.
Provide
more
detail
about
the
location
if
relevant
to
the
feasibility
of
alternatives
to
methyl
bromide.)

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).
Zone
4
­
13%
production;
Zone
6
­
2%
production;
Zone
8
­
71%
production;
Zone
9
­
12%
production;
Zone
10
­
2%
production
Dorena
GRC,
34963
Shoreview
Rd
(
541)
858­
6166
(
541)
858­
6110
tlandis@
fs.
fed.
us
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Central
Point,
OR
97502
Tom
D.
Landis
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
45000
lbs.

17a.
Acres
units
18.
Yes
X
No
18a.

19.

20.

20a.

OMB
Control
#
2060­
0482
45000
Unit
of
Area
Treated
The
use
of
methyl
bromide
is
essential
for
control
of
such
a
broad
range
of
pest
species.
Fumigation
targets
a
broad
spectrum
of
fungal
pathogens,
invertebrate
pests,
and
weed
species.
Fungal
Pathogens:
The
impact
of
individual
fungal
species
varies
between
nurseries.
The
predominate
fungal
species
include
Macraphomina
(
particularly
in
California),
Cylindrocladium
spp.,
Fusarium
Spp.,
Pythium
spp.,
Phytophthora
spp.,
Phoma,
Phomopsis,
Verticillium
wilt,
Sirococcus,
root
gall
pathogens
Invertebrate
pests:
Fumigation
has
been
shown
to
be
critical
in
the
control
of
nematodes
and
larval
stages
of
various
species
of
root
weevils
which
have
caused
significant
crop
losses
in
the
past.

Weed
species:
Fumigation
provides
the
most
efficient
and
effective
control
of
a
variety
of
noxious
weed
species,
including
senecio,
poa,
thistle,
and
most
particularly
,
Cyperus
spp.,
for
which
there
is
no
currently
labeled
effective
nursery
product.
2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
45000
Area
to
be
Treated
150
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.

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

Year
Explain
why
this
user
represents
the
typical
user
in
the
consortium.
150
Specific
sections
of
seedling
production
areas
are
fumigated
each
year.
The
request
for
a
Critical
Use
Exemption
is
based
on
this
annual
application
requirement.
How
much
area
will
this
be
applied
to?
Please
list
units.
150
For
EPA
Use
Only
ID#

Forest
tree
nurseries(
public)
in
the
western
United
States
produce
40
to
60
million
bareroot
trees
(
conifer
and
hardwood)
and
.6
to
.7
million
shrub,
forb
and
grass
species
annually.
Conifer
seedlings
represent
95
of
that
total.
Conifer
crops
are
grown
as
1­
year­
old,
2­
year­
old,
or
transplants
depending
on
the
species
or
target
seedling
type.
Each
crop
type
requires
a
different
schedule
of
fumigation
and
cover
crop
rotation.
Methyl
bromide
is
predominately
used
in
the
western
states
on
a
selective
basis,
targeting
only
areas
where
alternative
chemicals
have
been
proven
to
be
ineffective
or
damaging
to
nearby
crops.
Nurseries
covered
by
this
consortium
are
predominately
owned
by
Federal
and
State
governmental
forestry
agencies.
Consortium
nurseries
are
distributed
throughout
the
region.

The
"
typical
user"
as
defined
for
this
application
is
based
on
nursery
surveys,
the
National
Nursery
directory
(
www.
rngr.
net/
nurseries/
dirfor.
html),
and
interaction
with
nursery
managers.
The
Western
Forest
and
Conservation
Nursery
association
has
been
involved
in
nursery
information
and
technology
transfer
for
many
years,
and
is
familiar
with
"
typical"
nursery
activities
throughout
the
region.
How
much
active
ingredient
(
ai)
of
methyl
bromide
are
you
requesting
for
2005?

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.
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.)
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.

Are
you
requesting
methyl
bromide
for
additional
years
beyond
2005?

Acres
Acres
2007
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.
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
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
140
49000
350
180
63000
350
180
63000
350
190
66500
350
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
140
49000
350
180
63000
350
180
63000
350
190
66500
350
Comments:
Methyl
bromide
use
1997­
2000
The
purpose
of
the
Western
Forest
and
Conservation
Nursery
Association
has
historically
been
information
and
technology
transfer.
As
such,
we
have
not
historically
kept
records
of
seedling
production
and
methyl
bromide
use
numbers.
We
do,
however,
have
seedling
production
inventories
published
by
the
US
Forest
Service,
as
well
as
historical
records
of
methyl
bromide
application
from
the
area
professional
applicators.
The
above
historical
data
is
based
on
that
information
from
Federal
and
State
nurseries.

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.
Worksheet
Title
Instructions
specific
to
each
worksheet
are
located
at
the
top
of
each
sheet.

2­
A
Methyl
Bromide
Use
for
1997
­
2000
This
worksheet
provides
data
in
actual
usage
for
1997­
2000.

2­
B
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
1997­

2000
This
worksheet
provides
crop/
commodity
yield
and
gross
revenue
for
1997
through
2000.

2­
C
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
2001
This
data
provides
historical
information
on
crop/
commodity
yield
and
gross
revenue
for
2001.

2­
D
Methyl
Bromide
Use
and
Costs
for
2001
This
worksheet
isolates
use
and
cost
data
for
2001.

2­
E
Methyl
Bromide
­
Other
Operating
Costs
for
2001
This
data
is
needed
to
estimate
a
baseline
for
operating
costs
in
order
to
estimate
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

2­
F
Methyl
Bromide
­
Fixed
And
Overhead
Costs
for
2001
This
data
is
needed
to
estimate
a
baseline
for
total
costs
in
order
to
estimate
the
impact
on
profitability
and
long­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

Purpose
of
Data:
To
establish
a
baseline
estimate
of
crop/
commodity
yields,
gross
revenues,
and
costs
using
methyl
bromide.
Worksheet
2.
Methyl
Bromide
­
Historical
Use
of
Methyl
Bromide
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)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)

1997
1000
trees
258
$
275.00
$
70950/
ac
1998
1000
trees
258
$
275.00
$
70950/
ac
1999
1000
trees
258
$
285.00
$
73530/
ac
2000
1000
trees
258
$
295.00
$
76110/
ac
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
for
1997
$
9.93
million
Total
Revenue
for
1998
$
12.77
million
Total
Revenue
for
1999
$
13.24
million
Total
Revenue
for
2000
$
14.46
million
Average
Revenue
Per
Year
$
12.6
million
Comments:
The
purpose
of
the
Western
Forest
and
Conservation
Nursery
Association
has
historically
been
information
and
technology
transfer.
As
such,
we
have
not
historically
kept
records
of
seedling
sales.
The
above
data
is
based
on
seedling
production
inventories
and
average
costs
of
stocktypes.

Although
the
price
per
unit
and
units/
acre
differ
for
seedlings
and
transplants,
an
average
cost
and
average
units/
acre
were
affixed
to
the
commodity.

Table
2B.
Average
cost
per
stocktype
for
2001
Stocktype
Units/
Ac
Price
Seedling
344
$
220
Transplant
172
$
370
Ave
258
$
295
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
Col.
B:
Crop/
Commodity
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
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.

Conifer
seedlings/
transplants
Conifer
seedlings/
transplants
Conifer
seedlings/
transplants
B
Conifer
seedlings/
transplants
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)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)

Conifer
seedlings
Species/
age/
size
1000
trees
344
$
220.00
$
75,680.00
Conifer
transplants
Species/
size
1000
trees
172
$
370.00
$
63,640.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
$
2.41
million
Comments:

Total
revenue
is
calculated
for
an
"
average"
nursery
Table
2C.
Calculation
of
gross
revenue
for
a
"
representative
user"
nursery
in
2001
Crop
Production
(
in
millions)
Acres
Value/
Ac
Revenue
Conifer
seedlings
2.8
8
$
75,680
$.
605
million
Conifer
transplants
5
28.5
$
63,640
$
1.81
million
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.

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

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.

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
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
Cost
per
Area
over
95%
methyl
bromide
$
0.00
75%
methyl
bromide,
25%
chloropicrin
$
0.00
67%
methyl
bromide,
33%
chloropicrin
300
lbs./
acre
$
2.90
$
300.00
$
500.00
150
$
1,670.00
50%
methyl
bromide,
50%
chloropicrin
$
0.00
__%
methyl
bromide,
__%
chloropicrin
$
0.00
__%
methyl
bromide,
__%
chloropicrin
$
0.00
$
0.00
All
formulations
of
methyl
bromide
300
lbs./
acre
$
2.90
$
300.00
$
500.00
150
$
1,670.00
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:
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
$
1,448.27
Postage
FedEx,
UPS,
and
regular
mail
charges
Communications
Telephones,
Cellular
Phones
$
38.56
Data
Processing
Computer
Hardware
Computers,
printers,
etc.

Rentals­
Tangible
Properties
Machine
Rentals
Rentals­
Real
Property
Land
Rental
$
466.67
Vehicle
Lease
Expenses
Auto
Lease
and
Heavy
Equipment
$
260.53
Dues
and
Assessments
Trade
Association
Dues
and
Contributions
Publications
Trade
Magazine
Subscriptions
Meetings
Taxes
Sales
and
Property
Taxes
Depreciation
Capitalized
Interest
and
Plant
Depreciation
$
1,356.00
Legal
Settlements
Company
Legal
Bill
$
197.51
Supplies
and
Equipment
Managerial
and
Administrative
Supplies
$
114.94
Other
Income/
Expenses
Utilities
Water
and
Electricity
$
191.57
Allocations
and
Transfers
Corporate
and
Division
Overhead
$
957.85
Total
$
5,031.90
Comments:

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.
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
$
478.00
$
387.00
$
865.00
Sowing
$
335.00
$
162.00
$
497.00
Maintenance
$
255.00
$
425.00
$
680.00
Fertilization,
Pest
Control,

pruning,
etc.

Harvest
and
Storage
$
762.00
$
725.00
$
1,487.00
Total
Custom
per
Area
User
Total
per
area
$
3,529.00
1)
2)
3)
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
Note
on
typical
equipment
used:
Highly
mechanized
harvesting
operation
using
specially
designed
seedling
lifters.
Seedlings
placed
in
cold
storage
until
shipped
to
planting
site.
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.

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.
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
X
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
rates,
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
of
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websites
for
studies
that
pertain
to
your
crop
and
geographic
area.
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
alternative
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
1996.
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

Metam­
sodium,
Dazomet
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.
For
EPA
Use
Only
ID#
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.

2.
Author(
s)
or
researcher(
s)
Sally
J.
Campbell
and
Bruce
R.
Kelpsas
3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

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

8.

OMB
Control
#
2060­
0482
Tree
Planters'
Notes
v.
39
(
1988)
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
USDA
Forest
Service
Bend
Nursery,
Bend,
Oregon
Metam­
sodium,
Dazomet
populations.
Pythium
was
more
sensitive
than
Fusarium,
showing
significant
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

this
consortium.
Bend
Pine
Nursery
(
no
longer
in
business)
was
a
"
high
desert"
nursery
which
grew
pines
for
harsh
sites
in
eastern
Oregon
and
Washington.
The
soils
were
sandy
For
EPA
Use
Only
ID#

and
rocky.
The
results
in
Bend
would
not
be
applicable
to
most
other
nurseries
in
reductions
at
postreatment
and
presow
times
in
all
treatments
compared
to
the
control.
The
metam­
sodium
treatment
produced
the
highest
density
of
seedlings.
Only
methyl
bromide­
chloropicrin
produced
a
significant
reduction
in
Fusarium
Worksheet
Title
3­
A
Alternatives
­
Technical
Feasibility
This
form
is
used
to
obtain
information
on
the
chemical
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
that
are
registered
for
use
in
the
United
States,
as
well
as
the
non­
chemical
alternatives
identified
by
the
MBTOC.
Applicants
must
address
the
technical
feasibility
of
all
the
chemical
and
non­
chemical
alternatives
identified
on
the
list.

3­
B
Alternatives
­
Pest
Control
Regimen
Costs
This
form
is
used
to
estimate
the
cost
of
using
alternative
pest
control
regimens.

3­
C
Alternatives
­
Crop/

Commodity
Yield
and
Gross
Revenue
This
form
is
used
to
estimate
the
crop/
commodity
yields
and
gross
revenues
when
using
alternative
pest
control
regimens.

3­
D
Alternatives
­
Changes
in
Other
Costs
This
form
is
used
to
estimate
change
in
any
other
costs
as
a
result
of
using
the
alternatives.

Complete
each
of
the
worksheets
below
(
3­
A,
3­
B,
3­
C,
and
3­
D)
for
each
alternative
pest
control
regimen
listed
in
the
"
U.
S.
Matrix"
for
chemical
controls
(
www.
epa.
gov/
ozone/
mbr/
cueqa.
html)
and
the
"
International
Matrix"
for
non­
chemical
pest
controls
(
www.
epa.
gov/
ozone/
mbr/
cue).
Each
worksheet
contains
a
place
holder
in
the
title
for
you
to
insert
the
name
of
the
specific
alternative
pest
control
regimen
addressed.
You
should
add
additional
worksheets
as
required.
Please
add
a
number
designation
to
each
worksheet
title
to
indicate
a
different
alternative.
For
example,
for
the
first
alternative
pest
control
regimen
label
the
worksheets
as
3­
A(
1),
3­
B(
1),
3­
C(
1),
and
3­
D(
1).
For
the
second
alternative
pest
control
regimen
label
the
worksheets
3­
A(
2),
3­
B(
2),
3­
C(
2),
and
3­(
D)(
2).

Purpose
of
Data
on
Alternative
Pest
Control
Regimens:
To
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available.
EPA
needs
to
compare
data
(
yields,
crop/
commodity
prices,
gross
revenues
and
costs)
on
the
use
of
methyl
bromide
and
alternative
pest
control
regimens.

Worksheet
3.
Alternatives
­
Feasibility
of
Alternative
Pest
Control
Regimens
Enter
all
alternative
pesticides
and
pest
control
methods
(
and
associated
cost
and
yield
data)
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
fumigation
cycle
worksheet
for
a
comprehensive
definition.
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
x
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

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

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
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).

When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

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
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.

BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
alternative
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
1996.

There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
rates,
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
of
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websites
for
studies
that
pertain
to
your
crop
and
geographic
area.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.

[
Insert
Alternative]
[
Insert
Study
Title]

If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
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.
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
study?
Yes
X
No
7.

was
lower
in
MBC­
treated
areas.

8.

OMB
Control
#
2060­
0482
The
clay
content
at
the
nursery
is
much
higher
than
at
most
other
nurseries,
so
results
would
differ
throughout
the
region.
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
Results
from
Lucky
Peak
would
be
somewhat
applicable
to
nurseries
in
colder
zones.
Dazomet
was
not
as
effective
as
MBC,
possibly
due
to
the
high
clay
soils
of
the
Density
of
both
tree
crops
was
comparable
between
MBC
and
fallow
treatments.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Fallowing
fields
for
at
least
one
year
prior
to
sowing
was
as
effective
as
dazomet
Dazomet,
Fallow
USDA
Forest
Health
Protection
Report
99­
9,
June
1999
USDA
Lucky
Peak
Nursery,
Boise,
Idaho
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
R.
L.
James
and
K.
Beall
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
Fusarium
Pythium
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
1
Methyl­
bromide­
chlorop.
350
lbs/
ac
pre­
trt
1126
2
wks
22
presow
0
pre­
trt
98
2
wks
0
presow
2
1,352
2
Metam­
sodium
109
gal/
ac
pre­
trt
554
2
wks
483
presow
616
pre­
trt
63
2
wks
3
presow
31
1,760
3
Dazomet
350
lbs/
ac
pre­
trt
543
2
wks
615
presow
332
pre­
trt
73
2
wks
2
presow
34
2,042
4
control
­­­
pre­
trt
843
2
wks
1160
presow
311
pre­
trt
85
2
wks
29
presow
85
2,257
Comments:
Ratings
are
propagules
per
gram
of
ovendry
soil
Yield
is
mm3
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)

Dazomet,
Metam
Sodium
Comparison
of
Three
Soil
Fumigants
in
a
Bareroot
Conifer
Nursery
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
x
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

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

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
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).

When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

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
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.

BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
alternative
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
1996.

There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
rates,
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
of
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websites
for
studies
that
pertain
to
your
crop
and
geographic
area.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.

[
Insert
Alternative]
[
Insert
Study
Title]

If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
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.
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
study?
Yes
X
No
7.

was
lower
in
MBC­
treated
areas.

8.

OMB
Control
#
2060­
0482
The
clay
content
at
the
nursery
is
much
higher
than
at
most
other
nurseries,
so
results
would
differ
throughout
the
region.
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
Results
from
Lucky
Peak
would
be
somewhat
applicable
to
nurseries
in
colder
zones.
Dazomet
was
not
as
effective
as
MBC,
possibly
due
to
the
high
clay
soils
of
the
Density
of
both
tree
crops
was
comparable
between
MBC
and
fallow
treatments.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Fallowing
fields
for
at
least
one
year
prior
to
sowing
was
as
effective
as
dazomet
Dazomet,
Fallow
USDA
Forest
Health
Protection
Report
99­
9,
June
1999
USDA
Lucky
Peak
Nursery,
Boise,
Idaho
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
R.
L.
James
and
K.
Beall
Alternative:
Study:
Conifer
Seedling
Production
­
USDA
FS
Lucky
Peak
Nursery,
Boise,
Idaho
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
T/
R
ratio
Pythium
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interva
l
3
Ratin
g
for
Interv
al
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Ponderosa
pine
1
dazomet
350
lbs/
ac
pre­
trt
2.1
9
mos.
8.7
pre­
trt
3
9
mos.
1
151
2
MBC
*
pre­
trt
4.8
9
mos.
125.4
pre­
trt
0
9
mos.
0
204
3
Fallow
­­
pre­
trt
6.6
9
mos.
19.7
pre­
trt
2
9
mos.
0
204
Lodgepole
pine
1
dazomet
350
lbs/
ac
pre­
trt
21.6
9
mos.
4.9
pre­
trt
53
9
mos.
4
183
2
MBC
*
pre­
trt
8.3
9
mos.
86.2
pre­
trt
153
9
mos.
8
215
3
Fallow
­­
pre­
trt
6.3
9
mos.
7.1
pre­
trt
190
9
mos.
150
204
Comments:
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/
area)

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.).

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.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
For
EPA
Use
Only
Research
Summary
Dazomet,
Fallowing
An
Evaluation
of
the
Effects
of
Dazomet
on
Soil­
Borne
Diseases
and
*
see
Stone
et
al.
1997
for
rate
applied
Rating
for
Pest
1
is
the
ratio
of
Trichoderma
to
Fusarium
populations
(
colony­
forming
units
per
gram
of
oven­
dried
soil)

Rating
for
Pest
2
is
cfu/
gram
of
oven­
dried
soil.
Yield
is
no.
seedlings/
m2.

OMB
Control
#
2060­
0482
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
x
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

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

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
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).

When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

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
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.

BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
alternative
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
1996.

There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
rates,
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
of
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websites
for
studies
that
pertain
to
your
crop
and
geographic
area.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.

[
Insert
Alternative]
[
Insert
Study
Title]

If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
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.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
Assoc.
Aug.
14­
16,
1984
4.
Location
of
research
study
5.

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

8.

OMB
Control
#
2060­
0482
this
consortium.
The
results
from
Stone
nursery
would
be
applicable.
pines
for
harsh
sites
in
eastern
Oregon
and
Washington.
The
soils
were
sandy
and
rocky.
The
results
in
Bend
would
not
be
applicable
to
most
other
nurseries
in
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
Bend
Pine
Nursery
(
no
longer
in
business)
was
a
"
high
desert"
nursery
which
grew
(
at
Bend)
and
6.5
weeks
(
J.
H.
Stone).
Solarization
produced
no
significant
reductions
in
Pythium
populations.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Fusarium
propagules
were
reduced
significantly
by
solarization
after
4
weeks
solarization
Proceedings:
Western
For.
Nur.
Council­
Intermountain
Nurseryman's
J.
Herbert
Stone
and
Bend
Forest
Service
Nurseries
in
Oregon
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
Sally
J.
Cooley
Alternative:
Study:

Col.
A:

Treat
ment
Numb
er
Col.
B:

Treat
ment
Col.
C:

Rate
Col.
D,

F,
H,

J,
L,

N:
Interv
al
Cols.

E,
G,
I,

K,
M,

O:
Rating
for
Interv
al:
Contr
ol
of
Pests
1
and
2
(
Cols.

D
­
I
and
Cols.

J
­
O):
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.).

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

List
what
type
of
pest
control
method
was
used.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
For
EPA
Use
Only
Research
Summary
Solarization
Solarization
in
Two
Pacific
Northwest
Forest
Nurseries
Col.
J:

Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Fusarium
Pythium
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
Stone
Nurs
0­
6"

1
control
­­
pre­
trt
2320
6.5
wks
3400
pre­
trt
180
6.5
wks
136
16
2
solarization
6.5
wks
pre­
trt
2640
6.5
wks
920
pre­
trt
184
6.5
wks
144
17
3
MBR
350
lbs/
ac
pre­
trt
2680
6.5
wks
0
pre­
trt
194
6.5
wks
0
23
6­
12"

4
control
­­
pre­
trt
1880
6.5
wks
2760
pre­
trt
188
6.5
wks
146
16
5
solarization
6.5
wks
pre­
trt
2040
6.5
wks
1120
pre­
trt
184
6.5
wks
128
17
6
MBR
350
lbs/
ac
pre­
trt
2600
6.5
wks
80
pre­
trt
208
6.5
wks
0
23
Comments:
Ratings
are
propagules/
gram
of
soil.
Yield
is
Trees/
ft2.

Similar
results
for
Fusarium
were
obtained
at
another
nursery
in
Bend,
Oregon
(
data
not
published).
Pythium
was
not
measured
at
this
other
site.

OMB
Control
#
2060­
0482
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/
area)
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
X
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
alternative
pest
control
regimens
for
various
crops,
which
can
be
found
at
http://
www.
epa.
gov/
ozone/
mbr
or
by
calling
1­
800­
296­
1996.

There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
application
rates,
application
intervals,
pest
pressure,
weather
conditions,
varieties
of
the
crop
used,
etc.
All
results
should
be
included,
regardless
of
outcome.
You
must
submit
copies
of
each
study
to
EPA
unless
they
are
listed
on
the
Agency
website.
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
other
websites
for
studies
that
pertain
to
your
crop
and
geographic
area.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

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
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
of
relevant
treatments
should
be
provided
for
each
study
reviewed.

BACKGROUND
For
EPA
Use
Only
ID#

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
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

Alternatives
to
Methyl
Bromide
for
control
of
Soil­
borne
Diseases
in
Bare
Root
Nurseries
3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

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

8.

OMB
Control
#
2060­
0482
this
consortium.
In
the
1993
trial,
seedling
diameter
and
shoot
height
was
significantly
greater
in
the
MBR
treatment
than
the
bare
fallow
treatments,
but
was
not
significant
in
1995.

Average
preplant
levels
of
Fusarium
were
not
significantly
different
between
the
bare
pines
for
harsh
sites
in
eastern
Oregon
and
Washington.
The
soils
were
sandy
and
rocky.
The
results
in
Bend
would
not
be
applicable
to
most
other
nurseries
in
fallow
treatments
and
the
fumigated
treatment.
Pea
plant
cover
exacerbated
disease.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?

Bend
Pine
Nursery
(
no
longer
in
business)
was
a
"
high
desert"
nursery
which
grew
fumigated
and
the
bare
fallow
treatments.
The
pea
cover
crop
without
fumigation
resulted
in
significantly
lower
densities
and
significantly
higher
mortality
in
both
trials.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Average
seedling
densities
and
mortality
were
not
significantly
different
between
the
Pea
cover
crop
&
MBC,
Bare
Fallow
with
Tillage,
Bare
Fallow
with
no
Till
Pea
cover
crop
&
no
fumigation
FID
Tech
Rep.
R6­
06­
02,
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
Bend
Pine
Nursery,
Bend,
Oreogn
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Jeffrey
K.
Stone,
Diane
M.
Hildebrand,
Robert
L.
James,
Susan
M.
Frankel
David
S.
Germandt
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
Alternative:
Study:
in
Bare
Root
Forest
Nurseries
Col.

A:
Treat
ment
Numb
er
Col.

B:
Treat
ment
Col.

C:
Rate
Col.
D,

F,
H,

J,
L,

N:
Interv
al
Cols.

E,
G,
I,

K,
M,

O:
Rating
for
Interv
al:
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.

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,

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

List
what
type
of
pest
control
method
was
used.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
For
EPA
Use
Only
Research
Pea
cover,
bare
fallow,
tillage,
MBC
Alternatives
to
Methyl
Bromide
for
control
of
Soil­
Borne
Diseases
Contr
ol
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
Fusarium
Pythium
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Inte
rval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
1
Peas.
MBC
350lbs/
ac
pre­
sow
170
pre­
sow
1.6
21
2
BF+
Tillage
­­
pre­
sow
618
pre­
sow
14.2
22
3
BF­
no
till
­­
pre­
sow
948
pre­
sow
17.6
22
4
Peas,
no
Fum
­­
pre­
sow
3711
pre­
sow
157.7
7
Comments:
BF=
Bare
fallow
June­
Sept.
Tillage=
every
3
weeks
Rating
is
colony­
forming
units
per
gram
dry
weight
of
soil.

Density
is
2+
0
seedlings
per
sq.
meter
Aged
pine
sawdust
and
amendments
of
NH4NO3
were
added
to
all
treatments
OMB
Control
#
2060­
0482
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
Trtmnt
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)
Yield
(
units/
are
a)

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.).
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
x
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
Alternatives
to
Methyl
Bromide
for
control
of
Soil­
borne
Diseases
in
Bare
Root
Nurserie
4.
Location
of
research
study
5.

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

till
treatments
had
similar
mortalities
in
1995
and
were
not
significantly
different
from
one
another.
The
lowest
moralities
in
the
1995
trial
were
found
in
the
bare
fallow
with
tillage
and
the
sawdust,
bare
fallow­
till,
delayed
nitrogen
treatment.
Higher
weeds
were
noted
in
bare
fallow
without
tillage
in
1993.
FID
Tech
Rep.
R6­
06­
02,
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
y
yy
without
Bare
fallow
without
tillage
also
produced
shorter
seedlings
in
1993,
but
not
1995,
compared
to
all
other
g
g
p
g
p
pg
of
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
g
g
year.
sawdust
soil
amendment,
ammonium
nitrate,
bare
fallow,
tillage,
Dazomet,
no­
tillage
David
S.
Germandt
J.
Herbert
Stone
Nursery,
Oregon
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
2
papers
Jeffrey
K.
Stone,
Diane
M.
Hildebrand,
Robert
L.
James,
Susan
M.
Frankel
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
[
Insert
Alternative]
[
Insert
Study
Title]

If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
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
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed
.
Please
number
8.

OMB
Control
#
2060­
0482
Northwest.
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
Results
from
Stone
nursery
would
possibly
apply
to
most
nurseries
in
the
Pacific
Alternative:
Study:

delayed
nitrogen,
nitrogen,
dazomet
in
Bare
Root
Forest
Nurseries
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
Fusarium
Pythium
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
ponderosa
pine
1
S+
N,
BFT,
Dazomet
350
lb/
ac
1993­
95
135
1995­
98
866
1993­
95
19
1995­
98
4
165
2
S+
N,
BFT
250
m3/
ha
(
S)
1993­
95
2194
1995­
98
7988
1993­
95
22
1995­
98
60
164
3
S+
N,
BF
300
lb/
ac
(
N)
1993­
95
3469
1995­
98
4796
1993­
95
82
1995­
98
45
168
4
BFT
every
3
wks
1993­
95
1106
1995­
98
4303
1993­
95
56
1995­
98
46
145
5
S,
BFT,
delayed
nitrogen
1993­
95
808
1995­
98
2653
1993­
95
67
1995­
98
46
169
Comments:
Ratings
are
colony­
forming
units
per
gram
dry
weight
of
soil
BF=
bare
fallow,
T=
with
tilling,
S=
sawdust
soil
amendment,
N=
ammonium
nitrate
Yield
is
2+
0
seedlings
per
m2
OMB
Control
#
2060­
0482
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/
area)

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.).

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
commodity
being
treated,
or
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
sawdust+
ammonium,
bare
fallow
with
till,
bare
fallow
(
no­
till)
Alternatives
to
Methyl
Bromide
for
control
of
Soil­
Borne
Diseases
Use
additional
pages
as
needed.

Alternative:
bare
fallow
tillage,
dazomet
Study:
Alternatives
to
methyl
bromide
for
control
of
soil­
borne
bark
compost,
sludge
diseases
in
bare
root
forest
nurseries
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
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
4.
Location
of
research
study
5.

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

8.
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
amendments
produced
the
shortest
seedlings
and
the
lowest
diameters,
while
dazomet
treatment
still
had
greater
height
than
the
bare
fallow
without
amendment
treatment.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Seedling
densities
were
not
significantly
affected
by
any
treatment.
Bark
compost
and
sewage
sludge
bare
fallow
with
tillage,
dazomet,
bark
comost,
sludge
Hildebrand
et
al.
2002
FID
Tech.
Rep.
R6­
02­
02,
2002,

Coeur
d'Alene
Nursery,
Coeur
d'Alene,
Idaho
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
2
papers
Stone
et
al.
1995
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
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
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed
.
Please
number
OMB
Control
#
2060­
0482
nurseries,
as
well
as
areas
in
the
Pacific
Northwest.
Results
from
Coeur
d'Alene
nursery
would
be
applicable
to
most
northern
region
Alternative:
Study:
diseases
in
bare
root
for
nurseries.

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

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
preplant
Fusarium
preplant
Pythium
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
Douglas­
fir
1
bare
fallow
tillage,
Dazomet
350
lb/
ac
1993­
95
73
1995­
98
115
1993­
95
12
1995­
98
3
291
2
bare
fallow
tillage,
bark
compost
55
m3/
ha
1993­
95
217
1995­
98
338
1993­
95
26
1995­
98
35
319
3
bare
fallow
tillage
periodic
tilling
1993­
95
172
1995­
98
530
1993­
95
31
1995­
98
38
292
4
bare
fallow
tillage,
sludge
55
m3/
ha
1993­
95
2180
1995­
98
472
1993­
95
41
1995­
98
38
357
5
bare
fallow
tillage,
pine
mulch
periodic
tilling
1993­
95
1329
1995­
98
­­
1993­
95
­­
1995­
98
­­
­­

Comments:
Ratings
are
colony­
forming
units
per
gram
dry
weight
of
soil
Yield
is
2+
0
Seedlings
per
square
meter
in
1998
OMB
Control
#
2060­
0482
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/
area)

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
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
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
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
commodity
being
treated,
or
protected.
Ideally,
a
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
bare
fallow,
tillage,
dazomet,
bark
compost,
sludge
Alternatives
to
methyl
bromide
for
control
of
soil­
borne
Use
additional
pages
as
needed.

Alternative:
bare
fallow
tillage,
bare
fallow,
bare
fallow
&
compost,
Study:
Alternatives
to
methyl
bromide
for
control
of
so
bare
fallow
sawdust
nitrogen,
bare
fallow
&
MBC
diseases
in
bare­
root
forest
nurseries
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
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
1995
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
4.
Location
of
research
study
5.

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

8.
amendment
treatments.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
Seedling
diameters
were
smaller
in
the
mushroom
and
sawdust
treatments.
Seedling
height
were
significantly
greater
in
the
bare
fallow
and
MBC
treatments
than
soil
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Seedling
density
was
significantly
greater
for
the
bare
fallow
with
sawdust
treatment.
bare
fallow
tillage,
bare
fallow,
bare
fallow
+
compost
bare
fallow
+
sawdust
+
nitrogen,
bare
fallow
+
MBC
FID
Tech.
Rep.
R6­
02­
02
(
2002),

Lucky
Peak
Nursery,
near
Boise,
Idaho
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
Stone
et
al.
1995,
Hildebrand
et
al.
2002
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
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
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed
.
Please
number
OMB
Control
#
2060­
0482
The
clay
content
at
the
nursery
is
much
higher
than
at
most
other
nurseries,
so
results
would
differ
throughout
the
region.
Results
from
Lucky
Peak
would
be
somewhat
applicable
to
nurseries
in
colder
zones.
Alternative:
bare
fallow
till,
bare
fallow,
bare
fallow
+
compost,
Study:
Alternatives
to
Methyl
bromide
for
control
of
soil­
borne
bare
fallow
sawdust
+
nitrogen,
bare
fallow
+
MBC
diseases
in
bare
root
forest
nurseries
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
Preplant
Fusarium
Preplant
Pythium
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
Ponderosa
pine
1
bare
fallow
tillage
­­
1993­
95
496
1995­
98
376
1993­
95
25
1995­
98
21
340
2
bare
fallow
­­
1993­
95
241
1995­
98
488
1993­
95
38
1995­
98
29
284
3
bare
fallow
+
compost
42
m3/
ha
1993­
95
227
1995­
98
434
1993­
95
24
1995­
98
32
306
4
bare
fallow,
sawdust
+
nitrogen
*
1993­
95
214
1995­
98
341
1993­
95
21
1995­
98
27
372
5
bare
fallow
+
MBC
393
kg/
ha
1993­
95
80
1995­
98
65
1993­
95
7
1995­
98
4
343
Comments:
*
sawdust
containing
supplemental
nitrogen
at
42
m3/
ha,
with
ammonium
nitrate
fertilizer
added
at
92
kg/
ha
Ratings
are
colony­
forming
units
per
gram
dry
weight
of
soil
Yield
is
2+
0
seedlings
per
square
meter
in
1998
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.

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

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

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.

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.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
Provide
one
summary
table
for
each
study
being
described.
Use
additional
pages
as
needed.

Alternative:
bare
fallow
tillage,
bare
fallow,
bare
fallow
&
compost,
Study:
Alternatives
to
methyl
bromide
for
control
of
so
bare
fallow
sawdust
nitrogen,
bare
fallow
&
MBC
diseases
in
bare­
root
forest
nurseries
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
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
1995
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
4.
Location
of
research
study
5.

till,
hydromulch,
early
sow,
hydromulch;
7)
bare
fallow/
till,
bare
soil,
early
sow,
hydromulch
6.
Was
crop
yield
measured
in
the
study?
Yes
X
No
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
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed
.
Please
number
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Stone
et
al.
1995,
Hildebrand
et
al.
2002
FID
Tech.
Rep.
R6­
02­
02
(
2002),

Placerville
Nursery,
Placerville,
CA
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
1)
bare
fallow/
till,
rice
straw,
late
sow,
soil
cover;
2)
bare
fallow/
till,
rice
straw,
early
hydromulch;
3)
bare
fallow/
till,
sawdust,
early
sow,
hydromulch;
4)
bare
fallow/
till,
early
sow,
sawdust;
5)
bare
fallow/
till,
pine
needles,
early
sow,
hydromulch;
6)
bare
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Late
sowing
with
soil
covering
the
seed
resulted
in
significantly
lower
seedling
density
and
greater
mortality
caused
by
disease,
compared
to
treatments
with
sowing
seed
early
and
shallow,
with
a
non­
soil
mulch
covering
the
seed.
Seedling
root
volume,
and
height
were
not
significantly
different
after
one
growing
season.
8.

OMB
Control
#
2060­
0482
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
Results
from
Placerville
would
be
applicable
throughout
California
and
the
southwest.
Alternative:
bare
fallow
till,
bare
fallow,
bare
fallow
+
compost,
Study:
Alternatives
to
Methyl
bromide
for
control
of
soil­
borne
bare
fallow
sawdust
+
nitrogen,
bare
fallow
+
MBC
diseases
in
bare
root
forest
nurseries
Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

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
Preplant
Fusarium
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
Shasta
red
fir
1
BFT,
Rice
straw,
Late
sow,
Soil
cover
1993­
95
5285
19
2
BFT,
Rice
straw,
Early
sow,
Hydromulch
1993­
95
4460
30
3
BFT,
sawdust,
Early
sow,
Hydromulch
1993­
95
3821
27
4
BFT,
sawdust,
Early
sow,
sawdust
1993­
95
3244
28
5
BFT,
pine
needles,
Early
sow,
Hydromulch
1993­
95
4708
26
BFT,
Hydromulch,
Early
sow,
Hydromulch
1993­
95
5406
26
BFT,
Bare,
Early
sow,
Hydromulch
1993­
95
3233
24
Comments:
Ratings
are
colony­
forming
units
per
gram
dry
weight
of
soil
Yield
is
2+
0
seedlings
per
square
foot
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
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
commodity
being
treated,
or
protected.

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
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
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
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/
area)
Use
additional
pages
as
needed.

Alternative:
bare
fallow
tillage,
bare
fallow,
bare
fallow
&
compost,
Study:
Alternatives
to
methyl
bromide
for
control
of
so
bare
fallow
sawdust
nitrogen,
bare
fallow
&
MBC
diseases
in
bare­
root
forest
nurseries
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
x
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
1995
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
4.
Location
of
research
study
5.

late
sow,
soil;
7)
bare
fallow/
till,
vetch,
late
sow,
soil;
8)
bare
fallow/
till,
hydromulch,
late
sow,
soil
6.
Was
crop
yield
measured
in
the
study?
Yes
X
No
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
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed
.
Please
number
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
BACKGROUND
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Stone
et
al.
1995,
Hildebrand
et
al.
2002
FID
Tech.
Rep.
R6­
02­
02
(
2002),

Placerville
Nursery,
Placerville,
CA
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
1)
bare
fallow/
till,
sawdust,
early
sow,
sawdust
cover;
2)
bare
fallow/
till,
sawdust,
early
soil;
3)
bare
fallow/
till,
MBC,
Vetch,
late
sow,
sawdust;
4)
bare
fallow/
till,
vetch,
late
sawdust;
5)
bare
fallow/
till,
hydromulch,
late
sow,
sawdust;
6)
bare
fallow/
till,
MBC,

Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Vetch
cover
crop
treatments
resulted
in
crop
failure.
The
best
treatments
included
bare
fallow
with
tilling,
sawdust
mulch
over
the
winter,
early
sowing.
8.

OMB
Control
#
2060­
0482
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
Results
from
Placerville
would
be
applicable
throughout
California
and
the
southwest.
Alternative:
bare
fallow
till,
bare
fallow,
bare
fallow
+
compost,
Study:
Alternatives
to
Methyl
bromide
for
control
of
soil­
borne
bare
fallow
sawdust
+
nitrogen,
bare
fallow
+
MBC
diseases
in
bare
root
forest
nurseries
Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

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
Preplant
Fusarium
Preplant
Pythium
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
Shasta
red
fir
1
BFT,
sawdust,
Early
sow,
sawdust
1995­
98
3860
1995­
98
48.7
39.7
2
BFT,
sawdust,
Early
sow,
soil
1995­
98
2653
1995­
98
55
25.2
3
BFT,
MBC,
vetch,
late
sow,
sawdust
1995­
98
3806
1995­
98
71.4
17.9
4
BFT,
vetch,
late
sow,
sawdust
1995­
98
993
1995­
98
56.8
failure
5
BFT,
hydromulch,
late
sow,
sawdust
1995­
98
653
1995­
98
67
16.3
6
BFT,
MBC,
vetch,
late
sow,
soil
1995­
98
927
1995­
98
72
11.2
7
BFT,
vetch,
late
sow,
soil
1995­
98
690
1995­
98
71
failure
8
BFT,
hydromulch,
late
sow,
soil
1995­
98
5774
1995­
98
63.6
4.4
Comments:
Ratings
are
colony­
forming
units
per
gram
dry
weight
of
soil
Yield
is
2+
0
seedlings
per
square
foot
OMB
Control
#
2060­
0482
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
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
commodity
being
treated,
or
protected.

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
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
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
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/
area)
Use
additional
pages
as
needed.

Alternative:
bare
fallow
tillage
(
BFT),
BFT
&
compost,
BFT
&
hydromulch
Study:
Alternatives
to
methyl
bromide
for
control
of
so
BFT
&
MBC,
BFT
&
Dazomet
diseases
in
bare­
root
forest
nurseries
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
x
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
1995
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
4.
Location
of
research
study
5.

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

resulted
in
2
seedlings
per
square
foot
more
than
the
bare
fallow
with
tilling
with
or
without
composted
reddwood
chip
mulch.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Seedling
density,
root
volume,
and
height
did
not
vary
significantly
among
treatments.
Trends
in
the
data
indicate
that
bare
fallow
with
tilling
and
hydromulch
treatment
4)
bare
fallow/
till
&
MBC;
5)
bare
fallow/
till
&
dazomet
Humboldt
Nursery,
near
McKinleyville,
California
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
1)
bare
fallow/
till;
2)
bare
fallow/
till
&
compost;
3)
bare
fallow/
till
&
hydromulch
Stone
et
al.
1995,
Hildebrand
et
al.
2002
FID
Tech.
Rep.
R6­
02­
02
(
2002),
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
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
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed
.
Please
number
8.

OMB
Control
#
2060­
0482
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
Results
from
Humboldt
would
be
applicable
throughout
California
and
to
coastal
nurseries.
Alternative:
bare
fallow/
till
(
BFT),
BFT
+
compost,
,
BFT
+
hydromulch
Study:
Alternatives
to
Methyl
bromide
for
control
of
soil­
borne
BFT
+
MBC,
BFT
+
Dazomet
diseases
in
bare
root
forest
nurseries
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
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
Shasta
red
fir
1
BFT
1993­
95
19.3
2
BFT,
compost
1993­
95
19.6
3
BFT,
hydromulch
1993­
95
21.6
4
BFT,
MBC
1993­
95
20.1
5
BFT,
Dazomet
1993­
95
20.1
Comments:
Yield
is
1+
0
seedlings
per
square
foot
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.

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

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

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
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.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
Provide
one
summary
table
for
each
study
being
described.
Use
additional
pages
as
needed.

Alternative:
bare
fallow
+
herbicide,
bare
fallow/
till
(
BFT)
+
phosphate,
buffer
Study:
Alternatives
to
methyl
bromide
for
control
bare
fallow,
BFT
+
MBC,
BFT
+
biocontrol
of
soil­
borne
diseases
in
bare­
root
forest
nurseries
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
x
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
X
No
X
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
1995
www.
epa.
gov/
spdpublc/
mbr/
airc/
1995/
077.
pdf
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
X
No
7.
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Stone
et
al.
1995,
Hildebrand
et
al.
2002
For
EPA
Use
Only
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
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
relevant
BACKGROUND
the
treatment
with
MBC
fumigation
(
significant
p
<
0.05).
Although
not
significant,
the
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Bare
fallow
with
tilling
and
bare
fallow
with
phosphate
buffer
resulted
in
less
height
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
1)
bare
fallow
+
herbicide;
2)
bare
fallow/
till
&
phosphate;
3)
buffer
4)
bare
fallow;
5)
BFT
+
MBC;
6)
BFT
+
biocontrol
FID
Tech.
Rep.
R6­
02­
02
(
2002),

Humboldt
Nursery,
near
McKinleyville,
California
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
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
conducted
in
a
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
species
did
not
correlate
with
seedling
density.
8.

OMB
Control
#
2060­
0482
nurseries.
possibly
due
to
a
density
effect.
Pre
sow
population
leves
of
Pythium
and
Fusarium
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
Results
from
Humboldt
would
be
applicable
throughout
California
and
to
coastal
MBC
fumigation
treatment
had
the
lowest
density
compared
to
the
other
treatments,
Alternative:
bare
fallow+
herbicide,
bare
fallow/
till
(
BFT)
+
phosphate
buffer
Study:
Alternatives
to
Methyl
bromide
for
control
of
soil­
borne
bare
fallow,
BFT+
MBC,
BFT+
biocontrol
diseases
in
bare
root
forest
nurseries
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
Preplant
Fusarium
Preplant
Pythium
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
Shasta
red
fir
1
BFT
+
herbicide
1995­
98
1330
1995­
98
286
7.2
2
BFT
+
phosphate
buffer
1995­
98
1430
1995­
98
272
6.6
3
BF
1995­
98
1300
1995­
98
232
6.9
4
BFT
MBC
1995­
98
0
1995­
98
3
5.2
5
BFT
biocontrol
1995­
98
1330
1995­
98
323
7.3
Comments:
Ratings
are
colony­
forming
units
per
gram
dry
weight
of
soil
Yield
is
2+
0
seedlings
per
square
foot
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.

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

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

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
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.

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
Research
Summary
Table
Provide
one
summary
table
for
each
study
being
described.
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)

Basamid
weeds/
fungi
MITC
67%
350/
ac
258
lb
$
5.00
$
125/
ac
1
$
1875/
ac
$
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
Pests
Description
Cost/
area
$
1875/
ac
Total
$
0.00
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
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
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Basamid
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
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
pesticides
that
replace
methyl
bromide
for
the
entire
interval.
Do
not
include
pesticides
that
are
used
along
with
methyl
bromide­­
enter
only
the
additional
pest
control
if
methyl
bromide
were
not
available.

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.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
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
the
same
product.

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.
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
metam­
sodium
weeds/
fungi
MITC
42%
464
lbs
109
gallons
$
6.25/
gal
$
75.00
$
960.00
1
$
1,716.25
(
vapam
sectagon)

Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
1,716.25
Comments:

Metam
sodium
needs
to
be
tarped
because
of
the
sensitivity
of
some
conifer
species
to
drift
and
MITC.
Pines
are
especially
sensitive.
Chloropicrin
must
also
be
added
because
metam
will
not
diffuse
readily
through
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
regardin
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:
Metam­
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)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)

Conifer
seedlings
Species/
age/
size
1000
trees
344
$
220.00
$
75,680.00
Conifer
transplants
Species/
size
1000
trees
172
$
370.00
$
63,640.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
$
2.41
million
Comments:
Gross
Revenue
fo
Alternatives
The
same
"
representative
user"
was
used
in
Worksheet
3­
C
as
defined
in
Worksheet
2­
C
in
terms
of
annual
crop
production
and
area.
Since
both
methyl
bromide
alternatives
provide
the
same
results
in
our
research
trials,
the
estimation
of
gross
revenue
for
a
representative
user
is
the
same
for
both
compounds.

It
is
essential
to
consider
indirect
effects
to
accurately
assess
the
impact
of
the
loss
of
methyl
bromide.

OMB
Control
#
2060­
0482
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.

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.

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

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternativ
Basamid
and
Metam
Sodium
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
section
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.
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
Total
Cost
per
Area
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Custom
per
Area
$
0.00
User
Total
per
area
$
0.00
Comments:
Alternatives:
Changes
in
Other
Costs
for
Alternative
There
are
significant
indirect
costs
associated
with
the
loss
of
methyl
bromide
fumigation
in
forest
tree
nurseries.
Although
most
nurseries
in
the
West
only
use
methyl
bromide
in
areas
where
the
alternatives
are
unsuitable
(
i.
e.
increased
risk
of
crop
damage,
lack
of
suitable
weed
control,
etc.),
there
is
not
currently
a
viable
substitute
for
methyl
bromide
fumigation
in
these
situations.
The
"
market
disruption"
to
the
forest
tree
nursery
business
will
not
occur
from
the
increase
in
the
cost
of
soil
fumigation,
but
as
a
result
of
a
decrease
in
planting
stock
quality
and
an
increase
in
planting
stock
price.
The
most
serious
consequences
will
not
be
the
direct
effect
of
using
a
more
expensive
or
less
effective
fumigation
alternative,
but
rather
the
long­
term
effect
on
the
reforestation
program
in
the
Western
United
States.

The
loss
of
methyl
bromide
in
areas
where
alternatives
are
unsuitable
will
cause
a
decrease
in
seedling
numbers
per
unit
of
area,
a
decrease
in
average
seedling
size,

and
an
increase
in
weed
control
costs.

The
cost
of
a
reduction
in
seedling
production
per
unit
of
area.

The
bed
density
of
bareroot
conifer
seedlings
is,
on
average,
344,250
per
acre.
For
conifer
transplants,
the
bed
density
is,
on
average
172,125
per
acre.
At
$
220/
1000
seedlings
and
$
370/
1000
transplants,
this
is
a
value
of
$
68,850
and
$
60,246
respectively
per
bed
acre.
By
increasing
the
number
of
saleable
seedlings
or
transplants
by
only
1
per
square
foot
of
bed
space,
the
value
of
the
bed
acre
increases
by
$
9580
for
seedlings
and
$
16100
for
transplants.
This
is
substantially
more
than
the
cost
of
fumigation.

The
cost
of
a
decrease
in
average
seedling
size
It
has
been
established
that
larger
seedling
sizes
translate
into
increase
survival
and
growth
during
reforestation.
Research
around
the
country
has
shown
that
fumigation
can
significantly
increase
the
production
of
higher
grade
seedlings
in
the
nursery.
When
the
effect
of
fumigation
is
multiplied
over
the
number
of
seedlings
produced
and
the
number
of
acres
planted
annually
in
the
Western
United
States,
the
indirect
effect
of
nursery
fumigatoin
becomes
quite
significant.

The
cost
of
increased
weed
competition
Methyl
bromide
fumigation
provides
cost
effective
control
of
many
noxious
weed
species,
including
nutsedge
(
Cyperus
spp.)
and
its
loss
will
result
in
an
increase
in
herbicide
use
and/
or
an
increase
in
handweeding.
Although
cost
effective
herbicides
are
available
for
forest
tree
nurseries,
they
are
not
effective
against
all
weeds.

The
increase
in
weeding
costs
will
be
sufficient
to
result
in
higher
seedling
prices
for
conifer
species.

Summary
The
loss
of
methyl
bromide
fumigation
in
forest
tree
nurseries
will
have
significant
large
scale
disruptions
that
go
well
beyond
the
nursery.
While
direct
effects
on
seedling
production,
seedling
quality,
and
seedling
cost
may
in
fact
be
documented,
the
true
market
disruption
is
the
indirect
effect
on
plantation
establishment
and
growth
over
the
all
the
reforested
acres
each
year.

OMB
Control
#
2060­
0482
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.
Typical
Equipment
Used
Operation
Done
by
User
[
Insert
name
of
alternative]

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
.
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
X
No
7.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
Will
crop
yield
be
measured
in
the
study?
Various
studies
USDA
Forest
Service
and
State
nursery
cooperators
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.)
Various
nurseries
throughout
the
region
2002
and
continuing
Continue
to
test
basamid,
metam
sodium,
and
organic
amendments/
cover
crops/
sowing
alternatives
1.

1a.
Check
all
methods
you
will
use
Nothing
X
Tarpaulin
(
high
density
polyethylene)
X
Virtually
impermeable
film
(
VIF)
X
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
25­
50
acres
50­
100
acres
100­
200
acres
200­
400
acres
over
400
acres
no
cum.
data
3
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.

Pursuit
of
suitable
weed
control
methods
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Fallow,
organic
amendments,
various
seedbed
coverings
Do
you
have
access
to
recycled
methyl
bromide?
Basamid,
oxyflorfen,
chlorothalonil,
dursban,
and
a
variety
of
herbicides/
fungicides
Effectiveness
of
alternatives
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)?
Worksheet
5.
Additional
Information
For
EPA
Use
Only
ID#

1
Timing
of
sowing,
depth
of
sowing
3
1
2
Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
on
January
1,
2005?
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.
1
40,001
­
80,000
sq.
ft.
1
80,001
­
160,000
sq.
ft.
8
over
160,000
sq.
ft.

I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.

Signature
Date
Print
Name
Title
Signature
Date
Print
Name
Title
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
phaseout.
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.
For
EPA
Use
Only
ID#

9/
6/
2002
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.
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)

/
s/
Lee
E.
Riley
Lee
E.
Riley
Project
Leader
/
s/
Lee
E.
Riley
9/
6/
2002
Lee
E.
Riley
Project
Leader
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
45000
5.
Area
Treated
with
Methyl
Bromide
2005
150
acres
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

2006
45000
lbs.
Area
Treated
150
acres
units
2007
45000
lbs.
Area
Treated
150
acres
units
Not
Technically
Feasible
Not
Economically
Feasible
x
x
x
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.

Metam
sodium
Organic
amendments
Potential
Alternatives
Basamid
Basamid
is
both
technically
and
economically
feasible
only
in
certain
situations.
It
can
be
detrimental
to
certain
crops
(
particularly
5­

needle
pines)
and
does
not
provide
effective
weed
control.
Reasons
Metam
sodium
has
not
been
tested
on
a
large
enough
scale
to
use
it
in
production.
It
can
also
be
detrimental
to
certain
crops,

particularly
pines.

Organic
amendments
have
been
proven
to
work
in
small
situations,
but
not
on
a
large
scale,
and
have
not
been
shown
to
be
effective
against
many
fungal
diseases.
They
do
not
provide
an
effective
control
for
noxious
weeds.

Forest
Tree
Seedlings
Name
of
Applicant:

Location:

Crop:
Western
Forest
and
Conservation
Public
Nursery
Association
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.
Fumigation
cycle:

Year:
Comparable
data:

2­
year
example:

Other
beneficiary
example
Crop
cycle
change
example:
If
a
methyl
bromide
fumigation
is
made
every
2
years,
then
the
2001
fumigation
cycle
began
in
2001
and
would
end
in
2003.
The
data
should
cover
the
methyl
bromide
costs
and
usage
for
the
methyl
bromide
fumigation
made
in
2001,
and
all
yields
and
revenues
received
and
other
costs
incurred
during
the
2
year
period.
To
be
comparable,
the
data
on
alternatives
should
cover
a
similar
2
year
period
beginning
in
2005
beginning
at
the
same
time
of
year
when
a
methyl
bromide
fumigation
would
be
made.
The
data
should
cover
all
methyl
bromide
alternatives
used,
and
all
yields
and
revenues
received
during
that
2­
year
interval.
Other
pest
control
and
other
costs
would
only
need
to
be
provided
for
that
interval
if
they
would
change
from
what
they
were
with
methyl
bromide.

If
someone
other
than
the
applicant
benefits
from
a
methyl
bromide
fumigation,
you
should
comment
on
these
benefits
if
you
do
not
have
quantitative
data
for
the
entire
fumigation
cycle.
For
example,
if
a
rotational
crop
in
the
second
year
benefits
from
a
methyl
bromide
fumigation
a
year
earlier,
but
there
is
quantitative
data
only
on
the
first
crop,
then
the
data
on
the
alternatives
should
cover
only
the
first
crop,
and
the
benefits
of
methyl
bromide
and
the
additional
pesticides
that
would
have
to
be
used
on
the
rotational
crop
should
be
discussed
in
the
comments
sections.

If
in
a
one
year
interval,
methyl
bromide
is
applied,
tomatoes
are
grown
and
harvested
followed
by
peppers,
then
the
fumigation
cycle
would
be
one
year
including
the
tomatoes
and
peppers.
If,

however,
without
methyl
bromide,
it
is
not
possible
to
follow
tomatoes
with
peppers
in
the
same
one
year
interval,
then
the
alternative
data
on
pesticides,
costs,
yields,
and
revenues
should
just
cover
tomatoes.
The
loss
of
profit
from
not
being
able
to
grow
peppers
with
the
alternatives
would
be
part
of
the
loss
from
not
having
methyl
bromide.

Fumigation
Cycle
Definitions:

In
order
to
compare
revenues
and
costs
with
and
without
methyl
bromide,
data
on
alternatives
for
pest
control,
yields,
revenues,
and
costs
must
be
for
the
same
time
interval
as
the
methyl
bromide
fumigation
cycle.
If,
however,
quantitative
data,
is
not
available
for
the
entire
fumigation
cycle,

then
to
be
comparable,
the
quantitative
data
for
the
alternatives
should
cover
the
same
portion
of
the
fumigation
cycle
as
the
quantitative
data
for
methyl
bromide,
and
the
rest
of
the
cycle
should
be
discussed
in
the
comments
sections.

If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
"
year"
refers
to
the
calendar
year
when
methyl
bromide
is
applied
(
or
the
beginning
of
the
cycle).

The
period
of
time
between
methyl
bromide
fumigations.
Appendix
1
Information
for
Worksheet
3­
A.

Several
studies
have
been
completed
in
the
western
states
in
addition
to
those
found
in
the
format
of
worksheet
3­
A
and
3­
B.
These
additional
studies
do
not
lend
themselves
to
the
format
as
presented.
In
addition,
several
of
the
studies
detailed
in
the
worksheets
have
been
published
in
various
Nursery
Proceedings
or
Internal
Memos
during
the
early
stages
of
data
collection.

Table
1.
Summary
of
alternatives
to
fumigation
studies.

Year
Location
(
s)
Treatments
Report
as
numbered
below
1990
One
nursery
in
OR
Fallow,
cover
crop,
MBC
5
1990
Three
nurseries
in
WA,
OR
Cover
crops
and
MC33
1
1993­
95
Six
nurseries
in
CA,
ID,
OR
Organic
amendments
and
Basamid
2
+
worksheets
3A
and
3B
1995­
98
Six
nurseries
in
CA,
ID,
OR
Organic
amendments
and
Basamid
worksheets
3A
and
3B
1999
One
nursery
in
ID
Basamid
4
2001
One
nursery
in
ID
Fallow,
soil
amendments,
MBC
3
1)
Hansen
EM,
Myrold
DD,
Hamm
PB.
1990.
Effects
of
soil
fumigation
and
cover
crops
on
potential
pathogens,
microbial
activity,
nitrogen
availability,
and
seedling
quality
in
conifer
nurseries.
Phytopathology
80(
8):
698­
704.

2)
Hildebrand
DM,
Stone
JK,
James
RL,
Frankel
SJ,
Pokorny
JD,
O'Brien
JG,
Cram
MM.
1995.
Alternatives
to
chemical
fumigation
technology
development
project:
Preliminary
results.
In:
Landis
TD,
Cregg
B,
technical
coordinators.
National
Proceedings:
Forest
and
Conservation
Nursery
Associations
­
1995.
Portland
(
OR):
USDA
Forest
Service,
Pacific
Northwest
Research
Station.
General
Technical
Report
PNW­
GTR­
365:
p
15­
22.

3)
James
RL.
2001.
Effects
of
pre­
sowing
soil
treatments
on
root
colonization
of
1­
0
ponderosa
and
lodgepole
pine
seedlings
by
potentially­
pathogenic
fungi,
USDA
Forest
Service
Lucky
Peak
Nursery,
Boise,
Idaho.
Plant
Health
Protection
Report
01­
9.
Missoula
(
MT):
USDA
Forest
Service,
Northern
Region.
9
p.

4)
James
RL,
Beall,
K.
1999.
An
evaluation
of
the
effects
of
dazomet
on
soil­
borne
diseases
and
conifer
seedling
production
 
USDA
Forest
Service
Lucky
Peak
Nursery,
Boise,
Idaho.
Plant
Health
Protection
Report
99­
9.
Missoula
(
MT):
USDA
Forest
Service,
Northern
Region.
15
p.

5)
Stone
JK,
Hansen
EM.
1993.
Green
manure
effects
on
soilborne
pathogens.
In:
Landis
TD,
technical
coordinator.
Proceedings:
Northeastern
and
Intermountain
Forest
and
Conservation
Nursery
Associations.
Fort
Collins
(
CO):
USDA
Forest
Service,
Rocky
Mountain
Forest
and
Range
Experiment
Station.
General
Technical
Report
RM­
243:
p
57­
64.
Summary
of
research
into
alternatives
to
methyl
bromide.
Methyl
bromide,
in
general,
seems
to
work
well
across
the
geographic
region
covered
by
this
consortium.
The
various
alternatives,
including
fallow,
tilling,
organic
amendments,
cover
crops,
Basamid,
and
metam
sodium,
varied
widely
in
efficacy
among
nurseries.
Basamid
appears
to
produce
the
best
results,
with
similar
yields
to
those
crops
grown
following
methyl
bromide
fumigation.
However,
weed
control
was
significantly
less
with
Basamid
than
methyl
bromide,
increasing
the
rates
of
herbicide
use
and/
or
hand
weeding.

Use
of
fallowing,
tilling,
organic
amendments,
and
cover
crops
appeared
to
show
mixed
results.
Each
treatment
depended
on
the
nursery
environment,
nursery
soils,
crop
type,
etc.
and
would
only
be
applicable
in
small
areas.
Use
of
any
of
these
treatments
on
a
production
basis
would
require
further
research
and
large
risk
to
crop
production.
