1.

2.

3.

4.

Light
33%
Medium
33%
Heavy
33%

0
to
2%
X
2
to
5
%
over
5%

5.

6.
Specialty
(
check
one)

7.
Glen
A.
Fischer
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.
Ventura,
CA
93007
glensaticoy@
moodydunbar.
com
805
933­
1523
Contact
name
Address
805
647­
5266
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).

California
Pepper
Commission
California
Peppers
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
7990
Holsclaw
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).

9b
PO
Box
4547
408
848­
6373
408
847­
3887
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Gilroy,
CA
gambler@
hotcity.
com
Mike
Chuck
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
400,000
lbs.

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

19.

20.

20a.

OMB
Control
#
2060­
0482
400,000
Unit
of
Area
Treated
Nematodes
Phytophthora
spp.

Verticillium
spp.

Rhizoctonia
spp.

Pythium
spp.
2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
400,000
Area
to
be
Treated
2500
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.

alternative
in
controlling
Phytophthora
and
Verticillium
pathogens.

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

Explain
why
this
user
represents
the
typical
user
in
the
consortium.
2500
This
represents
about
10%
of
total
California
production
that
has
no
viable
economic
or
technical
How
much
area
will
this
be
applied
to?
Please
list
units.
2500
For
EPA
Use
Only
ID#

Representative
user
leases
about
600
acres,
of
which
pepper
is
grown
on
200
acres;
other
crops
are
grown
on
remaining
acreage.

Source:
University
of
California
Cooperative
Extension.
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.

Year
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
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
Acres
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Acre
Total
Actual
Acres
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Acres
Total
Actual
Acre
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Acre
Total
Actual
Acres
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Acres
over
95%
methyl
bromide
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
60%
methyl
bromide,
40%
chloropicrin
1794.37
295159.61
164.492056
2134.67
403079.94
188.825411
3028.77
544962.62
179.928691
2458.41
376616.74
153.195252
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
164.492056
188.825411
179.928691
153.195252
Comments:
Source
­
Calif.
Pesticide
Use
Report
OMB
Control
#
2060­
0482
The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
area
are
automatically
calculated
from
the
previous
2
columns.
2000
Enter
the
total
actual
area
treated.
Note:
This
number
should
be
the
total
actual
area
treated
by
the
individual
user
or
total
actual
area
for
the
entire
consortium,
for
the
year
indicated.

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

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

1997
1998
1999
For
EPA
Use
Only
ID#

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

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

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

1997
Hundredweight
(
cwt.)
300
$
24.60
$
7,380.00
1998
Hundredweight
(
cwt.)
285
$
27.20
$
7,752.00
1999
Hundredweight
(
cwt.)
330
$
29.80
$
9,834.00
2000
Hundredweight
(
cwt.)
300
$
27.30
$
8,190.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
for
1997
$
7,380.00
Total
Revenue
for
1998
$
7,752.00
Total
Revenue
for
1999
$
9,834.00
Total
Revenue
for
2000
$
8,190.00
Average
Revenue
Per
Year
$
8,289.00
Comments:
Source
­
NASS
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.

Pepper
Pepper
Pepper
B
Pepper
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
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
acre)

Pepper
market,
grade
(
ave.)
Hundredweight
(
cwt.)
260
$
25.80
$
6,708.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
$
6,708.00
Comments:
NASS
(
est.)

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
Acre
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Acre
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Acre
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Acre
over
95%
methyl
bromide
$
0.00
75%
methyl
bromide,
25%
chloropicrin
$
0.00
67%
methyl
bromide,
33%
chloropicrin
$
0.00
50%
methyl
bromide,
50%
chloropicrin
$
0.00
60
methyl
bromide,
40%
chloropicrin
225
$
2.97
$
195.00
$
520.00
10%
$
1,383.25
__%
methyl
bromide,
__%
chloropicrin
$
0.00
$
0.00
All
formulations
of
methyl
bromide
$
1,383.25
Comments:
Total
cost
of
application
is
$
1938/
acre;
above
reflects
only
MeBr
costs,
not
chloropicrin.

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

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

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

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

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

For
EPA
Use
Only
ID#

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

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

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

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
Cultural
Costs
$
334.00
$
1,501.00
$
492.00
$
1,993.00
Harvest
Costs
$
1,200.00
$
996.00
$
1,506.00
$
2,502.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Custom
per
Area
$
1,534.00
User
Total
per
area
$
4,495.00
Source:
1997
University
of
California
Cooperative
Extension,
Sample
Costs
to
Produce
Bell
Peppers
(
San
Benito
and
Santa
Clara
Counties.

(
Adjusted
by
20%
for
increased
costs
since
1997)

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

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

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

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

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

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

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

Do
not
include
methyl
bromide
costs.

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

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

The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
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
Assessment
Curly
Top
Virus
$
0.27
per
ton
$
5.00
Assessment
California
Pepper
Commission
0.5
per
ton
$
9.00
Interest
Operation
Capital
10%
per
year
$
148.00
Cash
Overhead
Rent,
Office,
Insurance,
Taxes
Actual
Costs
$
518.00
Total
$
680.00
Comments:

Source:
1997
University
of
California
Cooperative
Extension,
Sample
Costs
to
Produce
Bell
Peppers
(
San
Benito
and
Santa
Clara
Counties.

(
Adjusted
by
20%
for
increased
costs
since
1997)

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.
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
1b.
Township
caps
X
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
X
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.

Buffer
zones
(
300
ft.)
limits
Telone
use
because
of
limited
land
available
for
production
and
urban
encroachment.
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
Industry
Knowledge
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.

1,3­
D
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)

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

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

8.

OMB
Control
#
2060­
0482
Industry
Knowledge
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.

Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
1,3­
D
is
effective
against
nematodes,
but
not
diseases
such
as
Phytophtora
and
Verticillium
and
NA
NA
1,3­
D
land
make
the
adoption
of
this
tool
extremely
limited.
Fusarium
wilts;
additional
chemicals
are
needed
to
control
these
targets.

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?

Note:
One
application
of
MeBr
can
last
several
years;
alternative
chemicals
must
be
applied
annually.
For
EPA
Use
Only
ID#

Township
caps
and
300
ft.
buffers
in
a
densely
populated
growing
area
with
limited
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
1b.
Township
caps
X
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
X
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Industry
Knowledge
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
pro
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,

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.

1,3­
D,
Chloropicrin
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
resear
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
applicati
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
othe
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
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
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
NA
No
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.

8.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

From
practical
experience
and
industry
knowledge,
the
concentration
of
Chloropicrin
in
premix
comibinations
of
1,3­
D
is
not
high
enough
to
provide
effective
control
against
plant
pathogens
in
this
growing
area
1,3­
D/
Chloropicrin
(
Inline,
Telone
C35).

when
used
at
maximum
label
rates.

NOTE:
One
application
of
MeBr
can
last
several
years,
alternative
chemicals
must
be
applied
annually.
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.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
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
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
resear
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
applicati
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
othe
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
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
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
pro
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,

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.

Chloropicrin
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Industry
Knowledge
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
NA
No
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
NA
No
7.

8.

OMB
Control
#
2060­
0482
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.
Industry
Knowledge
NA
Chloropicrin
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.
For
EPA
Use
Only
ID#

Chloropicrin
does
not
distribute
throughout
soil
profile
when
used
by
itself
(
without
MeBr),
resulting
in
reduced
efficacy.
It
does
not
adequately
control
Phytophthora
spp.
when
used
alone
according
to
label.
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
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Industry
Knowledge
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
resear
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
applicati
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
othe
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
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,

BACKGROUND
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.

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
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
pro
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
Metam
Sodium
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
NA
No
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
NA
No
7.

8.

OMB
Control
#
2060­
0482
Metam
Sodium
does
not
control
Phytopthora
or
Fusarium
and
Verticillium
wilts,
the
major
disease
problems
in
this
growing
region.

Results
are
very
erratic
and
plants
are
subject
to
phytotoxicity.
For
EPA
Use
Only
ID#

Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
NA
Metam
Sodium
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.
Industry
knowledge
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
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)
Metam
Sodium/
Crop
Rotation
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
resear
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
applicati
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
othe
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
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
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
pro
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,

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.
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Industry
Knowledge
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
NA
No
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
NA
No
7.

8.

OMB
Control
#
2060­
0482
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
Industry
Knowledge
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
in
soil.
This
is
not
economically
feasible.
NA
Metam
Sodium
/
Crop
Rotation
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.
For
EPA
Use
Only
ID#

Metam
sodium
results
in
erratic
control.
Due
to
high
land
costs,
there
are
not
many
crops
that
peppers
can
rotate
with
that
will
provide
an
economic
return.
A
four
or
five
year
rotation
is
necessary
to
adequately
reduce
inoculum
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
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Industry
Knowledge
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
pro
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.

Solarization/
Fungicides
Not
technically
feasible.
Temperatures
do
not
get
hot
enough
during
land
preparation
period
(
Feb­
April)

to
control
pathogens
in
the
soil.
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
resear
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
applicati
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
othe
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
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
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,

BACKGROUND
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
NA
No
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
NA
No
7.

8.

OMB
Control
#
2060­
0482
NA
NA
For
EPA
Use
Only
ID#

Not
technically
feasible.
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.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
NA
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
NA
NA
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)

Inline
Phytopthora
1,3­
D,
chloro.
10%
1
$
900.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
900.00
Comments:

Cost
includes
material,
plastic
mulch
and
extra
costs
due
to
hand
transplanting
(
can
not
perform
mechanically).

This
is
less
expensive
than
a
MeBr
treatment,
but
is
not
used
because
it
is
not
effective.

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:
[
Insert
name
of
alternative]

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)

Vapam
Phytopthora
Metam
sodium
10%
1
$
900.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
900.00
Comments:

Cost
includes
material,
plastic
mulch
and
extra
costs
due
to
hand
transplanting
(
can
not
perform
mechanically).

This
is
less
expensive
than
a
MeBr
treatment,
but
is
not
used
because
it
is
not
effective.

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
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
1,3­
D,
chloropicrin
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
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.
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
Acre
Labor
Cost
per
Acre
Total
Cost
per
Acre
Plastic
mulch
300
100
$
400.00
$
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
$
400.00
OMB
Control
#
2060­
0482
1,3­
D,
Chloropicrin;
Metam
Sodium
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
.

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.

Comments:
Increased
costs
will
occur
with
both
materials.
Planting
costs
will
increase
by
$
100
per
acre
because
mechanical
planters
can
not
plant
into
plastic
mulch.
Plastic
mulch
system
is
most
effective
way
to
use
Vapam
or
Telone/
Chloropicrin.
Typical
Equipment
Used
Operation
Done
by
User
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)

Pepper
$
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
Revenue
$
0.00
Comments:

OMB
Control
#
2060­
0482
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.

No
data
are
available
for
this
section;
listed
alternatives
will
not
adequately
control
disease,
so
growers
do
not
use.

Reduction
in
yields
will
occur,
but
how
much
and
over
what
period
of
time
is
not
known.

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternativ
All
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.

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.
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?
Using
broccoli
as
alternative
crop
for
rotational
purposes.

Ongoing
grower
attempts
to
learn
how
to
use
Vapam
and
Telone/
Chloropicrin
in
an
efficaceous
way.
General
breeding
and
research
efforts.

Various
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.)
California
Continuous
Breeding
of
disease
tolerant
strains.
1.

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

Virtually
impermeable
film
(
VIF)

Cultural
practices
(
please
specify)

1b.
Will
you
use
other
pesticides
to
reduce
use
of
methyl
bromide?
Yes
No
X
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
~$
250,000
33
33
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.

Drip
tape
($
500
­
$
600/
acre)
for
Phytophthora
control
through
water
management.

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).
For
EPA
Use
Only
ID#

How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Possible
rotation
with
broccoli.

What
is
the
cumulative
amount
spent
to
date
by
the
user
or
consortium
on
research
to
develop
alternatives
to
methyl
bromide
(
beginning
in
1992)?
Use
has
been
reduced
as
much
as
possible
(
10%
of
total
acreage).
Other
materials
will
be
used
if
they
are
as
economically
and
technically
viable
as
MeBr.
Worksheet
5.
Additional
Information
Do
you
have
access
to
recycled
methyl
bromide?

0
Unknown
New
varieties;
other
effective
pesticides.

0
33
0
0
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.
40,001
­
80,000
sq.
ft.
80,001
­
160,000
sq.
ft.
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
X
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#

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)
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
400,000
5.
Area
Treated
with
Methyl
Bromide
2005
2500
acres
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

2006
400,000
lbs.
Area
Treated
2500
acres
units
2007
400,000
lbs.
Area
Treated
2500
acres
units
Not
Technically
Feasible
Not
Economically
Feasible
X
X
X
X
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.

Solarization/
fungicides
Metam
Sodium
Metam
Sodium,
Crop
Rotation
1,3­
D,
chloropicrin
Chloropicrin
Potential
Alternatives
1,3­
D
Township
caps
limit
use.
Not
effective
against
diseases
such
as
Phytophtora
and
Verticillium,
which
are
the
primary
problems.

Reasons
Concentrations
of
chloropicrin
in
1,3­
D/
Chloropicrin
premixes
are
not
high
enough
to
control
diseases
when
used
at
maximum
label
rates.

Does
not
distriubte
throughout
soil
profile
when
applied
alone,
resulting
in
reduced
efficacy.
It
does
not
adequately
control
Phytophthora
when
used
according
to
label
directions.

Does
not
control
Phytopthora
or
wilts.
Results
are
erratic
and
plants
are
subject
to
phytotoxicity.

See
above.
Due
to
high
land
costs,
there
are
not
many
crops
that
can
be
rotated
with
pepper
that
will
provide
an
economic
return.

A
four
or
five
year
rotation
is
necessary
to
adequately
reduce
inoculum
in
soil
Temperatures
do
not
get
hot
enough
during
land
preparation
period
(
Feb­
April)
to
control
pathogens
in
soil.

About
10%
of
California
pepper
production
has
problems
with
disease
control
(
Phytophthora
and
V
erticillium)
that
existing
alternatives
do
not
adequately
control.
A
single
application
of
MeBr
can
provide
several
years
of
acceptable
control
ina
given
field;
alternatives
must
be
applied
annually.

California
Pepper
Name
of
Applicant:

Location:

Crop:
California
Pepper
Commision
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.
