­­­­­
Forwarded
by
Hodayah
Finman/
DC/
USEPA/
US
on
09/
11/
02
11:
30
AM
­­­­­
SWAConsult@
aol.
com
09/
10/
02
01:
37
AM
To:
Bromide
Methyl@
EPA
cc:
Subject:
almond
cue
1.

2.

3.

4.

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

5.

6.
Specialty
(
check
one)

7.
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.
Merced,
Calif.
95340
genebeach@
aol.
com
209­
723­
7943
Contact
name
Address
209­
723­
7661
E­
mail
Gene
Beach
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).

Almond
Hullers
&
Processors
Association
California
Almonds
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
512
C
St,
NE
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).

9a
&
9b.
About
12%
of
the
almond
production
is
in
zone
9b.

2350
Lecco
Way
202­
543­
4455
202­
543­
4586
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Washington,
DC
20002
gludwig@
swaconsult.
com
Gabriele
Ludwig
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
325,000
lbs.

17a.
A
units
18.
Yes
x
No
18a.

19.

Pratylenchus
vulnus
(
Root
lesion
nematode)

Criconemella
xenoplax
(
Ring
nematode)

Xiphinema
americanum
(
Dagger
nematode)

20.
325,000
Unit
of
Area
Treated
Polyphylla
decemlineata
(
Tenlined
June
Beetle)
Replant
Problem
­
which
include
pathogens,
nematodes,
possible
exudates,
remnant
roots,
and
various
unknown
factors
Meloidogyne
incognita
(
Root
knot
nematode)

Armarillaria
mellea
(
Oak
Root
Fungus)

Pseudomonas
syringae
(
Bacterial
Canker)
2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
325,000
Area
to
be
Treated
1000
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.

The
other
contributing
factor
is
variablity
in
new
plantings.
Currently
(
2001
season),
some
5%
(
29,000
A)
of
almond
acreage
is
greater
than
30
years
old.
30
years
is
considered
the
maximum
productive
lifespan
of
an
almond
orchard
and
growers
are
likely
to
replace
those
orchards.
Given
the
current
market
situation,
especially
in
comparison
to
other
tree
crops,
almonds
ochards
remain
the
likely
crop
to
replace
ageing
orchards
(
other
than
housing
developments).
Furthermore,
1974
and
1975
were
years
where
high
number
of
new
acreage
planted
(
19,000
A)
which
will
reach
the
30
year
­
old
stage
by
2005
­
2006
(
NASSUSDA
almond
acreage
statistics).

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

1000
Research
on
efficacy
and
best
methods
for
application
in
perennial
crops
such
as
almonds
takes
much
longer
to
complete.
In
almonds
the
first
harvest
is
3
years
after
planting
and
full
harvest
is
not
achieved
until
the
tree
is
7­
10
years
old.
Thus,
even
as
new
methods
and/
or
materials
become
available,
testing
of
the
efficacy
will
take
5­
10years.
How
much
area
will
this
be
applied
to?
Please
list
units.
1000
For
EPA
Use
Only
ID#

The
size
of
acreage
for
almond
growers
in
California
various
from
10
A
to
25,000
A.
The
representative
almond
grower
has
100
A
of
almonds.
Most
almond
growers
own
their
own
land,
though
some
lease
additional
land.
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?

A
A
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
20a.

OMB
Control
#
2060­
0482
Explain
why
this
user
represents
the
typical
user
in
the
consortium.
Methyl
Bromide
is
applied
to
a
given
acre
with
almonds
only
once
in
25­
35
years.
Based
on
what
was
growing
in
the
ground
previously,
any
pest
problems
that
existed
in
the
previous
orchard/
crop
(
such
as
bacterial
canker,
oak
root
fungus),
and
on
the
results
from
soil
testing
for
nematodes
presence
and
species,
a
grower
will
decide
whether
the
soil
needs
to
be
fumigated
with
methyl
bromide
before
planting.
New
almond
plantings
typcially
follow
almonds,
other
Prunus
spp,
cotton,
walnuts
or
hay.
If
the
previous
crop
was
a
Prunus
sp.
orchard,
that
ground
will
cause
replant
disorder
in
the
young
almond
trees.
Research
and
experience
indicates
that
such
ground
should
be
fumigated
to
kill
remaining
roots
which
harbor
nematodes,
disease
and
the
pests
that
have
accumulated
over
the
life
of
the
previous
orchard.
If
cotton
was
the
preceding
crop,
then
a
grower
will
only
fumigate
if
the
soil
tests
indicate
high
populations
of
ring
and/
or
root
lesion
nematodes,
as
replant
disorder
is
not
an
issue.
The
use
of
Nemaguard
rootstock
will
allow
the
new
orchard
to
be
planted
in
the
presence
of
root
knot
nematode.
However,
in
the
majority
of
the
situations,
a
grower
is
planting
almonds
to
ground
that
previous
had
another
tree­
crop
such
as
almond
or
peach.

MeBr
has
been
applied
broadcast
to
the
whole
acreage,
in
6­
10ft
strips
along
the
tree
row,
and
to
tree
holes
before
planting
at
rates
of
300­
400
lbs/
A.
If
there
was
a
need
to
fumigate,
then
the
decision
which
intensity
of
MeBr
to
applied
would
depend
on
the
seriousness
of
the
pest
pressures
and
costs.
Applications
to
tree
holes
has
been
popular
because
it
does
not
incur
the
expense
of
a
custom
applicator,
but
provides
only
limited
nematode
and
disease
protection.
Individual
holes
are
also
treated
when
individual
trees
that
have
died
within
a
young
orchard
due
to
soil
caused
problems
are
to
be
replanted.
Currently
none
of
the
other
fumigants
have
viable
means
for
application
to
individual
holes.

For
the
CUE,
the
almond
grower
who
will
need
to
use
MeBr
is
a
grower
who
cannot
apply
Telone
because
of
township
cap
restrictions,
is
replanting
land
which
contained
a
tree
or
vine
crop
previously,
and
has
serious
nematode,
disease
or
soil
insect
issues
based
on
soil
testing
or
history
of
the
orchard.
If
oak
root
fungus
or
bacterial
canker
are
an
issue,
the
grower
needs
to
apply
MeBr
broadcast
at
300­
400
lbs/
A.
If
the
concern
is
only
replant
disorder/
nematodes
then
applying
MeBr
in
8ft
strips
along
the
tree
line
will
be
adequate.
Within
the
strip
a
300­
400
lbs/
A
rate
will
be
applied
which
is
equivalent
to
a
99
­
132
lb/
A
application
of
MeBr.

While
the
size
of
almond
orchards
covers
such
a
wide
range
of
acreage,
most
growers
have
some
50­
200A
of
almonds
along
with
several
other
crops
­
typically
other
tree
crops.
As
stated
above,
it
is
quite
common
for
a
grower
to
decide
to
replant
almonds
into
ground
that
previously
grew
another
tree
crop,
especially
Prunus
species.
California
has
ideal
growing
conditions
for
peaches,
nectarines,
plums,
apricots,
cherries
along
with
almonds.
Growers
who
specialize
in
tree
crops
have
equipment
and
skills
specific
to
production
of
tree
crops
such
as
tree
shakers,
air
blast
equipment,
drip
irrigation,
etc.
Thus,
for
a
tree
grower
to
switch
into
row
crops
can
mean
a
significant
investment
cost.
Furthermore,
in
recent
years
the
market
for
several
of
the
canned
peaches
or
dried
plums
has
been
slowing,
while
almond
prices
have
remained
profitable
by
comparison.

The
representative
methyl
bromide
user
for
almonds
for
the
CUE
is
someone
who
is
replanting
an
almond
ochard
onto
land
that
previous
had
almonds,
peaches,
other
Prunus
species,
walnuts
or
vines.
The
ability
to
kill
the
roots
deep
in
the
soil
is
critical
for
preventing
nematode
populations
from
exploding
on
the
young
tree
root
systems.
Furthermore,
a
grower
who
has
had
a
history
of
bacterial
canker
or
oak
root
fungus,
would
need
to
provide
a
deep
and
thorough
fumigation
of
the
soil.
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
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
20,791.01
893,299.00
42.9656376
14,850.25
551,068.72
37.10838
16,703.24
365,706.75
21.89436
8903.92
164,436.35
18.4678602
over
95%
methyl
bromide
6,492.72
1,852,812.74
285.367726
4,086.00
972,539.00
238.017376
6,834.00
1,591,687.00
232.907082
4813.83
1,080,438.00
224.444569
All
formulations
of
methyl
bromide
#
DIV/
0!
#
DIV/
0!
#
DIV/
0!
#
DIV/
0!

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.

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
Data
from
CDPR
Pesticide
Use
Database
for
Almonds.
The
database
does
not
differentiate
between
broadcast,
strip
and
hole
applications.
The
low
lbs
ai/
A
are
due
to
applications
of
MeBr
to
holes,
that
are
reported
as
applied
to
the
total
acreage
of
the
orchard.
See
below
for
pre­
plant
rates.

The
CDPR
database
also
has
a
category
for
"
soil
fumigation/
pre­
plant"
and
for
"
uncultivated
ag".
The
numbers
above
are
derived
from
those
counties
with
predominantly
orchard
crops
and
are
thus
indicative
of
the
rates
applied
pre­
plant
for
orchards.
Carpenter
et
al.
(
2001)
noted
that
for
the
Central
Valley
counties
the
unspecified
MeBr
usage
was
primarily
for
orchards
based
on
interviews
with
the
County
Ag.
Commissioner's
Offices.
Unfortunately,
it
is
not
clear
how
much
of
the
acreage
was
eventually
planted
to
almonds.
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.

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.
For
EPA
Use
Only
ID#

A
C
D
E
F
Crop
Year
Unit
of
Crop/
Commodity
(
e.
g.,
pounds,
bushels)
Crop/
Commodity
Yield
(
lbs
shelled/
A)
Price
($/
lb)
Revenue
($/
A)

Total
Revenue
for
1997
lbs
shelled
nuts
1,720
$
1.56
$
2,683.20
Total
Revenue
for
1998
lbs
shelled
nuts
1,130
$
1.41
$
1,593.30
Total
Revenue
for
1999
lbs
shelled
nuts
1,740
$
0.86
$
1,496.40
Total
Revenue
for
2000
lbs
shelled
nuts
1,410
$
1.01
$
1,424.10
Average
(
1997­
2000)
Revenue
Per
Year
$
1,799.25
Comments:

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
B
Col.
E:
Price
Col.
F:
Revenue
Crop/
Commodity
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

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

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

As
MeBr
is
typically
applied
6
months
before
planting
and
its
benefits
accrue
over
the
first
5
years
of
the
orchard's
life,
it
is
not
possible
to
make
a
direct
correlation
between
usage
and
return
for
a
given
year.
Almond
Almond
Almond
Almond
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
(
lb/
A)
Price
($/
lb)
Revenue
($/
A)

lbs
shelled
nuts
1,580
$
1.00
$
1,580.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Revenue
$
1,580.00
Comments:

OMB
Control
#
2060­
0482
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.

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

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

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

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

Enter
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.
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)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Area
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Area
98%
MeBr
­
broadcast
application
w/
o
tarp
325
lb/
A
$
970.00
98%
MeBr
­
broadcast
application
w/
tarp
325
lb/
A
655
$
1,625.00
All
formulations
of
methyl
bromide
$
0.00
Comments:

OMB
Control
#
2060­
0482
Enter
the
actual
area
treated.
Note:
This
number
should
be
the
total
area
treated
by
all
users
in
the
consortium.

970
Price
of
applying
325
lb
MeBr/
A
(
2001
Average)

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.

970
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.
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.
price/
lb
=
$
1.00
1
year
2
year
3
year
4
year
5
year
6
year
7
year
8
year
9
year
10
year
Meat
Pounds
per
Acre
400
750
1200
1580
1475
1800
1680
2000
Planting
Costs:

Land
Preparation:
Backhoe
Tree
Holes
$
242.00
Land
Preparation:
Disc
&
Float
2x
$
17.00
Fumigation
MeBr
no
tarp
$
970.00
Survey
and
Plant
Trees
$
83.00
$
9.00
$
4.00
Trees:
110
Per
Acre
(
1%
replant
in
2nd
year)
$
479.00
$
2.00
$
1.00
Paint
and
Put
Trunk
Guards
Trees
$
22.00
$
1.00
TOTAL
PLANTING
COSTS:
$
1,813.00
$
12.00
$
5.00
Cultural
Costs:

Training,
Pruning,
&
Suckering
$
39.00
$
29.00
$
43.00
$
100.00
$
100.00
$
100.00
$
100.00
$
100.00
$
100.00
$
100.00
Brush
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
Water
Sanitation:

Knock
Mummies
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
Blow
&
Rake
Mummies
$
47.00
$
47.00
$
47.00
$
47.00
$
47.00
$
47.00
$
47.00
Shred
Mummies
$
7.00
$
7.00
$
7.00
$
7.00
$
7.00
$
7.00
$
7.00
Weed
Control
­
Dormant
Strip
$
36.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
Insect
Control
­
Dormant
$
52.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
Disease
Control
­
Shothole/
Nutrient
$
25.00
$
20.00
$
34.00
$
34.00
$
34.00
$
34.00
$
34.00
$
34.00
$
34.00
Insect
Control
­
Pinkbud
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
Pollination
$
40.00
$
80.00
$
100.00
$
100.00
$
100.00
$
100.00
$
100.00
$
100.00
Fertilizer
­
Potassium
$
11.00
$
13.00
$
18.00
$
23.00
$
23.00
$
23.00
$
23.00
$
23.00
Vertebrate
Control
­
Rodents
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
Fertilizer
­
Nitrogen
$
9.00
$
17.00
$
31.00
$
39.00
$
56.00
$
70.00
$
70.00
$
70.00
$
70.00
$
70.00
Weed
Control
­
Mow
$
20.00
$
20.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
Irrigate
7x
$
28.00
$
53.00
$
74.00
$
94.00
$
94.00
$
94.00
$
94.00
$
94.00
$
94.00
$
94.00
Weed
Control
­
Spot
Spray
$
16.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
Insect
Control
­
Ants
$
19.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
Insect
Control
­
Worms
&
Mites
$
26.00
$
51.00
$
70.00
$
90.00
$
90.00
$
90.00
$
90.00
$
90.00
$
90.00
$
90.00
Weed
Control
­
Preharvest
Spray
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
Fertilizer
­
Boron
(
Foliar)
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
Misc.
Labor
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
Pickup
Truck
Use
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
ATV
Truck
Use
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
Meat
Pounds
per
Acre
400
750
1200
1580
1475
1800
1680
2000
TOTAL
CULTURAL
COSTS:
$
320.00
$
473.00
$
725.00
$
1,003.00
$
1,045.00
$
1,064.00
$
1,064.00
$
1,064.00
$
1,064.00
$
1,064.00
Harvest
Costs:

Pole
Trees
$
21.00
$
12.00
$
13.00
$
13.00
$
13.00
$
13.00
$
13.00
$
13.00
Shake
Trees
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
Sweep
Nuts
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
Hand
Rake
$
21.00
$
2.00
$
2.00
$
2.00
$
2.00
$
2.00
$
2.00
$
2.00
Pick
Up
and
Haul
$
56.00
$
58.00
$
61.00
$
63.00
$
63.00
$
63.00
$
63.00
$
63.00
Hull
Nuts
$
13.00
$
25.00
$
60.00
$
80.00
$
80.00
$
80.00
$
80.00
$
80.00
TOTAL
HARVEST
COSTS:
$
111.00
$
203.00
$
242.00
$
264.00
$
264.00
$
264.00
$
264.00
$
264.00
Interest
on
Operating
Capital
@
10.46%
$
64.00
$
19.00
$
43.00
$
63.00
$
65.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
TOTAL
OPERATING
COSTS/
ACRE:
$
2,197.00
$
504.00
$
884.00
$
1,269.00
$
1,352.00
$
1,394.00
$
1,394.00
$
1,394.00
$
1,394.00
$
1,394.00
TOTAL
CASH
OVERHEAD
COSTS:
$
291.00
$
289.00
$
289.00
$
289.00
$
289.00
$
289.00
$
289.00
$
289.00
$
289.00
$
289.00
Costs/
Returns
with
MeBr
Operation
For
EPA
Use
Only
ID#

A
B
C
D
E
F
Y
Operation
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
See
sheet
2­
D(
2)
$
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
OMB
Control
#
2060­
0482
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.

Col
B:
Custom
Operation
Cost
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.

Col
A:
Operation
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
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
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.
TOTAL
CASH
COSTS/
ACRE:
$
2,488.00
$
793.00
$
1,173.00
$
1,558.00
$
1,641.00
$
1,683.00
$
1,683.00
$
1,683.00
$
1,683.00
$
1,683.00
INCOME/
ACRE
FROM
PRODUCTION:
$
400.00
$
750.00
$
1,200.00
$
1,580.00
$
1,475.00
$
1,800.00
$
1,680.00
$
2,000.00
NET
CASH
COSTS/
ACRE
FOR
THE
YEAR:
$
2,488.00
$
793.00
$
773.00
$
808.00
$
441.00
$
103.00
$
208.00
($
117.00
$
3.00
($
317.00
PROFIT/
ACRE
ABOVE
CASH
COSTS:
$
117
$
317
ACCUMULATED
NET
CASH
COSTS/
ACRE:
$
2,139.00
$
2,932.00
$
3,705.00
$
4,513.00
$
4,954.00
$
5,057.00
$
5,265.00
$
5,148.00
$
5,151.00
$
4,834.00
TOTAL
NON­
CASH
OVERHEAD
COST/
ACRE:
$
852.00
$
836.00
$
843.00
$
840.00
$
840.00
$
836.00
$
836.00
$
836.00
$
836.00
$
836.00
TOTAL
COST/
ACRE
FOR
THE
YEAR:
$
2,991.00
$
3,768.00
$
4,548.00
$
5,353.00
$
5,794.00
$
5,893.00
$
6,101.00
$
5,984.00
$
5,987.00
$
5,670.00
INCOME/
ACRE
FROM
PRODUCTION:
$
360.00
$
630.00
$
1,080.00
$
1,422.00
$
1,327.50
$
1,620.00
$
1,512.00
$
1,800.00
TOTAL
NET
COST/
ACRE
FOR
THE
YEAR:
$
2,991.00
$
3,768.00
$
4,188.00
$
4,723.00
$
4,714.00
$
4,471.00
$
4,773.50
$
4,364.00
$
4,475.00
$
3,870.00
NET
PROFIT/
ACRE
ABOVE
TOTAL
COST:
($
2,991.00
($
3,768.00
($
3,828.00
($
4,093.00
($
3,634.00
($
3,049.00
($
3,446.00
($
2,744.00
($
2,963.00
($
2,070.00
TOTAL
ACCUMULATED
NET
COST/
ACRE
$
2,991.00
$
6,759.00
$
10,947.00
$
15,670.00
$
20,384.00
$
24,855.00
$
29,628.50
$
33,992.50
$
38,467.50
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
See
sheet
2­
D(
2)
Total
$
0.00
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.
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
no
1b.
Township
caps
yes
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
1,3­
dichloropropene
&
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
research
study
you
use
to
evaluate
a
single
methyl
bromide
alternative.
Use
additional
pages
as
need.

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.
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.

McKenry
(
2000)
The
Replant
Problem
&
Its
Management
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
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
dichloropropene
1,3­
dichloropropene
&
Metam
Sodium
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
COMMENTS
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
Currently
California
regulations
limit
the
maximum
amount
of
Telone
applications
in
one
year
to
less
than
90,250
"
adjusted"
lbs
of
1,3­
dichloropropene
in
a
township
(
36
square
miles
=
23040
A).
At
a
rate
of
335
lb
ai/
A
(
or
35
gal
Telone
II/
A)
can
only
be
applied
to
273
A
in
a
township
for
perennial
crops,
only
about
1.1%
of
the
township
acreage.
As
more
and
more
growers
switch
to
Telone
for
nematode
control,
more
growers
will
be
unable
to
use
Telone
because
other
growers
have
used
the
allowable
amount.
Carpenter
et
al.
(
2001)
have
estimated
that
some
47
townships
will
exceed
the
township
cap,
with
areas
growing
strawberries
and
perennial
crops
being
the
most
likely
areas
for
the
caps
to
be
exceeded.
Currently,
the
County
Agricultural
Commissioner's
Offices
are
charged
with
monitoring
and
accounting
for
Telone
usage
in
terms
of
contribution
to
township
caps.
Both
Telone
and
Methyl
Bromide
require
that
permission
be
obtained
from
the
County
Agriculture
Commissioner's
office
before
buying
or
using
the
product.
Thus,
the
infrastructure
is
already
in
place
to
have
the
use
of
methyl
bromide
under
a
CUE
be
triggered
when
the
township
cap
has
been
reached.
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
x
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
www.
uckac.
edu/
nematodes
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
No
x
7.

8.

OMB
Control
#
2060­
0482
size
of
tree
was
measured,
because
almond
trees
do
not
yield
the
first
3
years.

Telone
is
generally
equally
or
more
effective
in
control
of
nematodes,
but
less
effective
for
plant
diseases
and
weeds.
McKenry,
Michael
California
Numerous
alternatives
are
compared
The
Replant
Problem
and
Its
Management
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Currently
there
is
no
practical
mechanism
to
apply
Telone
to
individual
tree
holes,
which
could
lower
the
acreage
application.
For
EPA
Use
Only
ID#

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.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
yes,
with
buffer
zone
restrictions
1b.
Township
caps
no
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.

Metam­
Sodium
McKenry
(
2000)
The
Replant
Problem
&
Its
Management
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
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
www.
uckac.
edu/
nematodes
&
2000
(#
17)

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
No
x
7.
8.
OMB
Control
#
2060­
0482
Soil
Fumigants
Provide
Multiple
Benefits;
Alternatives
Give
Mixed
Results.
(
1994)
California
Agriculture
48:
22­
28
MS
at
current
label
rates
will
not
provide
adequate
kill
of
old
roots
below
75
cm
soil
depths
and
are
not
recommended
for
where
root
lesion
nematode
is
a
problem
McKenry
(
2000)
IPM­
Based
Guidleines
for
Replanting
Prunus
Orchards
in
2000
without
Methyl
Bromide
His
research
has
shown
that
endoparsitic
nematodes
can
live
off
of
and
propagate
on
old
roots
for
several
years.
Allowing
substantial
populations
of
nematodes
to
develop
while
the
new
trees
are
still
very
vulnerable
to
nematode
feeding.
Old
roots
also
sustain
populations
of
Oak
Root
Fungus
(
Armillaria
mellea
)
and
MS
is
not
recommended
where
Oak
Root
Fungus
is
an
issue.
Thus,
the
efficacy
of
methyl
bromide
has
included
its
ability
to
kill
remnant
roots
down
to
150
cm
(
5
ft)

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?
California
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Numerous
alternatives
are
compared
MS
is
currently
undergoing
a
risk
assessment
at
California
Department
of
Pesticide
Regulations
(
CDPR).
Early
indications
are
that
CDPR
may
require
increased
buffer
zones
and
other
use
restrictions
which
may
further
limit
the
use
of
MS
in
California.
size
of
tree
was
measured,
because
almond
trees
do
not
yield
the
first
3
years.

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

Metam
is
effective
for
killing
nematodes,
diseases
if
it
reaches
them.
Unfortunately
it
has
poor
fuming
capacity
and
it
efficacy
has
been
erratic
due
to
poor
movement
within
the
soil.
Addition
of
water
helps
move
MS
through
the
soil
and
seals
the
MS
in.
However,
it
requires
the
appropriate
equipment
to
drench
and
availability
of
water
to
drench
soils.
More
important,
is
that
MS
is
not
very
effective
in
killing
roots
remaining
in
the
soil,
which
harbor
nematodes
and
pathogens.
McKenry
found
that
MS
did
not
control
endoparasitic
nematodes
below
75
cm
(
2.5
ft)
depth
because
of
this
issue.
When
replanting
on
ground
after
a
previous
orchard,
being
able
to
kill
the
roots
below
75
cm
is
critical
to
succesful
growth
of
the
developing
trees.

McKenry,
Michael
The
Replant
Problem
and
Its
Management.
In
it
see:

If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.

For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
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.
www.
uckac.
edu/
nematodes
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
No
x
7.
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

j
y
p
g
y
most
successful
trial
was
incorporating
the
granules
in
the
surface
1
inch
then
sprinkler
irrigating
on
a
2
hr
on,
2
hr
off
cycle
for
a
total
of
14
hr
and
6
inches
of
water.
The
lethal
effect
was
transported
down
5
ft.
However,
by
the
end
of
1
yr,
the
nematode
control
level
was
75%
compared
to
the
99%
control
achieved
with
a
drenching
of
Vapam
at
325
lb/
acre
rate
in
6
California
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Numerous
alternatives
are
compared
The
Replant
Problem
and
Its
Management
(
1999)

McKenry,
Michael
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
yes,
with
buffers
1b.
Township
caps
no
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

Summarize
each
of
the
research
studies
you
cite
in
the
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
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.

Basamid
McKenry
(
1999)
The
Replant
Problem
&
Its
Management
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.

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
No
x
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.
www.
uckac.
edu/
nematodes
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
No
x
7.
8.
OMB
Control
#
2060­
0482
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

One
major
difficulty
with
this
product
is
the
lack
of
data
on
the
dissolution
rate
of
the
granules,
which
vary
in
size.
The
most
successful
trial
was
incorporating
the
granules
in
the
surface
1
inch
then
sprinkler
irrigating
on
a
2
hr
on,
2
hr
off
cycle
for
a
total
of
14
hr
and
6
inches
of
water.
The
lethal
effect
was
transported
down
5
ft.
However,
by
the
end
of
1
yr,
the
nematode
control
level
was
75%
compared
to
the
99%
control
achieved
with
a
drenching
of
Vapam
at
325
lb/
acre
rate
in
6
inches
water.
Before
this
product
is
practical,
the
granule
dissolution
rate
must
be
known
and
predictable
or
there
must
be
a
formulation
providing
slow
release
of
MITC
over
a
known
period
of
time.
Uniformity
of
distribution
of
granules
to
the
soil
surface
also
poses
a
problem.

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
California
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Numerous
alternatives
are
compared
McKenry,
Michael
The
Replant
Problem
and
Its
Management
(
1999)

If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.

For
EPA
Use
Only
ID#

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

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
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
Solarization
Soil
Solarization
as
an
Alternative
to
Methyl
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
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
scientifically
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
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
BACKGROUND
For
EPA
Use
Only
Worksheet
3­
A(
6).
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
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
x
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
No
x
7.
8.

OMB
Control
#
2060­
0482
Solarization
effectivel
kills
most
soil
organisms
in
the
top
soil
layer
if
the
application
reaches
sufficient
temperatures
and
length
of
time.
The
Central
Valley
has
suffient
sun
and
heat
for
use
of
solarization
in
principle.

"
Although
solarization
can
be
a
viable
alternative
to
methyl
bromide
in
orchards,
there
are
limitations
to
its
use.
While
almond
trees
do
not
yield
the
first
3
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
California
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Solarization
with
various
tarp
systems
EPA
Case
Studies
­
Vol
II
(
1996)
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
yes
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

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
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
Biofumigation
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
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
scientifically
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
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
BACKGROUND
For
EPA
Use
Only
Worksheet
3­
A.(
5)
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
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
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
No
x
7.
8.

OMB
Control
#
2060­
0482
sufficiently
to
be
applicable
for
the
replant
situation
in
almonds.
As
stated
before,
as
long
as
live
roots
exist
down
to
150­

180
cm
(
5­
6
ft),
the
nematodes
and
pathogens
are
also
present
and
available
to
recolonize
any
newly
planted
almond
tree.

almond
trees
do
not
yield
the
first
3
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
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
fenamiphos
­
no/
oxamyl
­
yes
1b.
Township
caps
no
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
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
Nematicides
McKenry
(
1999)
The
Replant
Problem
&
Its
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

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
scientifically
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
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
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
BACKGROUND
For
EPA
Use
Only
Worksheet
3­
A(
4).
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
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
1.
Is
the
study
on
EPA's
website?
Yes
x
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
No
x
7.
8.

OMB
Control
#
2060­
0482
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

In
the
top
18
inches
(
45
cm)
7
apps
of
1
lb
oxamyl
(
Vydate)/
A
controlled
Pratylenchus
vulnus
(
lesion
nematode).
Enzone
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Enzone;
Acrolein,
Fenamiphos
(
Nemacur),
DiTera,
Oxyamyl
(
Vydate)

FIELD
COMPARISON
OF
20
POTENTIAL
METHYL
BROMIDE
1997
Annual
International
Research
Conference
on
Methyl
Bromide
California
orchards
have
drip
or
microsprinkler
irrigation
systems.
These
systems
supply
water
only
between
the
trees
and
to
a
the
top
12­
18
inches
of
the
soil
only.
It
does
not
provide
any
pathogen
or
microbial
Fenamiphos
has
been
voluntarily
cancelled
by
the
registrant
as
of
March
22,
2002
(
Federal
Register
3/
22/
2002)

Michael
V.
McKenry*,
Tom
Buzo,
Stephanie
Kaku,
and
David
Dougherty
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
yes
1b.
Township
caps
no
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

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
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
Biological
Control,
McKenry
(
1999)
The
Replant
Problem
&
Its
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
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
scientifically
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
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
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
not
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
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.
www.
uckac.
edu/
nematodes
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
No
x
7.
8.

OMB
Control
#
2060­
0482
Flooding
and
water
management
­
Flooding
provided
no
control
of
nematodes
Biological
Control
­
poor
­
as
we
are
ignorant
of
what
all
the
organisms
are
that
cause
replant
disorder,
we
are
not
able
to
monitored
in
some
studies
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
almond
trees
do
not
yield
the
first
3
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

Cover
crop
&
Mulching
­
poor.
They
do
not
alter
the
soil
composition
deep
enough
to
control
the
replant
problem.

California
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Numerous
alternatives
are
compared:
Steam
­
No.
38;
Flooding
­
No.
53,
54;

McKenry,
Michael
The
Replant
Problem
and
Its
Management
(
1999)
Alternative:
Study:

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

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

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

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

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)

[
Insert
Alternative]
[
Insert
Study
Title]

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.
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
Sting
nematode
Stunt
nematode
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
Interval
3
1
Untreated
­
pre­
trt
700
3
wks
700
6
wks
707
pre­
trt
100
3
wks
111
6
wks
109
5,000
2
Methyl
Bromide
300
gal.
pre­
trt
669
3
wks
221
6
wks
120
pre­
trt
98
3
wks
77
6
wks
36
8,000
3
Iodo
methane
150
gal.
pre­
trt
675
3
wks
250
6
wks
125
pre­
trt
111
3
wks
35
6
wks
32
7,580
Comments:

Ratings
are
for
nematodes
per
gram
of
soil
OMB
Control
#
2060­
0482
Example
Research
Summary
Table
Example
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
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
intervals
(
days,
weeks
or
months)
that
the
rating
was
taken
for
each
treatment
in
Columns
D,
F,
H,
J,
L,
and
N.
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.
For
this
example,
insert
"
pre­
treatment"
in
the
"
Interval
1"
column
,
insert
"
3
weeks"
in
the
"
Interval
2"
column,

and
insert
"
6
weeks"
in
the
"
Interval
3"
column."

In
columns
E,
G,
I,
K,
M,
and
O
insert
the
rating
(
the
level
of
control
provided
for
a
specific
pest)
for
each
interval
for
each
treatment
described.
In
this
example,
for
the
methyl
bromide
treatment
for
sting
nematode
enter
669
for
the
"
Rating
for
Interval
1",
221
for
the
"
Rating
for
Interval
2",
and
120
for
the
"
Rating
for
Interval
3."
In
the
comments
section
below
describe
the
rating
scale
(
e.
g.,

nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,
etc.).

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

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

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

Treatment
Number
Treatment
Rate
(
lbs.
or
gals.
ai
per
area)
Yield
(
lbs/
acre)
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)
$
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
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
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:
[
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)

Product
X
Pest
Y,
Pest
Z
Chemical
D,

Chemical
F
90%
Chemical
D,

10%
Chemical
F
250
278
lbs
$
10.00
$
20.00
0
25
1
$
2,800.00
Product
U
Pest
V,
Pest
Y
Chemical
C
100%
150
200
gal
$
5.00
$
20.00
10
25
2
$
2,060.00
Vapam
nematodes,

pathogens
Metam
Sodium32..
7%
78
75
gal/
A
Irrigation
$
801A
1/
30
years
$
500.00
RoundUP
Roots
Glyphosate
Penetrator
41%
50%
4
lb
1
gal/
a
$
29.00
$
10.00
0
1A
of
tree
stumps
$
0.00
Telone
II
nematodes
1,3
­
dichloropr
97.50%
335
lb
ai/
A
35
gal/
A
1/
30
years
#
VALUE!

$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Control
P
Pest
J,
Pest
K
$
500.00
Total
#
VALUE!

Comments:

If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Control
P
is
done
2
times
per
year
according
to
____
methods.

None
applicable
for
dealing
w.
replant
disorder
and
oak
root
fungus
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:
Product
X
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.
$
420.00
$
525.00
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)
$
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
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
[
Insert
name
of
alternative]

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.

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.
1
year
2
year
3
year
4
year
5
year
6
year
7
year
8
year
9
year
10
year
Meat
274
400
660
948
885
1170
1092
1400
Price/
lb
=

Planting
Land
Prepa
#######

Land
Prepa$
17.00
Fumigation
#######

Survey
and
$
83.00
$
9.00
$
4.00
Trees:
110
#######
$
50.00
$
5.00
Paint
and
P$
22.00
$
5.00
TOTAL
PL
#######
$
64.00
$
9.00
Cultural
Costs:

Training,
P
$
39.00
$
29.00
$
43.00
#######
#######
#######
#######
#######
#######
#######

Brush
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
$
19.00
Water
Sanitation:

Knock
Mummies
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
Blow
&
Rake
Mummies
$
47.00
$
47.00
$
47.00
$
47.00
$
47.00
$
47.00
$
47.00
Shred
Mummies
$
7.00
$
7.00
$
7.00
$
7.00
$
7.00
$
7.00
$
7.00
Weed
Con
$
36.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
Insect
Control
­
Dorma$
52.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
Disease
Control
­
Sho
$
25.00
$
20.00
$
34.00
$
34.00
$
34.00
$
34.00
$
34.00
$
34.00
$
34.00
Insect
Control
­
Pinkbud
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
$
39.00
Pollination
$
40.00
$
80.00
#######
#######
#######
#######
#######
#######

Fertilizer
­
Potassium
$
11.00
$
13.00
$
18.00
$
23.00
$
23.00
$
23.00
$
23.00
$
23.00
Vertebrate
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
Fertilizer
­
$
9.00
$
17.00
$
31.00
$
39.00
$
56.00
$
70.00
$
70.00
$
70.00
$
70.00
$
70.00
Weed
Con
$
20.00
$
20.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
$
51.00
Irrigate
7x
$
28.00
$
53.00
$
74.00
$
94.00
$
94.00
$
94.00
$
94.00
$
94.00
$
94.00
$
94.00
Weed
Con
$
16.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
Insect
Control
­
Ants
$
19.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
$
21.00
Insect
Con
$
26.00
$
51.00
$
70.00
$
90.00
$
90.00
$
90.00
$
90.00
$
90.00
$
90.00
$
90.00
Weed
Control
­
Preharvest
Spray
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
$
16.00
Fertilizer
­
Boron
(
Foli
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
$
14.00
Misc.
Labo
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
$
27.00
Pickup
Tru
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
$
54.00
Metam
Sodium
app
only
Operation
ATV
Truck
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
$
44.00
Meat
Pounds
per
Acre
274
400
660
948
885
1170
1092
1400
TOTAL
CU
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

Harvest
Costs:

Pole
Trees
$
21.00
$
12.00
$
13.00
$
13.00
$
13.00
$
13.00
$
13.00
$
13.00
Shake
Trees
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
$
61.00
Sweep
Nuts
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
$
45.00
Hand
Rake
$
21.00
$
2.00
$
2.00
$
2.00
$
2.00
$
2.00
$
2.00
$
2.00
Pick
Up
and
Haul
$
56.00
$
58.00
$
61.00
$
63.00
$
63.00
$
63.00
$
63.00
$
63.00
Hull
Nuts
$
13.00
$
25.00
$
60.00
$
80.00
$
80.00
$
80.00
$
80.00
$
80.00
TOTAL
HARVEST
COSTS:
#######
#######
#######
#######
#######
#######
#######
#######

Interest
on
Operating
Capital
@
10.46%
$
64.00
$
19.00
$
43.00
$
63.00
$
65.00
$
66.00
$
66.00
$
66.00
$
66.00
$
66.00
TOTAL
OP
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

TOTAL
CA
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

TOTAL
CA
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

INCOME/
ACRE
FROM
PRODUC
#######
#######
#######
#######
#######
#######
#######
#######

NET
CASH
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

PROFIT/
ACRE
ABOVE
CASH
COSTS:

ACCUMUL
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

TOTAL
NO
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

TOTAL
CO
#######
#######
#######
#######
#######
#######
#######
#######
#######
#######

INCOME/
ACRE
FROM
PRODUC$
39.60
#######
#######
#######

TOTAL
NE
#######
#######
#######
#######
#######
#######

NET
PROFIT/
ACRE
ABOVE
TOTAL
COST:

TOTAL
AC
#######
#######
#######
#######
#######
#######
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:

OMB
Control
#
2060­
0482
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.
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.
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
No
X
7.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
Will
crop
yield
be
measured
in
the
study?
Fungal
Replant
Disorder
Greg
Browne
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.)
Butte
County
Following
up
to
determine
if
injection
of
chloropicrin
0.5­
1
lb
ai
into
planting
hole
is
effective
for
controling
the
fungal
component
of
replant
disorder
Joe
Connell
Chloropicrin
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
No
X
7.
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
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
Methyl
Bromide
Alternatives
Michael
McKenry
Contine
work
on
long
term
efficacy
of
various
alternative
methods
for
controlling
replant
disorder.
Also,
see
if
better
method
for
applying
Metam
Metam
Sodium,
various
other
compounds/
methods
such
as
methyl
iodide
Will
crop
yield
be
measured
in
the
study?

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,
OMB
Control
#
2060­
0482
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
No
X
7.
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
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
Determine
if
hole
injection
methods
for
Telone
are
effective
Greg
Browne
Joe
Connell
See
if
Telone
can
be
effectively
used
when
injected
into
the
planting
hole
only.
This
would
reduce
the
amount
of
Telone
needed
to
treat
an
replant
orchard
Butte
County
1,3­
dichloropropene
Will
crop
yield
be
measured
in
the
study?

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.)
OMB
Control
#
2060­
0482
1.

1a.
Check
all
methods
you
will
use
Nothing
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
If
yes
please
specify.

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

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

3.
Yes
No
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
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.
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Do
you
have
access
to
recycled
methyl
bromide?

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#

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
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#

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)
CUE
02
0043
