For
EPA
Use
Only
ID
#
______________
SECTOR
_________________________

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

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

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

EPA
Form
#
7620­
18a
Pre
Plant
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.
The
information
contained
in
this
application
is
critical
to
process
and
assess
the
need
for
methyl
bromide.
Filling
out
this
application
in
its
entirety
will
bolster
the
U.
S.
government's
ability
to
strengthen
the
nomination
package
for
the
international
review
boards.
OMB
Control
#
2060­
0482
WHY
IS
THIS
INFORMATION
NEEDED?
2003
Application
for
Critical
Use
Exemption
of
Methyl
Bromide
for
Pre
Plant
Use
in
2005
and
beyond
in
the
United
States
Click
on
the
Instructions
tab
located
at
the
bottom
of
the
screen
for
additional
information.
WHO
APPLIES?

STATE
CONTACTS
HOW
DO
I
APPLY?

IS
MY
INFORMATION
CONFIDENTIAL?

WHEN
IS
THE
INFORMATION
NEEDED?

Mailing
Address
for
applications
being
submitted
by
mail
directly
to
the
EPA:
Address
for
applications
being
sent
by
courier
or
non­
U.
S.
Postal
overnight
express
delivery
to
the
EPA:

US
Environmental
Protection
Agency
US
Environmental
Protection
Agency
Methyl
Bromide
Critical
Use
Exemption
Methyl
Bromide
Critical
Use
Exemption
Office
of
Pesticide
Programs
Office
of
Pesticide
Programs
Mail
Code
7503C
911
Bay,
BEAD
1200
Pennsylvania
Ave,
NW
1921
Jefferson
Davis
Highway
Washington,
DC
20460
Arlington,
VA
22202
Telephone:
(
703)
308­
8200
INSTRUCTIONS
The
information
provided
by
you
in
this
application
will
be
used
to
evaluate
the
requested
methyl
bromide
use.
The
U.
S.
and
other
countries
that
are
parties
to
the
Montreal
Protocol
On
Substances
That
Deplete
The
Ozone
Layer
decided
that:
"
a
use
of
methyl
bromide
should
qualify
as
"
critical"
only
if
the
nominating
Party
determines
that:
(
i)
The
specific
use
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
that
use
would
result
in
a
significant
market
disruption;
and
(
ii)
There
are
no
technically
and
economically
feasible
alternatives
available
to
the
user
that
are
acceptable
from
the
standpoint
of
environment
and
health
and
are
suitable
to
the
crops
and
circumstances
of
the
nomination
 "

WHERE
DO
I
SUBMIT
THE
APPLICATION?

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

If
you
have
general
questions
about
this
application
call:

Stratospheric
Ozone
Hotline
1­
800­
296­
1996
If
you
anticipate
that
you
will
need
methyl
bromide
in
2005
because
you
believe
there
are
no
technically
and
economically
feasible
alternatives,
then
you
should
apply
for
the
critical
use
exemption.
This
application
may
be
submitted
either
by
a
consortium
representing
multiple
users
or
by
individual
users.
We
encourage
users
with
similar
circumstances
of
use
to
submit
a
single
application
(
for
example,
any
number
of
pre
plant
users
with
similar
soil,
pest,
and
climactic
conditions
can
submit
a
single
application.)

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

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

States
that
have
agreed
to
participate
in
the
exemption
process
are
listed
on
EPA's
website
at
www.
epa.
gov/
ozone/
mbr/
cueqa.
html
You
may
either
complete
an
electronic
(
Microsoft
Excel)
or
a
printed
version
of
the
application.
Please
fill
out
each
form
or
worksheet
in
the
application
as
completely
as
possible.
If
you
are
completing
the
printed
version
and
need
extra
space
you
may
attach
additional
sheets
as
needed.
Additional
information
may
be
available
from
your
local
state
department
of
agriculture
or
at
the
sites
listed
below
or
by
calling
1­
800­
296­
1996.
The
applicant
may
assert
a
business
confidentiality
claim
covering
part
or
all
of
the
information
in
the
application
by
placing
on
(
or
attaching
to)
the
information,
at
the
time
it
is
submitted
to
EPA,
a
cover
sheet,
stamped
or
typed
legend,
or
other
suitable
form
of
notice
employing
language
such
as
trade
secret,
proprietary,
or
company
confidential.
Allegedly
confidential
portions
of
otherwise
non­
confidential
documents
should
be
clearly
identified
by
the
applicant,
and
may
be
submitted
separately
to
facilitate
identification
and
handling
by
EPA.
If
the
applicant
desires
confidential
treatment
only
until
a
certain
date
or
until
the
occurrence
of
a
certain
event,
the
notice
should
so
state.
Information
covered
by
a
claim
of
confidentiality
will
be
disclosed
by
EPA
only
to
the
extent,
and
by
means
of
the
procedures
set
forth
under
40
CFR
Part
2
Subpart
B;
41
FR
36902,
43
FR
400000.
50
FR
51661.
If
no
claim
of
confidentiality
accompanies
the
information
when
it
is
received
by
EPA,
it
may
be
made
available
to
the
public
by
EPA
without
further
notice
to
the
applicant.
Applicants
submitting
their
application
via
e­
mail
assume
responsibility
for
the
confidentiality
of
the
electronic
message
transmission.

This
application
must
be
postmarked
to
the
EPA
address
below
no
later
than
120
days
after
the
Notice
was
published
in
the
Federal
Register
requesting
critical
use
exemption
applications.
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
SECTIONS
OF
WORKBOOK
INSTRUCTIONS
Each
worksheet
number
corresponds
to
the
tab
number
in
the
electronic
version
of
the
application.
Instructions
specific
to
each
worksheet
are
provided
at
the
top
of
each
sheet.
A
header
row
is
included
on
each
worksheet
to
include
an
application
ID
number
that
EPA
will
assign.

EXCEL
USER
TIPS
Inserting
a
blank
worksheet:

1.
To
add
additional
blank
worksheets
in
the
Excel
file,
go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Insert"
then
"
worksheet"
Worksheet
3.
Alternatives
Worksheet
2­
A.
Methyl
Bromide
­
Pest
and
Crop
Information
Worksheet
2­
B.
Methyl
Bromide
­
Historical
Use
for
1997
­
2002
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Crop
Grouping
Yield
&
Gross
Revenue
for
2000
­
2002
Worksheet
2.
Methyl
Bromide
2.
A
tab
with
the
name
"
Sheet
1"
will
appear
at
the
bottom
of
the
worksheet
and
will
be
highlighted
in
white.
Take
the
cursor
and
double
click
the
"
new
tab"
3.
By
double
clicking
in
the
tab
you
can
now
rename
the
worksheet
to
the
appropriate
number
letter
designation
(
e.
g.,
3­
A(
1),
3­
A(
1)(
a),
etc.)

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

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

Copying
and
pasting
an
entire
worksheet's
contents
into
a
blank
worksheet:

1.
Select
the
worksheet
to
be
copied
by
clicking
on
the
worksheet
tab
at
the
bottom
of
the
screen.
The
tab
will
turn
white
in
color
when
it
has
been
selected.
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
Worksheet
2­
D(
1&
2).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
2002
(
Annual
or
Perennial)

Worksheet
5.
Application
Summary
Definitions
Climate
Zone
Map
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Worksheet
3­
B(
1&
2).
Alternatives
­
Changes
in
Operating
Costs
(
Annual
or
Perennial)
Worksheet
4.
Future
Research
Plans
Instructions
2.
Select
the
top
left
corner
of
the
worksheet
(
this
is
the
space
to
the
left
of
column
A
and
above
row
1.
You
will
know
that
the
entire
worksheet
has
been
selected
because
the
row
and
column
marks
as
well
as
the
worksheet
itself
Note:
This
is
the
only
way
you
can
copy
a
worksheet
and
not
lose
portions
of
the
text
instructions.

Viewing
worksheets
Worksheets
are
best
viewed
in
"
Page
Break
Preview."
To
select
the
view
of
the
worksheet,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Page
Break
Preview."
Page
break
preview
shows
only
the
printable
area
of
the
worksheet,
with
the
blue
lines
that
surround
the
screen
indicating
the
edges
of
each
page.
3.
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Copy".

4.
Go
to
the
blank
worksheet
where
you
want
the
copied
information
to
be
pasted.
5.
Again,
select
the
top
left
corner
of
the
worksheet
(
left
of
column
A
and
above
row
1)
to
select
the
entire
worksheet.
6.
Go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Edit"
then
"
Paste"
OMB
Control
#
2060­
0482
Printing
worksheets
To
increase
or
decrease
the
size
of
the
page
that
is
viewable
on
the
screen,
go
to
the
menu
bar
and
select
"
View"
and
then
"
Zoom".

Navigating
between
worksheets
The
set
of
four
arrows
on
the
bottom
left
of
the
screen
will
help
you
navigate
between
worksheets.
This
is
necessary
to
access
the
remaining
worksheet
tabs
in
the
workbook
that
are
not
viewable.
The
two
arrows
with
vertical
lines
to
either
the
left
or
right
will
take
you
to
the
first
worksheet
and
to
the
last
worksheet
respectively
in
the
workbook.
The
inner
two
arrows
allow
you
move
the
worksheet
tabs
to
the
right
or
to
the
left
incrementally.
The
two
arrows
on
the
bottom
right
of
the
screen
allow
you
to
move
the
worksheet
that
you
are
viewing
to
the
right
or
to
the
left.
This
is
useful
if
the
viewable
area
of
on
the
screen
is
smaller
than
the
entire
page
that
is
in
the
7.
Change
the
title
row
of
the
newly
pasted
worksheet
from
the
old
worksheet
number
to
be
consistent
with
the
worksheet
tab.
EPA
Form
#
7620­
18a
Pre
Plant
If
you
would
like
to
print
all
worksheets
that
are
contained
in
this
workbook,
go
to
the
menu
bar
at
the
top
of
the
screen
and
select
"
File"
and
then
"
Print."
Then
in
the
section
of
the
menu
that
appears
called
"
Print
what,"
select
"
Entire
Workbook."
Yes
No
x
x
x
Cell
Fax
x
x
Cell
Fax
Address
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.

Is
this
information
Confidential
Business
Information?

4401
E.
Colonial
Dr.;
Box
140155
Agronomic
Orlando,
FL
32814­
0155
Economic
(
813)
752­
2167
Florida
Strawberry
Growers
Association
Drawer
2550
Plant
City,
FL
33564
Agronomic
Economic
Date
Title
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
now
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.
Print
Name
Daniel
A.
Botts
I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.

Signature
11­
Aug­
03
Director,
Environmental
and
Pest
Management
Division,
FFVA
Title
Signature
11­
Aug­
03
Date
Print
Name
Daniel
A.
Botts
Director,
Environmental
and
Pest
Management
Division,
FFVA
If
yes,
the
applicant
assumes
responsibility
for
the
secure
transmission
of
electronic
submissions.

Applicant
Name
Primary
Contact
Contact
Name
(
Check
One)
Specialty
Daniel
A.
Botts
or
Michael
J.
Aerts
Florida
Fruit
and
Vegetable
Association
E­
mail
Address
Address
Daytime
Phone
(
813)
752­
6822
chinton@
tampabay.
rr.
com
Charles
F.
Hinton
(
407)
894­
1351
(
407)
257­
6148
or
(
407)
257­
4694
dan@
ffva.
com
or
maerts@
ffva.
com
(
407)
894­
7840
Specialty
Daytime
Phone
E­
mail
Address
Alternate
Contact
Contact
Name
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
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.
1.
Location
2.
Crop/
Crop
Grouping
3.

cannot
determine
**

cannot
determine
4.
Climate
Zone
Zones:
(
check
all
that
apply)

5.
Soil
Type
&
Organic
Matter
Light
95%
Medium
x
Heavy
0
to
2
%
x
2
to
5
%
x
over
5
%

6.
Yes
Pounds
No
x
7.
Yes
x
CUE
#
02­
0053
No
8.

Year
2005
Acres
2006
Acres
2007
Acres
9.

10.

11.
Yes
Lbs
No
x
12.
Yes
Lbs
Please
explain
why
methyl
bromide
is
being
requested.
(
Insert
number
or
percentage
of
users
in
each
category)
0
­
25
acres
lbs.
7,100
lbs.
What
is
the
amount
of
methyl
bromide
being
requested
by
this
application
?
(
Do
NOT
include
QPS
amounts)

1,278,000
Has
this
applicant
previously
applied
for
Critical
Use
Exemption
of
methyl
bromide?
Range
of
acres
farmed
by
growers
included
in
this
application
Is
this
applicant
eligible
for
Quarantine
and
Preshipment
(
QPS)
uses
of
methyl
bromide?
100
­
200
acres
200
­
400
acres
25
­
50
acres
50
­
100
acres
cannot
determine
(
Enter
the
state,
region,
or
county.)

Florida
(
Include
all
crops/
crop
groupings
that
benefit
from
an
application
of
methyl
bromide
in
a
fumigation
cycle.
For
a
definition
of
fumigation
cycle
see
Worksheet
entitled
"
Definitions".)

Strawberry
7,100
(
Indicate
the
soil
type
and
percent
organic
matter
where
methyl
bromide
would
be
applied.)

Soil
Type:

Organic
Matter:

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

Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
after
January
1,
2005?
Methyl
bromide
continues
to
be
the
most
consistent
and
reliable
pest
control
alternative
for
the
pest
complex
targeted
by
crop
yield
and
quality.
Also
see
attached
Worksheet
1
narrative
description.
preplant
fumigation.
The
variation
in
consistency
with
alternatives
at
the
present
time
presents
unacceptable
risks
to
both
Do
you
have
access
to
recycled
methyl
bromide?

If
yes,
please
specify
amount
(
in
pounds).
Total
Pounds
Active
Ingredient
(
a.
i.)
of
Methyl
Bromide
1,278,000
Total
Area
to
be
Treated
(
check
all
that
apply)
**
The
average
farm
size
of
a
grower
is
about
53
acres.
Some
double
cropping
does
take+
B81
place.

(
Indicate
the
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map
located
at
the
end
of
this
workbook
or
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html.)

1____
2a____
2b____
3a____
3b____
4a____
4b____
5a____
5b____
6a____
6b____
7a____
7b____
8a____
8b__
3%_
9a_
90%_
9b_
3%__
10a__
2%_
10b_
2%__
11____

lbs.
1,278,000
Please
explain
why
there
may
be
variations
in
the
pounds
or
acres
treated
from
year
to
year.
7,100
cannot
determine
cannot
determine
OMB
Control
#
2060­
0482
over
400
acres
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
No
x
storage
after
January
1,
2005?
If
yes,
please
specify
amount
(
in
pounds).

EPA
Form
#
7620­
18a
Pre
Plant
Worksheet
Title
2­
A
Methyl
Bromide
­
Crop
&
Pest
Information
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

The
purpose
of
this
worksheet
is
to
determine
pest
infestation
and
crop
information
where
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
impacts
of
using
an
alternative
to
replace
methyl
bromide.

2­
B
Methyl
Bromide
­
Historical
Use
1997
­
2002
If
a
consortium
is
submitting
this
application,
all
data
should
reflect
the
actual
data
for
the
consortium.

This
worksheet
provides
data
in
actual
usage
for
1997­
2002.

2­
C
Methyl
Bromide
­
Crop/
Crop
grouping
Yield
and
Gross
Revenue
for
2000­
2002
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

This
worksheet
provides
crop/
crop
grouping
yield
and
gross
revenue
for
2000
through
2002.

The
purpose
of
this
worksheet
is
to
determine
past
gross
revenues
when
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
revenue
impacts
of
using
an
alternative
to
replace
methyl
bromide.

2­
D(
1
&
2)
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
2002
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

This
data
is
needed
to
estimate
a
baseline
for
operating
costs
in
order
to
estimate
changes
in
costs
and
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide
and
to
provide
required
information
to
the
international
review
board.

The
purpose
of
this
worksheet
is
to
determine
operating
expenses
when
methyl
bromide
is
used.
This
forms
the
baseline
for
evaluating
the
cost
impacts
of
using
an
alternative
to
replace
methyl
bromide.
The
data
requested
are
designed
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable,
which
will
be
shown
in
Worksheet
3­
B.
Worksheet
2­
D(
1)
is
for
users
with
a
fumigation
cycle
of
less
than
5
years.
Worksheet
2­
D(
2)
is
for
users
growing
perennial
crops
following
a
single
fumigation
at
establishment.

In
collaboration
with
USDA,
we
will
estimate
fixed
and
overhead
costs
across
crops
and
regions
to
ensure
consistency
within
the
U.
S.
nomination.
OMB
Control
#
2060­
0482
Purpose
of
Data:
To
establish
a
baseline
estimate
of
crop/
crop
grouping
yields,
gross
revenues,
and
costs
using
methyl
bromide.

Instructions
specific
to
each
worksheet
are
located
at
the
top
of
each
sheet.
Worksheet
2.
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
1.
Crop/
Crop
Grouping
or
Consortium
2.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept
Oct
Nov
Dec
x*

2.
Fumigation
and
Crop
Timeline
Beginning
Fumigation
Cycle
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Continuation
of
Fumigation
Cycle
(
if
needed)

Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Which
month
does
your
fumigation
cycle
start?
(
check
only
one)

Other
key
crop
steps
include
items
such
as
pruning,
mulch
removal,
laying
overhead
irrigation
piping,
etc.
Other
key
pest
steps
include
insecticide,
fungicide
and
herbicide
applications,
burndown
of
crop
and
cover
cropping.
A
comprehensive
description
that
includes
the
timeline
and
variability
in
timing
for
specific
field
operations
is
given
in
the
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Comments:

narrative.
See
pages
13
and
14.
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
*
Fumigation
Cycle
Start
is
dependent
on
regionally
differences.
See
Strawberry
Production
Timeline
on
pages
12
and
13
of
the
narrative
and
the
attached
Worksheet
2­
A
narrative
description.
Florida
Fruit
and
Vegetable
Association;
Strawberries
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
OMB
Control
#
2060­
0482
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

See
Narrative,
pages
12
and
13.
Also
see
the
attached
Worksheet
2­
A
narrative
description.
3.
Target
Pest(
s)
or
Pest
Problem(
s):

Pest
1
Pest
2
Pest
3
Pest
4
Pest
5
4.
Pest
Economic
Threshold
Year
Pest
1
Pest
2
Pest
3
Pest
4
Pest
5
5.
Target
Pest
Infestation
Pest
1
%
Pest
2
%
Pest
3
%
Pest
4
%
Pest
5
%

6.
Representative
User
:
Sting
Nematodes
Nutsedge
Phytophthora
Crown
Rot
Belonolaimus
longicaudatus
Cyperus
rotundus
&
C.
esculentus
Phytophthora
citricola
&
P.
cactorum
Low
Density/
Undefined
Carolina
Geranium
Geranium
carolinianum
Source
See
Narrative,
pages
23
and
24
100
Also
see
the
attached
Worksheet
2­
A
narrative
description.
Other
descriptive
factors
regarding
representative
user:
Acres
Acres
(
Please
provide
descriptive
factors
regarding
your
operation.)

Average
Farm
Size
Average
acres
in
this
crop
Average
Area
Treated
with
Methyl
Bromide:
Acres
Root­
knot
Nematodes
Meloidogyne
spp.
See
pages
22
of
the
narrative
(
Please
identify
the
top
target
pests
or
pest
problems.
Provide
at
least
common
name
and
genus
and
species
if
possible.
Additional
pests
or
pest
problems
can
be
provided
as
an
attachment.)

Common
Name
Genus
Low
Density/
Undefined
Describe
a
few
crops
that
could
follow
this
crop:
53
53
cucurbits*

*
For
double
crop
on
the
same
plastic,
we
have
used
cucumber
as
the
model
for
budget
purposes;
other
cucurbits
may
be
planted.
Percentage
of
Total
Growing
Area
Source
Threshold
and
the
attached
Worksheet
2­
A
narrative
description.

Low
Density/
Undefined
100
100
100
100
(
Please
provide
the
economic
threshold
information
for
each
pest.
Describe
year
and
source
of
information
such
as
survey
or
expert
estimate.)

Units
(
e.
g.
pests/
sq
ft)
EPA
Form
#
7620­
18a
Pre
Plant
OMB
Control
#
2060­
0482
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
Low
Density/
Undefined
(
Please
estimate
the
percentage
of
the
consortia's
total
growing
area
with
a
moderate
to
severe
problem
with
these
pests.
Describe
source
of
information
such
as
a
survey
or
expert
estimate.)
Low
Density/
Undefined
EPA
Form
#
7620­
18a
Pre
Plant
Column
A:

Column
B:

Column
C:

A
B
C
Total
Actual
Pounds
a.
i.
of
Methyl
Bromide
Applied
per
Year
Total
Actual
Acres
Treated
per
Year
Average
Pounds
a.
i.
Applied
per
Acre
per
Year
1997
1,195,600
6,100
196
1998
1,215,200
6,200
196
1999
1,023,000
6,200
165
2000
1,039,000
6,200
164.9
2001
1,072,500
6,500
165
2002
1,138,500
6,900
165
Worksheet
2­
B.
Methyl
Bromide
­
Historical
Use
for
1997­
2002
Total
Actual
Pounds
a.
i.
of
Methyl
Bromide
Applied
per
Year
Enter
the
total
actual
pounds
active
ingredient
(
a.
i.)
of
methyl
bromide
applied.
Note:
This
number
should
be
the
total
pounds
a.
i.
applied
by
the
individual
user
or
the
entire
consortium,
for
the
year
indicated.
Include
only
the
pounds
active
ingredient
of
methyl
bromide.
Do
not
include
the
pounds
of
chloropicrin
that
may
be
part
of
the
same
product.

Total
Actual
Acres
Treated
per
Year
Enter
the
total
actual
acres
treated.
Note:
This
number
should
be
the
total
actual
acres
treated
by
the
individual
user
or
total
actual
acres
treated
for
the
entire
consortium,
for
the
year
indicated.
For
furrow
treatment
the
acres
should
include
the
area
between
the
rows
as
well
as
the
area
of
the
rows.
i.
e.
acres
treated
is
the
area
of
the
cultivated
fields
being
treated
including
the
area
between
rows
even
if
they
are
not
treated.

Average
Pounds
a.
i.
Applied
per
Area
per
Year
The
average
application
rates
in
pounds
a.
i.
of
methyl
bromide
per
area
may
be
calculated
by
dividing
Column
A
by
Column
B.

Year
If
there
is
a
variation
(
greater
than
10%)
in
the
quantity
a.
i.,
the
acres
treated
or
average
application
rate
from
year
to
year,
please
explain
the
reasons
for
the
variation.
What
is
the
frequency
of
methyl
bromide
applied
per
area?
(
1x
/
year,
2x
/
year,
1x
/
3
years,
etc.)

____
1____
time
per
__
year______
OMB
Control
#
2060­
0482
impacting
planted
acreages,
pest
impacts,
cultural
impacts,
and
rates
applied
per
acre.

Comments:

The
downward
trend
in
sales
from
1997
reflects
formulation
changes
(
and
availability
of
products)
from
98:
2
to
67:
33
as
the
phase­
out
schedule
reduced
the
amounts
of
material
available
to
distributors.
Pages
13
through
20
of
the
CUE
petition
#
02­
0053
describe
the
factors
affecting
the
application
of
methyl
bromide.
Refer
to
both
narratives
for
further
specifics
and
descriptions
EPA
Form
#
7620­
18a
Pre
Plant
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

Column
F:

Column
G:

A
B
C
D
E
F
G
Year
Crops/
Crop
Groupings
Market
Category
Yield
Unit
of
Measurement
Price
($)
Gross
Revenue
per
Acre
($)

1997
Strawberry
Fresh
2,417
12­
lb.
Flat
$
9.91
$
23,952.00
1998
Strawberry
Fresh
2,167
12­
lb.
Flat
$
12.00
$
26,004.00
1999
Strawberry
Fresh
2,500
12­
lb.
Flat
$
9.72
$
24,300.00
2000
Strawberry*
Fresh
2,917
12­
lb.
Flat
$
9.12
$
26,603.00
2001
Strawberry*
Fresh
2,167
12­
lb.
Flat
$
11.88
$
25,744.00
2002
Strawberry*
Fresh
2,126
12­
lb.
Flat
$
10.46
$
22,238.00
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Species
Yield
&
Gross
Revenue
for
2000­
2002
Market
Categories
Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
crop
groupings
in
the
fumigation
cycles
from
2000
to
2002.
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/
crop
groupings
that
benefit
from
methyl
bromide
in
the
fumigation
cycle.
If
multiple
crops/
crop
groupings
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/
crop
groupings
during
the
entire
interval.

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/
crop
groupings
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.
Year
Crops/
Crop
Groupings
If
this
application
is
for
multiple
crops/
crop
groupings
(
e.
g.
nurseries
producing
evergreens,
deciduous,
and
forbs)
please
indicate
the
proportion
of
land
area
allocated
to
each
crop/
crop
grouping.
For
additional
specifics
related
to
enterprise
budgets
when
including
cucurbits
as
a
second
crop,
refer
to
the
strawberru
crop
budgets
included
in
Appendix
II.

Comments:
OMB
Control
#
2060­
0482
Gross
revenue
per
acre
for
each
market
category
and
or
each
crop/
crop
grouping
may
be
calculated
using
the
data
you
entered
as
price
times
yield.
If
revenue
is
not
equal
to
price
times
yield,
you
may
enter
a
different
revenue
amount,
but
please
explain
the
difference
in
the
comments
section
below.
Gross
Revenue
Price
Enter
the
unit
of
measurement
for
each
crop/
species
(
lbs,
cwt,
carton,
bin).
If
not
by
weight,
specify
in
the
comments
section
the
average
weight
of
the
measure.
Units
of
Measurement
Enter
average
prices
received
by
the
users
for
that
crop/
crop
grouping
and
market
category.
Average
price
over
all
categories
can
be
calculated
separately,
if
needed.
Enter
marketing
categories
that
determine
prices
received,
for
example,
grade
(
size,
color),
timeliness
(
early
season,
late
season),
or
end
use
(
fresh,
processing).
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
if
lack
of
methyl
bromide
would
effect
the
yields
in
each
category.

Enter
the
yield
per
acre,
or
the
proportion
of
total
yields,
obtained
for
that
category.
For
perennial
crops,
please
enter
yields
at
full
production.
Be
sure
to
indicate
yields
at
other
stages
in
the
timeline
in
Worksheet
2­
A.
Yield
EPA
Form
#
7620­
18a
Pre
Plant
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:
Constant
Cost
per
Acre
For
harvest
operations,
specify
costs
that
depend
on
land
area,
for
example,
picking
costs,
per
acre
of
land.

Cost
per
Unit
of
Yield
For
harvest
operations,
specify
costs
that
depend
on
amount
of
product
harvested,
for
example,
packing
material,
per
unit
of
produce.
Units
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Harvest
costs
may
likewise
be
calculated
as
costs
per
acre
(
Column
B)
plus
variable
costs
per
unit
of
yield
(
Column
C)
times
yield
(
Column
D).
Total
Cost
per
Acre
Unit
Costs
Total
Cost
per
Acre
Yield
For
harvest
operations,
indicate
average
yields
or
representative
yields
from
Worksheet
2­
C.
This
field
is
required
only
for
methyl
bromide.
However,
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.
Operation
/
Input
Quantity
Used
per
Acre
Operation
/
Input
for
Perennial
Crops
OMB
Control
#
2060­
0482
For
perennial
crops
(
Worksheet
D(
2)),
we
have
divided
the
lifespan
into
three
basic
periods:
pre­
production
(
including
establishment),
initial
production,
and
full
production.
Please
ensure
that
the
timeline
in
Worksheet
2­
A
indicates
the
years
of
each
period.
Operating
costs
should
be
an
average
of
costs
incurred
during
each
period.
Please
consider
expected
replanting
rates
and
indicate
which
year
dead
or
poorly
performing
young
trees
would
be
replaced.
You
may
copy
columns/
rows
as
needed
if
these
periods
need
to
be
refined
for
your
situation.

For
inputs
and
operations
detailed
in
Columns
B
and
D,
total
costs
can
be
calculated
as
Column
B
times
Column
D.
Otherwise,
enter
total
cost
of
the
input
or
operation.
As
a
check,
you
may
add
up
Column
E
to
obtain
an
estimate
of
total
variable
operating
costs.
These
will
not
include
fixed
and
overhead
costs,
nor
a
return
to
the
owners'
labor.
It
should,
therefore,
be
less
than
gross
revenues
calculated
in
Worksheet
2­
C.
If
it
is
not,
please
explain
(
for
example,
unusually
poor
yields
or
unusually
poor
prices).
For
perennial
crops,
Column
E
should
only
be
totaled
for
the
years
at
full
production.
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
methyl
bromide,
including
any
material
costs,
for
example,
tarps.
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.
Worksheet
2­
D(
1&
2).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
2002
Enter
all
operating
costs
incurred
during
a
fumigation
cycle.
Users
with
a
relatively
short
fumigation
cycle
(
less
than
five
years)
should
use
version
D(
1);
users
cultivating
perennial
crops
should
use
version
D(
2).
Users
with
multiple
crops,
either
on
the
same
area
in
a
single
fumigation
cycle
or
on
different
areas
treated
separately,
should
copy
this
sheet
and
provide
costs
for
each
crop.
If
multiple
crops
are
cultivated
sequentially
following
a
single
fumigation,
replace
fumigation
costs
in
Pre­
plant
Operations
with
any
additional
pest
control
costs
used
prior
to
the
following
crops.
If
a
fallow
season
is
an
important
part
of
the
fumigation
cycle,
include
costs
incurred
(
for
example,
cultivating
a
cover
crop)
as
a
separate
line
or
as
a
separate
sheet,
if
costs
are
extensive.
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

The
operations/
inputs
listed
here
are
not
meant
to
be
exhaustive
or
representative
of
your
specific
production
system.
They
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.
Be
as
precise
as
necessary
otherwise
you
may
aggregate
operations
or
inputs.
For
example,
specify
herbicide
costs
if
additional
treatments
would
become
necessary
with
the
use
of
a
methyl
bromide
alternative,
otherwise
you
may
simply
specify
total
pesticide
costs.
Please
specify
only
variable
operating
costs.
EPA
Form
#
7620­
18a
Pre
Plant
B
C
D
E
Quantity
Used
per
Acre
Units
(
lbs,
hours,
etc)
Unit
Cost
($)
Total
Cost
per
Acre
($)

Single
Crop:
$
10,128.33
Double
Crop:
$
11,684.19
Constant
Cost
per
Acre
($)
Cost
per
Unit
of
Yield
($)
Yield
Total
Cost
per
Acre
($)

Single
Crop
5,320.00
$

Single
Crop
7,952.00
$

Double
Crop
6,400.00
$

Double
Crop
9,668.00
$
Grading
/
Packing
/
Storage
Other
Costs
Total
Harvesting
Costs
Total
Harvesting
Costs
Harvest
Operations
Labor
Hauling
Material
Fungicide
Nematicide
Irrigation
Labor
(
manual)

(
housing,
land,
insurance,
etc.)
Fuel
/
Machine
Labor
Other
Costs
Cultural
Operations
Seed
/
Seedlings
Fertilizer
/
Soil
Amendments
Pesticides
Insecticide
Herbicide
Other
costs
(
plastic,
labor,
depreciation,
etc.)
Fumigation
product
(
methyl
bromide)

application
Irrigation
Pre­
plant
Operations
­­
Totals
Land
preparation
A
Worksheet
2­
D(
1).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
2002
See
Strawberry
Enterprise
Budget
Worksheets
included
in
Appendix
II
­
B
­
2
of
the
narrative.

Total
Packing,
Selling
and
Related
Overhead
Total
Packing,
Selling
and
Related
Overhead
OMB
Control
#
2060­
0482
Operation
/
Input
EPA
Form
#
7620­
18a
Pre
Plant
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)
B
(
3)
C
(
3)
D
(
3)
E
(
3)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
Fumigation
product
application
Irrigation
Seedlings
Other
costs
Cultural
Operations
Fertilizer/
soil
amendments
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
Labor
(
manual)

Fuel/
machine
labor
Other
costs
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Picking/
hauling
Material
Grading/
packing
Other
costs
OMB
Control
#
2060­
0482
Worksheet
2­
D(
2).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops
INITIAL
PRODUCTION
YEARS
_____
FULL
PRODUCTION
YEARS
_____

PRE
PRODUCTION
YEARS
_______
EPA
Form
#
7620­
18a
Pre
Plant
Worksheet
3­
A
3­
B
Alternatives
­
Changes
in
Operating
Costs
Worksheet
3.
Alternatives
­
Feasibility
of
Alternative
Pest
Control
Regimens
Title
You
must
complete
one
worksheet
for
each
alternative.
Please
inset
the
name
of
the
alternative
in
the
area
on
top
of
the
page.
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review.
However,
you
must
fill
in
the
information
in
Question
#
1
and
#
3
or
we
will
assume
no
yield
or
quality
loss.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Purpose
of
Data:
To
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available.
EPA
needs
to
compare
data
(
yields,
crop/
species
prices,
gross
revenues
and
costs)
on
the
use
of
methyl
bromide
and
alternative
pest
control
regimens.

Complete
worksheet
3­
A
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
nonchemical
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.

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
Definition
worksheet
for
a
comprehensive
definition
on
fumigation
cycles.
OMB
Control
#
2060­
0482
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

This
data
is
needed
to
estimate
changes
in
costs
and
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide
and
to
provide
required
information
to
the
international
review
board.

The
purpose
of
this
worksheet
is
to
determine
operating
expenses
when
alternatives
are
used
for
evaluating
the
cost
impacts
of
using
an
alternative
to
replace
methyl
bromide.
The
data
requested
are
designed
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.
Worksheet
3­
B(
1)
is
for
users
with
a
fumigation
cycle
of
less
than
5
years.
Worksheet
3­
B(
2)
is
for
users
growing
perennial
crops
following
a
single
fumigation
at
establishment.

In
collaboration
with
USDA,
we
will
estimate
fixed
and
overhead
costs
across
crops
and
regions
to
ensure
consistency
within
the
U.
S.
nomination.
Please
fill
out
this
worksheet
for
each
alternative
specified
in
the
U.
S.
Matrix
and
for
other
alternatives
for
which
the
economic
evaluation
would
bolster
the
case
that
methyl
bromide
is
needed.
EPA
Form
#
7620­
18a
Pre
Plant
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

x
No
5.

6.
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.

Pest
Resistant
To
Alternative
­
Label
Restriction
­
Township
Caps
Restrictions
on
Alternative
Use
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
variable
variable
Yes
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
Extended
pretransplant
period
for
Telone
depends
on
soil
temperature
and
moisture.
variable
variable
1
2
3
4
root­
knot
nematodes
phytophthora
crown
rot
sting
nematodes
variable
Details
%
Pest
Control
*

variable
carolina
geranium
Alternative:

%
Yield
Loss
*
Telone
C35
+
chloropicrin
+
Devrinol
+
Goal.
See
pages
25
and
26
of
the
narrative
and
the
attached
Worksheet
2­
A
narrative
description.

Yield
Loss
&
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
Pest
Being
Tested
Study
#
(
list
below)
Provide
numerical
estimates
where
possible.

nutsedge
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
variable
Based
on
multiple
research
trials
conducted
over
the
past
10
years
and
summarized
in
the
narrative
of
CUE
#
02­
0053.
Additional
research
submitted
in
Appendix
1
­
D,
2003
application.
variable
variable
variable
Enter
Average
Loss
Details
Attached?
See
CUE
#
02­
0053
and
Appendix
1
­
B,
2003
application
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
OMB
Control
#
2060­
048
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Label
Restriction
Terminology
­
"
Karst
Geography"
­
see
narrative,
p.
15
­
16.
100%
Other
Restrictions
(
Describe)

EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Non­
Chemical
Pest
Control
(
please
describe)
Refer
to
Appendix
I
in
the
CUE
narrative
for
a
complete
overview
of
alternative
experimental
projects
undertaken
since
the
initial
CUE
submission,
and
additional
alternatives
work
planned
for
the
immediate
future.
Units
(
gals,
lbs.
Etc.)

Land
Preparation
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Fumigation
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
See
pages
25
and
26
of
the
narrative
and
the
discussion
of
non­
chemical
pest
control
alternatives
included
in
pages
27
through
32
of
CUE
petition
#
02­
0054.
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)

Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
See
narrative,
pages
25
and
26+
F26.

Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Also
see
the
attached
Worksheet
2­
A
narrative
description.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
OMB
Control
#
2060­
048
Comments:
Alternative:
Telone
C35
+
chloropicrin
+
Devrinol
+
Dual.

Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
EPA
Form
#
7620­
18a
Pre
Plant
482
es
482
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:
Yield
For
inputs
and
operations
detailed
in
Columns
B
and
D,
total
costs
can
be
calculated
as
Column
B
times
Column
D.
Otherwise,
enter
total
cost
of
the
input
or
operation.
As
a
check,
you
may
add
up
Column
E
to
obtain
an
estimate
of
total
variable
operating
costs.
These
will
not
include
fixed
and
overhead
costs,
nor
a
return
to
the
owners'
labor.
It
should,
therefore,
be
less
than
gross
revenues
calculated
in
Worksheet
2­
C.
If
it
is
not,
please
explain
(
for
example,
unusually
poor
yields
or
unusually
poor
prices).
For
perennial
crops,
Column
E
should
only
be
totaled
for
the
years
at
full
production.
Constant
Cost
per
Acre
For
harvest
operations,
specify
costs
that
depend
on
land
area,
for
example,
picking
costs,
per
acre
of
land.

Units
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

For
harvest
operations,
indicate
average
yields
or
representative
yields
from
Worksheet
3­
A.

Total
Cost
per
Acre
Total
Cost
per
Acre
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
methyl
bromide,
including
any
material
costs,
for
example,
tarps.
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.
Worksheet
3­
B(
1&
2).
Alternatives
­
Changes
in
Operating
Costs
Enter
all
operating
costs
incurred
during
a
fumigation
cycle.
Users
with
a
relatively
short
fumigation
cycle
(
less
than
five
years)
should
use
version
B(
1);
users
cultivating
perennial
crops
should
use
version
B(
2).
Users
with
multiple
crops,
either
on
the
same
area
in
a
single
fumigation
cycle
or
on
different
areas
treated
separately,
should
copy
this
sheet
and
provide
costs
for
each
crop.
If
multiple
crops
are
cultivated
sequentially
following
a
single
fumigation,
replace
fumigation
costs
in
pre
plant
Operations
with
any
additional
pest
control
costs
used
prior
to
the
following
crops.
If
a
fallow
season
is
an
important
part
of
the
fumigation
cycle,
include
costs
incurred
(
for
example,
cultivating
a
cover
crop)
as
a
separate
line
or
as
a
separate
sheet,
if
costs
are
extensive.
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

Operation
/
Input
The
operations/
inputs
listed
here
are
not
meant
to
be
exhaustive
or
representative
of
your
specific
production
system.
They
are
meant
to
provide
suggestions
and
to
help
you
identify
how
your
operation
would
change
if
methyl
bromide
were
unavailable.
Be
as
precise
as
necessary
otherwise
you
may
aggregate
operations
or
inputs.
For
example,
specify
herbicide
costs
if
additional
treatments
would
become
necessary
with
the
use
of
a
methyl
bromide
alternative,
otherwise
you
may
simply
specify
total
pesticide
costs.
Please
specify
only
variable
operating
costs.
Alternative:
Telone
C35
+
chloropicrin
+
Devrinol
+
Goal.

Cost
per
Unit
of
Yield
For
harvest
operations,
specify
costs
that
depend
on
amount
of
product
harvested,
for
example,
packing
material,
per
unit
of
produce.
OMB
Control
#
2060­
0482
Unit
Costs
Operation
/
Input
for
Perennial
Crops
For
perennial
crops
(
Worksheet
B(
2)),
we
have
divided
the
lifespan
into
three
basic
periods:
pre­
production
(
including
establishment),
initial
production,
and
full
production.
Please
ensure
that
the
timeline
in
Worksheet
3­
A
indicates
the
years
of
each
period.
Operating
costs
should
be
an
average
of
costs
incurred
during
each
period.
Please
consider
expected
replanting
rates
and
indicate
which
year
dead
or
poorly
performing
young
trees
would
be
replaced.
You
may
copy
columns/
rows
as
needed
if
these
periods
need
to
be
refined
for
your
situation.

Quantity
Used
per
Acre
This
field
is
required
only
for
methyl
bromide.
However,
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.
B
C
D
E
Quantity
Used
per
Acre
Units
(
lbs,
hours,
etc)
Unit
Cost
($)
Total
Cost
per
Acre
($)

Single
Crop:
$
10,408.33
Double
Crop:
$
12,252.52
Constant
Cost
per
Acre
($)
Cost
per
Unit
of
Yield
($)
Yield
Total
Cost
per
Acre
($)

Single
Crop
4,096.40
$

Single
Crop
6,123.04
$
Other
Costs
Total
Harvesting
Costs
Labor
Hauling
Material
Grading
/
Packing
/
Storage
Harvest
Operations
Labor
(
manual)

Fuel
/
Machine
Labor
Other
Costs
Herbicide
Fungicide
Nematicide
Irrigation
Seed
/
Seedlings
Fertilizer
/
Soil
Amendments
Pesticides
Insecticide
Cultural
Operations
application
Irrigation
Other
costs
Land
preparation
Fumigation
product
(
methyl
bromide)
Pre­
plant
Operations
­­
Total
Costs
Alternative:
Telone
C35
+
chloropicrin
+
Devrinol
+
Goal.

Operation
/
Input
Worksheet
3­
B(
1).
Alternatives
­
Changes
in
Operating
Costs
A
EPA
Form
#
7620­
18a
Pre
Plant
Harvest
costs
may
likewise
be
calculated
as
costs
per
acre
(
Column
B)
plus
variable
costs
per
unit
of
yield
(
Column
C)
times
yield
(
Column
D).

See
Strawberry
Enterprise
Budget
Worksheets
included
in
Appendix
II
of
the
narrativ
Total
Packing,
Selling
and
Related
Overhead
OMB
Control
#
2060­
0482
Double
Crop
7,267.60
$

Double
Crop
7,736.08
$
Total
Harvesting
Costs
EPA
Form
#
7620­
18a
Pre
Plant
Total
Packing,
Selling
and
Related
Overhead
Alternative:

A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)
B
(
3)
C
(
3)
D
(
3)
E
(
3)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
Fumigation
product
application
Irrigation
Seedlings
Other
costs
Cultural
Operations
Fertilizer/
soil
amendments
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
Labor
(
manual)

Fuel/
machine
labor
Other
costs
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Picking/
hauling
Material
Grading/
packing
Other
costs
OMB
Control
#
2060­
0482
Worksheet
3­
B(
2).
Alternatives
­
Changes
in
Operating
Costs
for
Perennial
Crops
PRE
PRODUCTION
YEARS
_______
INITIAL
PRODUCTION
YEARS
_____
FULL
PRODUCTION
YEARS
_____

[
Insert
Alternative
]
EPA
Form
#
7620­
18a
Pre
Plant
1.
1
4
2
5
3
2.
1
4
2
5
3
3.
1
4
2
5
3
4.

5.

6.
Yes
x
No
7.
Yes
x
No
8.

x
From:

x
To:

9.

Years
Amount
($)
1993­
2003
$
1.1M
1993­
2003
>$
2
M
10.
>$
3
million
Cost
11.
Will
economic
impacts
be
measured?
fosthiazate
Tarpaulin
(
High
Density
Polyethylene)

Other
depends
on
specific
study
depends
on
specific
study
Will
yield/
quality
loss
be
measured?
Chloropicrin
Solarization
trifloxysulfuron
sodium
Telone
Also,
as
per
Orlando
Workshop
discussions
on
June
24,
2003,
this
question
does
not
apply
to
soil
fumigation
petitions.
effective
alternative
is
made
available
that
is
technically
and
economically
feasible.
Currently,
there
is
no
program
to
Telone
application
methodologies
__
98_%
methyl
bromide,
__
2__%
chloropicrin
_
67_%
methyl
bromide,
_
33_%
chloropicrin
Virtually
Impermeable
Film
(
VIF)

Non­
Chemical
Methods
(
please
specify)
Worksheet
4.
Future
Research
Plans
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
You
may
use
this
worksheet
to
describe
all
future
plans.

Identify
the
top
3
to
5
target
pests
for
your
research.
Sting
Nematodes
Nutsedge
Root­
Knot
Nematodes
Provide
a
list
of
alternative
chemicals
or
cultural
practices
that
have
been
tested.
Phytophthora
Crown
Rot
Carolina
Geranium
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?
VIF
Technology
Metam
Sodium
transition
to
that
doesn't
have
excessive
monetary
risks,
unpredictability,
and
production
timing
issues
and
conflicts
Also
see
Appendix
II
­
B
­
1,
CUE
#
02­
0054,
and
Appendices
I
­
A,
I
­
B.

What
would
be
the
best
currently
available
alternative
if
methyl
bromide
were
not
available?
Currently,
the
best
alternative
has
been
a
strategy
of
applying
1,3­
dichloropropene
broadcast,
followed
3
­
4
weeks
later
Prioritize
the
alternative
chemicals
or
cultural
practices
to
be
tested.

Iodomethane
VIF
Technology
Formulation
Changes
Grant
requests
made
to
USDA,
EPA,
state,
or
other
funding
group.
See
research
summaries
in
CUE
#
02­
0053
and
current
application
narrative.
Investment
with
an
additional
application
of
chloropicrin
plus
Devrinol
plus
Goal
made
to
the
bed
before
laying
plastic.

Please
provide
an
overview/
timeline
of
the
plan
to
transition
away
from
using
methyl
bromide.
The
Florida
strawberry
industry
will
transition
away
from
dependency
from
methyl
bromide
as
soon
as
an
efficacious,
cos
FFVA/
FFVREF
Other
total
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide?
Formulation
Changes
(
please
specify)

(
check
all
that
apply)

Cultural
Practices
(
please
specify)
Other
Pesticides
(
please
specify)

Grower
In­
Kind/
Field
Plots
What
is
the
cumulative
amount
spent
and
the
types
of
contributions
this
consortium
has
made
to
fund
research
to
develop
alternatives
to
methyl
bromide
since
1992?
(
e.
g.
consortium
dues,
direct
research
funding,
etc.)

Name
of
Organization
/
Research
Institution
OMB
Control
#
2060­
0482
(
Describe
each
investment
and
its
associated
costs.
e.
g.
specialized
machinery,
etc.)

Refer
to
Appendix
1
Refer
to
Appendix
1
EPA
Form
#
7620­
18a
Pre
Plant
1.

2.

3.

4.
2005
5.
2005
6.

2006
1,278,000
lbs.
7,100
2007
1,278,000
lbs.
7,100
Not
Technically
Feasible
Not
Economically
Feasible
For
EPA
Use
Only
ID
#
_______________
SECTOR
__________________________

Worksheet
5.
Application
Summary
This
worksheet
will
be
posted
on
the
web
to
notify
the
public
of
requests
for
critical
use
exemptions
beyond
the
2005
phase
out
for
methyl
bromide.
Therefore,
this
worksheet
cannot
be
claimed
as
CBI.

Consortium
Name:
Florida
Fruit
and
Vegetable
Association
Location:
Florida
Crop:
Strawberries
Pounds
of
Methyl
Bromide
Requested
1,278,000
lbs.

Area
Treated
Acres
No
assurances
that
issues
associated
with
potential
alternatives
will
be
resolved,
or
that
the
currently
described
best
available
alternative
will
provide
economically
or
technically
feasible
long­
term
solutions.
Acres
Treated
with
Methyl
Bromide
7,100
Acres
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

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

Potential
Alternatives
Reasons
See
CUE
#
02­
0053
See
CUE
#
02­
0053
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
82
Fumigation
cycle:

Year:

Comparable
data:

2­
year
example:

Other
beneficiary
example
Crop
cycle
change
example:

Crop
Grouping
EPA
Form
#
7620­
18a
The
period
of
time
between
methyl
bromide
fumigations.

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

In
order
to
compare
revenues
and
costs
with
and
without
methyl
bromide,
data
on
alternatives
for
pest
control,
yields,
revenues,
and
costs
must
be
for
the
same
time
interval
as
the
methyl
bromide
fumigation
cycle.
If,
however,
quantitative
data,
is
not
available
for
the
entire
fumigation
cycle,
then
to
be
comparable,
the
quantitative
data
for
the
alternatives
should
cover
the
same
portion
of
the
fumigation
cycle
as
the
quantitative
data
for
methyl
bromide,
and
the
rest
of
the
cycle
should
be
discussed
in
the
comments
sections.

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

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

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

The
applicant
can
group
simliar
crops
together
if:
(
i)
Crops
would
experience
similar
yield
and
quality
losses
in
the
absence
of
methyl
bromide;
and
(
ii)
Crops
are
grown
on
the
same
fumigation
and
cultivation
cycle
with
similar
operating
costs.
For
example,
nursery
crops
including
various
flower
or
tree
species
can
be
aggregated,
with
average
yields
per
acre
and
prices.
However,
if
crops
are
distinctly
different
in
revenues
and
operating
costs,
or
the
cycles,
the
applicant
may
want
to
present
yield,
price
and
operating
costs
for
each
crop
separately
and
also
indicate
the
proportion
of
land
area
allocated
to
each
crop.
Definitions:
OMB
Control
#
2060­
0482
Pre
Plant
