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

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

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

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

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
STATE
CONTACTS
HOW
DO
I
APPLY?

OMB
Control
#
2060­
0482
States
that
have
agreed
to
participate
in
the
exemption
process
are
listed
on
EPA's
website
at
www.
epa.
gov/
ozone/
mbr/
cueqa.
html
Worksheet
4.
Alternatives
­
Research
Plans
Worksheet
5.
Additional
Information
Fumigation
Cycle
Climate
Zone
Map
Worksheet
6.
Application
Summary
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Revenue
3­
D.
Alternatives
­
Other
Operating
Costs
Research
Summary
Worksheet
Example
Research
Sum
(
Summary)
Worksheet
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
2­
F.
Methyl
Bromide
­
Fixed
and
Overhead
Costs
Worksheet
3.
Alternatives
­
Feasibility
of
Alternatives
to
Methyl
Bromide
3­
A.
Alternatives
­
Technical
Feasibility
Please
contact
your
local,
state,
regional
or
national
commodity
association
and/
or
state
representative
agency
to
find
out
if
they
plan
on
submitting
an
application
on
behalf
of
your
commodity
group.

2­
B.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Revenue
1997­
2000
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Revenue
2001
2­
D.
Methyl
Bromide
Use
and
Costs
for
2001
INSTRUCTIONS
Each
worksheet
number
corresponds
to
the
tab
number
in
the
electronic
version
of
the
application.
Instructions
specific
to
each
worksheet
are
provided
at
the
top
of
each
sheet.
A
header
row
is
included
on
each
worksheet
to
include
an
application
ID
number
that
EPA
will
assign.
You
may
either
complete
an
electronic
(
Microsoft
Excel)
or
a
printed
version
of
the
application.
Please
fill
out
each
form
or
worksheet
in
the
application
as
completely
as
possible.
If
you
are
completing
the
printed
version
and
need
extra
space
you
may
attach
additional
sheets
as
needed.
Additional
information
may
be
available
from
your
local
state
department
of
agriculture
or
at
the
sites
listed
below
or
by
calling
1­
800­
296­
1996.

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

If
a
consortium
is
applying
for
multiple
methyl
bromide
users,
the
economic
data
should
be
for
a
representative
or
typical
user
within
the
consortium
unless
otherwise
noted.
If
economic
or
technical
factors
(
such
as
size
of
the
farm)
affecting
the
ability
of
this
"
representative
user"
to
use
alternatives
are
significantly
different
than
other
users
in
the
consortium,
more
than
one
application
should
be
submitted
to
reflect
these
differences.
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
2­
A.
Methyl
Bromide
Use
1997­
2000
(
i)
The
specific
use
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
that
use
would
result
in
a
significant
market
disruption;
and
(
ii)
There
are
no
technically
and
economically
feasible
alternatives
available
to
the
user
that
are
acceptable
from
the
standpoint
of
environment
and
health
and
are
suitable
to
the
crops
and
circumstances
of
the
nomination
 "

WHO
APPLIES?

SECTIONS
OF
WORKBOOK
The
information
provided
by
you
in
this
application
will
be
used
to
evaluate
the
requested
methyl
bromide
use.
The
U.
S.
and
other
countries
that
are
parties
to
the
Montreal
Protocol
On
Substances
That
Deplete
The
Ozone
Layer
decided
that:
"
a
use
of
methyl
bromide
should
qualify
as
"
critical"
only
if
the
nominating
Party
determines
that:
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
IS
MY
INFORMATION
CONFIDENTIAL?

WHEN
IS
THE
INFORMATION
NEEDED?

1­
800­
296­
1996
phone:
(
202)
564­
9410
If
you
have
general
questions
about
this
application
call:

Stratospheric
Ozone
Hotline
Methyl
Bromide
Critical
Use
Exemption
Global
Programs
Division
Global
Programs
Division,
Mail
Code
6205J
1200
Pennsylvania
Ave,
NW
501
3rd
St.
NW
Washington,
DC
20001
Washington,
DC
20460­
0001
Address
for
applications
being
sent
by
courier
or
non­
U.
S.
Postal
overnight
express
delivery
to
EPA:

US
Environmental
Protection
Agency
(
When
submitting
an
application
electronically,
you
should
also
print
a
hard
copy,
sign
the
copy,
and
submit
it
by
mail)

Mailing
Address
for
applications
being
submitted
by
mail
directly
to
the
EPA:
US
Environmental
Protection
Agency
Methyl
Bromide
Critical
Use
Exemption
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
respo
This
application
must
be
postmarked
to
the
EPA
address
below
no
later
than
120
days
after
the
Notice
was
published
in
the
Federal
Register
requesting
critical
use
exemption
applications.

Electronic
Address
for
applications:

methyl.
bromide@
epa.
gov
HOW
CAN
I
RECEIVE
ADDITIONAL
INFORMATION?
WHERE
DO
I
SUBMIT
THE
APPLICATION?
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
1
To
add
additional
blank
worksheets
in
the
Excel
file,
go
to
the
menu
line
at
the
top
of
the
worksheet
and
select
"
Insert"
then
"
worksheet"

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Navigating
between
worksheets
Printing
worksheets
1.

2.

3.

4.

Light
20%
Medium
50%
Heavy
30%

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

5.

6.
Specialty
(
check
one)

7.
agronomic
x
8.
economic
x
9.
Daytime
phone
10.
FAX
11.

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

12.
agronomic
x
13.
economic
x
14.
15.
FAX
16.
James
W.
Wells
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Sacramento,
CA
95814
Nursery
tree
stock
is
grown
in
the
Sacramento
and
San
Joaquin
valleys
for
several
reasons
including
ideal
climate,
soil
type,
and
sufficient,
reliable
water.
These
areas
receive
enough
deep
chilling
hours
to
allow
the
trees
to
go
dormant
while
at
the
same
time
not
receive
such
extreme
chill
such
that
frost
protection
is
required.
The
Mediterranean
climate,
with
its
long
growing
period
and
dry
summer
temperatures
is
extremely
conducive
to
tree
growth,
both
upper
canopy
and
root
development.
Plentiful,
high
quality
water
is
available
for
use
in
nurseries.
Both
well
water
and
surface
water
are
used
for
irrigation.

910
K
Street,
Suite
325
Sacramento,
CA
95814
jwells@
exponent.
com
916.443.3071
916.443.2793
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.

The
annual
rainfall
in
this
region
ranges
from
10
to
25
inches
per
year
with
soil
varying
from
light
to
heavy.
Generally,
rainfall
follows
soil
type,
meaning
that
the
further
south
you
go,
the
less
rain
you
receive
and
the
lighter
the
soils
in
general.

Calif.
Assn.
of
Nurserymen
Deciduous
Fruit
&
Nut
Tree
CUE
Soil
Type:

Organic
Matter:
Location
California's
tree
nursery
growers
are
concentrated
principally
in
the
Sacramento
and
San
Joaquin
Valleys
with
limited
production
in
Lake
County.

Deciduous
tree
nursery
stock
includes,
but
is
not
limited
to,
(
1)
Fruit;
i.
e.,
peaches
(
cling
and
freestone),
prunes,
nectarines,
cherries,
plums,
apples,
pears,
Asian
pears,
apricots,
ornamental
pears,
ornamental
peach,
ornamental
plum,
and
ornamental
cherry
(
2)
Nut,
i.
e.
almonds,
walnuts,
pistachios,
pecans,
and
chestnuts.

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
The
Sacramento
and
San
Joaquin
valleys
are
generally
comprised
of
deep
(
3
to
6
feet),
well­
drained
A
and
B
soils
which
allow
for
good
water
percolation
and
very
good
root
development
which
are
necessary
for
the
production
of
commercially
acceptable
nursery
stock.
Soils
are
generally
fertile,
with
ideal
pH
and
lack
of
salinity.
Review
of
the
Soil
Conservation
Service
survey
maps
indicate
that
much
of
the
soil
throughout
the
valley
is
sandy
loam.
However,
depending
on
their
location
in
the
valley,
soils
range
from
sandy
clay
loam
to
sandy
loam
to
silt
loam
and
clay
loam.

Contact
name
Address
916.443.3071
916.443.2793
E­
mail
Anne
Downs
adowns@
exponent.
com
910
K
Street,
Suite
325
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
495,000
lbs.

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

19.

20.

20a.

because
of
the
significant
difference
in
yield
per
acre
and
price
received
per
tree
when
compared
to
other
nursery
tree
stock.

One
nursery
grower
represented
by
the
consortium
grows
in­
field
exclusively
for
home
and
garden
and
ornamental
use.

Separate
worksheets
are
provided
for
this
grower
when
applicable.

OMB
Control
#
2060­
0482
If
applying
as
a
consortium
for
many
users
of
methyl
bromide,
please
define
a
representative
user
.
Define
exactly,
issues
such
as
size
of
the
operation
(
acres
treated
with
methyl
bromide
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications),
whether
the
representative
user
owns
or
rents
the
land
or
operation,
intensity
of
methyl
bromide
use
(
treat
regularly
or
only
when
pest
reaches
a
threshold),
pest
pressure,
etc.
Target
Pest(
s)
or
Pest
Problem(
s):
(
Be
as
specific
as
possible
about
the
species
or
classes
of
pests
relevant
to
the
feasibility
of
alternatives.)
If
a
consortium
is
submitting
this
application,
the
data
for
question
17
and
17a.
should
be
the
total
for
the
consortium.

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

Are
you
requesting
methyl
bromide
for
additional
years
beyond
2005?

acres
acres
2007
How
much
active
ingredient
(
ai)
of
methyl
bromide
are
you
requesting
for
2005?

Most,
but
not
all,
growers
produce
a
range
of
different
species.
The
majority
of
nursery
growers
produce
trees
for
commercial
planting
grow
in
the
soil
("
in­
field")
and
use
methyl
bromide.
Walnuts
are
treated
separately
The
representative
user
grows
multiple
species
of
trees;
1
year
trees,
2
year
trees,
walnuts
and
seedlings.
The
representative
grower
owns
most
of
all
of
the
ground
on
which
the
stock
is
produced.
Methyl
bromide
is
used
for
each
crop
cycle.

(
Nursery
must
be
free
of
commercially
important
pests
to
be
sold
for
commercial
plantings).
It
is
estimated
that
95%
of
the
deciduous
nursery
gr
Explain
why
this
user
represents
the
typical
user
in
the
consortium.

Most
nursery
stock
producers
own
their
land.
All
nursery
growers
must
treat
each
crop
cycle
to
meet
certification
requirements.
1650
Yes.
No
indication
that
acceptable
alternatives
will
be
in
place
sufficient
to
meet
certification
requirements.
1650
2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
495,000
Area
to
be
Treated
1650
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.

Year
Nematodes,
Crown
Gall,
Verticillium
Wilt,
Pythium,
Fusarium,
Rhizoctonia,
Phytophthora
If
a
consortium
is
submitting
this
application,
the
data
below
should
be
the
total
for
the
consortium.

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.
For
EPA
Use
Only
ID#

Common
Purslane,
Lambsquarter,
Little
Mallo,
Spurge,
Watergrass,
Field
Bindweed,
Redroot
Pigweed,
Nutsedge,
Ragweed,

Burclover,
Oxalis,
Fescue,
Johnson
Grass,
Bermuda
Grass
495,000
Unit
of
Area
Treated
How
much
area
will
this
be
applied
to?
Please
list
units.
Application
for
a
Critical
Use
Exemption
for
Methyl
Bromide
California
Association
of
Nurserymen
NARRATIVE
The
tree
nurseries
in
California
grow
a
variety
of
tree
crops
including
almonds,
walnuts,
pistachios,
pecans,
chestnuts,
peaches
(
both
cling
and
free
stone),
prunes,
nectarines,
cherries,
plums,
apples,
pears,
Asian
pears,
apricots,
and
ornamental
pear,
peach,
plum
and
cherry.
About
95%
of
the
trees
are
fruiting
varieties
sold
mainly
to
commercial
fruit
producers,
while
the
remaining
5%
of
the
trees
are
flowering
varieties
sold
for
landscaping
purposes.
Planting
stock
is
sold
to
either
commercial
fruit
producers
or
home
gardeners
with
most
of
the
nurseries
selling
in
both
markets.
However,
the
vast
majority
of
nursery
stock
is
produced
for
commercial
planting
and
approximately
95%
of
the
deciduous
nursery
stock
produced
in
California
is
sold
in
California.
Growers
of
trees
for
ornamental
and
home
garden
markets
are
also
represented
by
the
consortium.

Trees
are
grown
in
the
Sacramento
and
San
Joaquin
Valleys.
The
annual
rainfall
in
this
region
ranges
from
12
to
25
inches
per
year
with
soil
texture
varying
from
light
to
heavy.
The
sandy
soils
tend
to
be
in
the
southern
end
of
the
San
Joaquin
Valley,
while
the
northern
counties
have
heavier
soils.
Nurseries
are
located
in
these
areas
due
to
the
fact
that
the
climatic
conditions
in
these
areas
are
ideal
for
nursery
tree
production.
Nursery
locations
receive
enough
deep
chill
hours
to
allow
the
trees
to
go
dormant
but
do
not
receive
extreme
chill,
so
that
frost
control
is
rarely
required.
The
Mediterranean
climate,
with
dry
summer
temperatures
is
also
conducive
to
tree
growth,
both
upper
canopy
and
root
development.
The
deep
soils
(
3
to
6
feet)
allow
for
good
water
percolation
and
also
permit
the
excellent
root
development
that
is
necessary
for
production
of
superior
nursery
stock.
There
is
plentiful,
high
quality
water
available
for
use
in
the
nurseries.
Well
water
as
well
as
surface
water
is
used
for
irrigation.

Tree
nursery
operations
range
from
40
to
over
1500
acres.
The
median
operation
in
the
California
consortium
is
between
200­
300
acres.
While
some
nurseries
specialize
in
a
specific
tree
crop,
most
of
the
nurseries
grow
and
sell
a
variety
of
different
trees.
Nursery
stock
is
grown
on
a
cropping
system
that
includes
crop
rotation
or
cover
cropping
between
tree
production
cycles.
Thus,
not
all
of
the
nursery
is
in
tree
production
in
a
given
year.
The
tree
production
cycle
can
be
anywhere
from
a
single
year
to
several
years
depending
on
the
type
of
tree
crop
being
produced.
Most
nurseries
own
the
ground
on
which
their
nursery
stock
is
produced.
Very
little
nursery
ground
is
leased.
Actual
nursery
production
of
trees
takes
from
one
to
four
years
in
the
ground
depending
on
the
type
of
tree
being
produced
(
almonds
take
one
year,
walnuts
at
least
two),
and
the
size
of
tree
needed
(
larger
trees
take
longer
to
grow).
The
most
common
cycle
is
for
the
tree
crop
to
be
in
the
ground
for
either
one
or
two
years.
A
typical
nursery
cycle
(
Figure
1)
starts
by
digging
out
the
current
tree
crop
(
for
sale)
then
planting
a
cover
crop
for
one
or
two
years,
followed
by
replanting
with
a
tree
crop.
In
order
to
prepare
the
soil
for
a
tree
crop,
the
fields
are
disked,
deep
ripped,
leveled
and
then
fumigated
to
meet
certification
standards
(
see
Appendix
1).
The
fumigation
is
contracted
to
one
of
two
major
fumigation
companies.
A
shank
applied,
broadcast
fumigation
of
75%
methyl
bromide,
25%
chloropicrin
(
300
lbs
per
acre
MeBr)
covered
with
high
barrier
tarp
is
used
by
the
majority
of
nursery
growers.
The
fumigation
is
carried
out
in
September
and
planting
begins
in
October.
Planting
can
continue
though
January.

Figure
1.
Typical
Growing
Cycle
for
Nursery
Tree
Production
Year
Season
Process
Year
1
October
through
December
Dig
Previous
Tree
Crop
Year
2
February
Plant
Cover
Crop
Summer
Fallow
field
October
Plant
Cover
Crop
Year
3
Spring
Harvest
Cover
Crop
or
Incorporate
as
Green
manure
August
or
September
Fumigate
October
Plant
seed
for
rootstock
October
through
November
Plant
Hard
wood
rootstock
Year
4
April
or
May
Cut
Budwood,
rootstocks
are
budded
Summer
Prune,
train,
Stake
October
If
the
tree
is
a
one
year
tree,
it
is
harvested
October
If
the
tree
was
harvested,
plant
cover
crop
Year
5
October
If
the
tree
was
not
harvested,
it
is
grown
for
another
year,
then
harvested
Open
pollinated
peach
seed
(
which
is
true
to
type
for
plant
vigor)
is
used
for
the
majority
(
85%)
of
the
stone
fruit
rootstock
(
including
almonds).
Nurseries
produce
their
own
peach
seed
for
the
rootstock
planting.
The
remaining
15%
of
the
rootstock
are
produced
on
hard
wood
cuttings.
The
hard
wood
used
as
a
rootstock
varies
somewhat
but
is
mainly
plum
wood
cuttings
which
are
either
stored
to
produce
callus
and
then
planted
in
the
field
in
January
or
February
or
directly
planted
in
the
field
without
callus
production
in
October
or
November.

In
spring,
the
rootstock
begins
to
grow
and
is
ready
for
budding.
The
nurseries
then
decide
what
wood
is
necessary
for
the
budding
process.
Budwood
can
originate
from
a
variety
of
sources:
1)
A
mother
block
orchard
maintained
by
the
nursery.
2)
Trees
grown
in
a
cooperator's
field
3)
Bud
wood
can
be
purchased
from
the
clean
stock
program
at
UC
Davis,
Foundation
Plant
Material
Service.
4)
Budwood
can
be
cut
out
of
commercial
orchards.

After
tree
rootstock
is
budded,
the
budwood
begins
to
grow;
it
is
pruned,
trained
and
staked.
Each
of
these
processes
requires
extensive
hand
labor.
Within
the
first
year,
each
tree
is
handled
around
fifteen
times
for
various
reasons.
By
mid
to
late
October,
the
trees
are
near
eight
feet
tall
and
around
5/
8
inch
diameter
(
the
girth
is
measured
two
inches
above
the
bud
union).
Trees
are
dug
with
U
blades
on
tractors,
digging
18­
24
inches
deep.
Although
the
state
or
county
biologists
inspect
for
nematodes
during
the
growing
season,
another
inspection
occurs
at
digging
for
nematodes
and
general
cleanliness
of
stock.
The
trees
are
graded
to
determine
quality.
The
grade
is
determined
by
tree
diameter
(
caliper),
straightness
of
trunk,
quality
of
roots,
and
disease
and
pest
levels.
Trees
are
bundled
in
fives
or
tens
by
size.
These
bundles
are
heeled
into
sawdust
or
held
in
cold
storage
until
the
material
is
shipped
to
the
buyer.
Yield
is
determined
by
the
percent
dig
out
(
the
number
of
saleable
trees
versus
the
total
number
of
trees
planted
in
a
field).
Yield
is
also
determined
by
size
(
caliper)
as
measured
by
diameter
of
the
trunk
(
not
height
of
the
tree).

Irrigation
is
predominantly
by
sprinkler
but
can
also
be
either
furrow
or
drip
depending
on
location
and
water
availability.
Water
quality
is
generally
good
and
quantity
is
currently
not
a
problem.
Trees
are
sprayed
by
tractor
on
a
regular
basis,
mainly
for
insect
pests
such
as
thrips,
mites
(
spider,
two
spotted,
etc.),
and
lygus
as
well
as
several
other
less
common
insects.
A
good
fumigation
gives
a
growth
response
that
allows
for
an
initial
growth
spurt.
This
growth
response
helps
maintain
a
healthy
tree,
as
a
stronger
tree
is
better
able
to
handle
the
stress
induced
by
pathogens
and
pests.
A
healthier
tree
consequently
requires
a
fewer
number
of
sprays
during
the
season.
Since
stock
rarely
flowers
in
the
nursery,
pollen
borne
viruses
are
not
considered
a
problem.
Viruses
that
can
be
transmitted
through
budwood
are
problematic.
However,
many
nurseries
participate
in
a
certification
program
conducted
by
the
California
Department
of
Food
and
Agriculture,
that
test
for
bud­
transmitted
viruses.
Powdery
mildew
may
also
require
a
fungicide
treatment
at
some
point
in
the
growing
season.
Some
nurseries
use
Ridomil
and
Alliette
to
suppress
Phytophthora,
but
these
chemicals
do
not
prevent
or
cure
the
disease.
Whereas,
methyl
bromide
soil
fumigation
virtually
eliminates,
rather
than
suppresses
soil
borne
pathogens
such
as
Phytophthora.

California
nurseries
contend
with
a
number
of
pests
and
diseases
(
Table
1)
as
well
as,
numerous
weeds
(
Table
2)
that
must
be
controlled
in
order
to
produce
clean
nursery
stock.
Nursery
stock
is
inspected
by
county
Agricultural
Commissioners
under
the
supervision
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
and
it
must
be
"
found
free
of
especially
injurious
pests
and
disease
symptoms"
in
order
to
qualify
for
a
CDFA
Nursery
Stock
Certificate
for
Interstate
and
Intrastate
Shipments.
California
nursery
regulations
require
specific
fumigation
protocols
to
be
used
in
order
to
control
nematodes,
pathogens
and
weeds
in
different
soil
and
moisture
settings.
If
there
is
a
history
of
nematodes
in
the
field,
no
known
history
of
the
field,
or
if
the
soil
has
a
moderate
to
heavy
clay
content,
methyl
bromide
is
currently
the
only
approved
fumigation.
In
some
other
cases,
Telone
II
meets
certification
guidelines.
If
fumigation
is
not
used
in
the
nursery,
a
nematode
sampling
system
is
imposed
by
CDFA.
The
sampling
procedure
is
cost
prohibitive
and,
if
even
one
nematode
is
found
within
a
100­
foot
grid,
all
trees
within
the
grid
must
be
destroyed
resulting
in
the
loss
of
one
or
two
years
work
and
income.

Pest
or
Pathogen
Causal
Organism
Root
Knot,
Lesion
and
Stubby
Root
Nematodes
Meloidogyne
spp.,
Pratylenchus
spp.,
Trichodorus
sp,
Xiphinema
spp.,
Criconemelia
sp.

Crown
Gall
Agrobacterium
tumefasciens
Wilt
Verticillium
spp.,
Fusarium
spp.

Root
Rot,
Damping
Off,
Soft
Rot
Phythium
sp.,
Rhizoctonia
sp.,
Phytophthora
spp.,
etc.
Table
1.
Pest
and
Insect
Problems
in
the
Tree
Nurser
Table
2.
Common
Weeds
in
the
Tree
Nursery
Industry
Common
Name
Scientific
Name
Common
Purslane
Portulaca
oleracea
Lambsquarter
Chenopodium
album
Little
Mallow
Malva
rotundifolia
Spurge
Euphorbia
humistrata
Watergrass
Heteranthera
dubia
Field
bind
weed
Convoulus
arvensis
Redroot
Pigweed
Amaranthus
retroflexus
Nutsedge
Cyperus
spp.
Rotundus
(
purple)
or
esculenlus
(
yellow)

Ragweed
Ambrosia
psilostachya
Burclover
Medicago
hispidus
Oxalis
Oxalis
spp.
Fescue
Festuca
megalura
Johnson
grass
Sorghum
halepense*

Burmuda
Grass
Cynodon
dactylon
*

*
Considered
noxious
weeds
by
the
California
Department
of
Food
and
Agriculture.

The
key
pest
of
deciduous
tree
nursery
stock
is
nematode.
Soil
must
be
treated
to
a
depth
of
5
feet
to
ensure
clean
stock
that
meets
certification
standards.
In
heavier
soils,
methyl
bromide
is
the
only
fumigant
proved
to
be
effective
at
this
depth.
In
order
for
Telone
II
to
be
effective,
the
soil
cannot
contain
more
than
12%
moisture.
This
moisture
level
cannot
be
achieved
deep
in
heavy
soils
and,
depending
on
rainfall,
may
not
always
be
achievable
in
medium
soils.
It
is
estimated
that
30%
of
the
deciduous
tree
nursery
growing
areas
in
California
are
in
silt
or
clay
loam
soils.
Of
the
70%
in
sand
or
sandy
loam
soils,
about
one­
half
will
require
fumigation
with
methyl
bromide
due
to
the
inability
to
achieve
12%
moisture
in
any
given
year.
Therefore,
up
to
65%
of
the
deciduous
tree
nursery
ground
may
require
fumigation
with
methyl
bromide
to
meet
certification
requirements,
especially
in
wet
years.
Depending
on
the
growing
area,
limitations
on
Telone
use
(
Township
Caps),
imposed
by
the
California
Department
of
Pesticide
Regulation
may
further
limit
the
use
of
Telone
II,
the
only
alternative
treatment
that
meets
certification
requirements.

Weed
control
will
be
a
special
problem
if
methyl
bromide
fumigation
is
not
used
in
the
nursery
fields.
Winter
annuals,
summer
annuals
and
perennials
are
all
problems
for
the
nurseries.
None
of
the
current
pre
or
post
emergent
herbicides
can
control
the
entire
spectrum
of
weeds
in
the
tree
nursery
crops.
Combinations
of
several
herbicides
may
control
most
of
the
weeds,
but
not
all
of
the
herbicides
are
labeled
for
nursery
use.
High
cost
of
applying
multiple
herbicides
is
also
a
factor.
In
addition,
there
is
a
significant
risk
of
plant
damage
or
failure
when
using
herbicide
"
cocktails".
Pre­
emergent
herbicides
are
especially
problematic
and
most
labels
have
special
precautions
for
nursery
use.
Any
chemical
that
affects
the
root
growth
of
the
trees
is
especially
detrimental
to
the
nursery
industry
as
one
of
the
characteristics
used
to
grade
product
quality
is
root
growth.

The
Methyl
Bromide
Technical
Options
Committee
of
the
United
Nations
Environment
Programme
recognized
the
dilemma
facing
the
nursery
industry
in
their
1998
report
stating
" 
it
is
likely
that
MB
will
be
required
for
some
time
to
solve
replant
problems
that
occur
in
areas
where
the
same
land
is
used
repeatedly
due
to
limited
land
availability
and
for
producing
pest­
free
propagation
materials"
(
UNEP
1998
Assessment
of
Alternatives
to
Methyl
Bromide).

It
should
be
noted
that
the
total
number
of
acres
treated
for
this
consortium
may
be
underestimated
in
the
tables
that
follow.
Actual
numbers
are
difficult
to
determine
and
100%
of
the
growers
in
the
consortium
did
not
report
methyl
bromide
use
numbers
as
of
the
date
of
this
application.
The
number
of
pounds
of
methyl
bromide
requested
and
the
estimated
number
of
acres
to
be
treated
in
2005
have
been
adjusted
upward
by
10%
to
account
for
the
lack
of
100%
reporting.
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
470
136,300
290
448
116,330
259
629
168,781
268
456
123,272
270
75%
methyl
bromide,
25%
chloropicrin
1140
339,000
297
1113
327,258
294
1097
321,600
293
1123
334,750
(
298)

67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
1610
475300
295
1561
443588
284
1726
490381
284
1579
458022
290
Comments:

OMB
Control
#
2060­
0482
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.

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

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

1997
1998
1999
For
EPA
Use
Only
ID#

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

1997
11,407
trees/
acre
$
6.37
$
56,694.45
1998
Nursery
Stock
11,986
trees/
acre
$
6.24
$
59,249.86
1999
Nursery
Stock
14,669
trees/
acre
$
6.60
$
77,842.26
2000
15,051
trees/
acre
$
6.67
$
74,853.83
$
0.00
Total
Revenue
for
1997
$
56,694.45
Total
Revenue
for
1998
$
59,249.86
Total
Revenue
for
1999
$
77,842.26
Total
Revenue
for
2000
$
74,853.83
Average
Revenue
Per
Year
$
67,160.10
Comments:
Nursery
Stock
is
represented
by
1
&
2
year
deciduous
fruit
and
nut
trees,
as
well
as
seedlings.

OMB
Control
#
2060­
0482
Nursery
Stock
B
Nursery
Stock
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.

Col.
A:
Year
Col.
B:
Crop/
Commodity
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
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.
Year
Methyl
Bromide
was
Applied
Crop/
Commodity
Unit
of
Crop/
Commodity
Crop/
Commodity
Yield
Price
Revenue
1997
Fruit/
Nut
Nursery
each
tree
4568
$
8.03
36,681.04
1997
Planted
back
into
Flowering,
Shade
each
tree
4710
$
8.79
41,403.98
1998
Fruit/
Nut
Nursery
each
tree
4595
$
8.09
37,173.55
1998
Planted
back
into
Flowering,
Shade
each
tree
4723
$
8.81
41,609.63
1999
Fruit/
Nut
Nursery
each
tree
4571
$
8.13
37,162.23
1999
Planted
back
into
Flowering,
Shade
each
tree
4719
$
8.89
41,951.91
2000
Fruit/
Nut
Nursery
each
tree
4601
$
8.21
37,774.21
2000
Planted
back
into
Flowering,
Shade
each
tree
4763
$
8.93
42,533.59
Total
Revenue
for
1997
$
78,085.02
Total
Revenue
for
1998
$
78,783.18
Total
Revenue
for
1999
$
79,114.14
Total
Revenue
for
2000
$
80,307.80
Average
Revenue
Per
Year
$
79,072.53
Specialty
Deciduous
Fruit
and
Nut
Nursery
Grower
who
sells
exclusively
to
Home
and
Garden
For
EPA
Use
Only
ID#

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

Nursery
Stock
market
14,904
trees/
acre
$
6.24
$
70,634.94
Total
Revenue
$
70,634.94
Comments:

Nursery
Stock
is
represented
by
1
&
2
year
deciduous
fruit
and
nut
trees,
as
well
as,
seedlings.

OMB
Control
#
2060­
0482
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.

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.
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Area
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Acre
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

glue)
per
acre
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Acre
over
95%
methyl
bromide
75%
methyl
bromide,
25%
chloropicrin
300
$
2.58
$
195.00
$
665.00
1563
$
1,634.00
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
300
$
2.58
$
195.00
$
665.00
1563
$
1,634.00
Comments:

OMB
Control
#
2060­
0482
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.

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

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

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

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

Enter
the
actual
area
treated.
Note:
This
number
should
be
the
total
area
treated
by
all
users
in
the
consortium.
For
EPA
Use
Only
ID#

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Acre
Typical
Equipment
Used
Land
Preparation*
$
16.00
$
549.00
$
565.00
Irrigating
$
50.00
$
327.00
$
377.00
Fertilizers**
$
312.00
$
328.00
$
640.00
Labor***
$
15,435.00
Other
Pest
Control
$
2,353.00
Repairs/
Maint./
Shop/
Tools,
etc.
$
1,178.00
General
Expense
$
1,699.00
Total
Custom
per
Area
$
0.00
User
Total
per
area
$
22,247.00
*
Includes:
ripping,
discing,
bedding,

**
Includes
fertilizers,
manure
spreading
***
Includes
planting,
thinning,
weeding,
hand
defoliation,
budding,
tying,
grafting,
staking,
rogueing,
suckering,
etc.

OMB
Control
#
2060­
0482
Operation
Done
by
User
Worksheet
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

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

Do
not
include
methyl
bromide
costs.

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

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

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

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

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

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

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

Submit
crop
budgets
for
each
crop,
if
available.
You
may
submit
crop
budgets
electronically
or
in
hard
copy.
If
your
costs
are
significantly
different
than
the
crop
budgets,
please
explain
in
the
comments.
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
Land
Lease/
Land
Payments
$
2,175.00
Interest
$
1,500.00
Other
O.
H.
s
(
See
Comments)
$
36,073.00
Total
$
39,748.00
OMB
Control
#
2060­
0482
Comments:
Other
Overhead
includes,
but
is
not
limited
to,
office
salaries,
insurance,
utilities,
office
supplies,
purchase
of
seed
and
budwood,
equipment
and
buildings,
marketing,
distribution,
etc.

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

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

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,
(
4)

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

Please
describe
the
cost
in
more
detail.

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

Enter
the
cost
per
area
of
methyl
bromide
treated.

Enter
all
fixed
and
overhead
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Worksheet
Title
3­
A
Alternatives
­
Technical
Feasibility
This
form
is
used
to
obtain
information
on
the
chemical
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
that
are
registered
for
use
in
the
United
States,
as
well
as
the
non­
chemical
alternatives
identified
by
the
MBTOC.
Applicants
must
address
the
technical
feasibility
of
all
the
chemical
and
non­
chemical
alternatives
identified
on
the
list.

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

3­
C
Alternatives
­
Crop/

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

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

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

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

Worksheet
3.
Alternatives
­
Feasibility
of
Alternative
Pest
Control
Regimens
Enter
all
alternative
pesticides
and
pest
control
methods
(
and
associated
cost
and
yield
data)
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
fumigation
cycle
worksheet
for
a
comprehensive
definition.
Use
additional
pages
as
needed.

Alternative:
Study:

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

1a.
Full
use
permitted
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Please
see
Narratives
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
provided
by
the
Agency
and
explain
why
they
cannot
be
used
for
your
crop
and
in
your
geographic
area.
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,
second
research
study,
label
the
worksheet
3­
A(
1)(
b).
For
the
first
alternative,
third
research
study,
label
the
worksheet
3­
A(
1)(
c).
For
the
second
alternative,
first
research
study,
label
the
worksheet
3­(
A)(
2)(
a).
For
the
second
alternative,
second
research
study,
label
the
worksheet
3­(
A)(
2)(
b).

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

Please
see
Narratives
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.

Please
see
Narratives
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
7.

8.

OMB
Control
#
2060­
0482
For
EPA
Use
Only
ID#

Please
see
Narratives
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.
Please
see
Narratives
Please
see
Narratives
Please
see
Narratives
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
Please
see
Narratives
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
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
DE
FGH
I
J
K
L
MNO
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
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.

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]
Alternative:
1,3­
D,
1,3­
D
+
Metam
Sodium,
1,3­
D
+
Basamid
Worksheet
3A.

Alternative:
1,3­
D
1,3­
D
+
Chloropicrin
1,3­
D
+
Chloropicrin
+
Metam
Sodium
1,3­
D
+
Metam
Sodium
Studies:
Please
refer
to
Reference
List.

Section
I.
1
There
are
township
caps
for
1,3­
D
(
5,
10).
Several
of
the
counties
where
tree
nursery
crops
are
grown
would
be
affected
by
the
caps
(
5).

Section
II.

1
Studies
1­
13
and
23
are
not
on
EPA
website,
Studies
14­
22
and
24­
27
are
on
the
EPA
website.
2
Author:
various,
as
stated
above
3
Publication
date:
various
as
above.
4
Multiple
locations
as
per
studies
above.
5
1,3­
D,
and
1,3­
D
combinations
6
Yield
was
studied
for
fruit/
nut
trees
in
Study
#
2.
7
Effectiveness
of
1,3­
D
and
1,3­
D
combinations
compared
to
Methyl
Bromide
a.
Control
of
Nematodes.
In
tree
nursery
production,
studies
have
shown
control
of
nematode
is
necessary
at
the
99.9%
level
in
order
to
have
nursery
stock
free
of
nematodes
(
1,
2,
3)
as
mandated
in
the
California
Department
of
Food
and
Agriculture
certification
program
and
California
Nursery
Stock
regulations.
Since
tree
crops
are
deep
rooted,
the
control
of
nematodes
needs
to
be
at
least
five
feet
deep.
While
1,3­
D
has
been
shown
to
control
nematodes
in
shallow,
light
soils
in
some
instances
(
16),
this
is
not
always
the
case
(
21).
1,3­
D
does
not
control
nematodes
effectively
unless
the
soil
moisture
is
less
than
12%.
Soils
this
dry
are
difficult
to
achieve
at
a
depth
of
five
feet
(
1,2,3),
in
heavier
soils,
or
where
applications
must
be
made
after
in
heavy
rainfall
years
before
the
moisture
dissipates.
Studies
showed
that
soils
in
Davis,
California
that
had
not
been
irrigated
for
two
years
still
exceeded
12%
moisture
at
the
four­
foot
level
(
1).
Nematodes
at
multiple
sites
were
not
controlled
in
deeper
soils
with
1,3­
D
alone
or
1,3­
D
combinations
(
1,
2,
3)
for
some
of
the
heavier
soil
types
utilized
by
tree
nurseries.

b.
Control
of
Pathogens.
Pathogens
must
be
controlled
in
nursery
stock
in
order
to
prevent
the
spread
of
a
pathogen
through
out
the
area
receiving
the
nursery
stock.
While
1,3­
D
was
effective
in
controlling
Phytophthora
cactorum
to
a
depth
of
24
inches
(
equivalent
to
methyl
bromide)
in
some
situations
(
14),
this
is
not
always
the
case
(
4,
14).
1,3­
D
has
not
been
as
effective
as
methyl
bromide
in
controlling
Verticillium
dahliae
in
strawberry
nursery
fields
(
6,
14)
but
has
provided
adequate
control
in
fruit
production
fields
(
17).
The
1,3­
D
and
1,3­
D
combinations
have
been
compared
to
methyl
bromide
for
control
of
Oak
Root
Fungus
in
commercial
and
nursery
tree
crops.
1,3­
D
alone
only
gave
control
in
the
top
four
feet
while
methyl
bromide
gave
control
at
a
deeper
level
and
that
control
continued
to
be
effective
in
a
production
field
for
over
six
years.
Split
applications
of
1,3­
D
or
1,3­
D
in
combination
with
metam
sodium
or
basamid
did
not
improve
the
effectiveness
of
1,3­
D
against
Oak
Rood
Fungus,
Armillaria
mellea,
and
still
only
gave
control
at
a
depth
of
four
feet
or
less.

c.
Weed
Control.
1,3­
D
(
alone
or
in
combination)
has
shown
good
weed
control
in
some
situations
(
7,
8,
9,
14)
especially
with
the
use
of
VIF
tarp
vs.
standard
tarp.
Weed
populations
following
a
methyl
bromide
fumigation
were
lower
after
a
year
than
weed
populations
following
a
1,3­
D
(
or
1,3­
D
combination)
treatment
(
2).
The
species
of
weeds
also
shifted
from
predominately
clovers
(
after
methyl
bromine)
to
predominately
grasses
and
chickweed
(
after
1,3­
D).

d.
Effect
on
yield.
There
were
no
significant
differences
in
yield
for
first
and
second
year
tree
growth
in
trials
were
yield
was
measured
(
2,3).
However,
there
has
been
some
phytotoxic
affect
associated
with
1,3­
D
(
18,
21)
for
certain
commodities.

e.
Movement
of
1,3­
D
in
the
Soil
Profile.
1,3­
D
can
either
be
shank
or
drip
applied.
Shank
applied
material
had
a
low
rate
of
success
in
moving
material
deep
in
the
soil
in
heavier
soil
types
(
3).
Either
drip
or
drench
applied
1,3­
D
reduces
volatilization
of
the
product
(
3,
19).
However,
high
amounts
of
water
may
be
necessary
to
effectively
move
the
material
through
the
soil
profile
(
3,
19,
20).
Further
research
to
design
equipment
necessary
for
efficient
and
economic
placement
of
material
in
deep
soil
profiles
needs
to
be
conducted.

Conclusions.
In
all
the
above
studies
where
1,3­
D
has
been
shown
to
give
effective
control,
high
rates
of
the
product
were
used.
1,3­
D
or
1,3­
D
in
combination
is
being
used
successfully
in
some
California
nurseries
(
grower
communication).
Areas
where
1,3­
D
is
replacing
methyl
bromide
tend
to
have
lighter
soils
and
drier
climates.
Even
so,
in
heavy
rainfall
years,
growers
report
difficulty
in
achieving
the
requisite
12%
or
less
moisture
(
grower
communication).
Weed
problems
and
poor
performing
trees
have
been
reported
in
one
nursery
using
1,3­
D
in
2001,
although,
since
this
was
not
a
controlled
trial
other
factors
could
not
be
ruled
out
as
contributing
to
the
performance
problem.
However,
weeds
continue
to
be
a
problem
when
1,3­
D
is
used
on
a
large
scale
even
in
combination
with
Vapam
or
Basamid
(
grower
communications).
Labeled
soil
moisture
requirements
are
an
impediment
to
the
herbicidal
activity
of
MITC
generators
(
2,
M.
McKenry
personal
communication).
Difficulties
in
applying
the
material
in
sub­
optimal
conditions
and
poor
performance
in
medium
and
heavy
soils
restrict
the
use
of
this
compound
as
a
viable
alternative
in
many
cases.
Further
studies
with
multiple
rates
and
different
application
methods
and
tarp
types
are
needed
to
see
if
the
overall
performance
of
1,3­
D
across
a
wider
environmental
range
can
be
improved.
Restrictions
on
the
total
amount
of
1,3­
D
that
can
be
used
on
all
crops
in
a
given
area
(
Township
Caps),
also
may
significantly
limit
the
utility
of
1,3­
D
as
a
methyl
bromide
replacement
for
deciduous
nursery
in
some
locations
(
5,
10).

Reference
List:

1)
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries.
Michael
McKenry,
Report
to
DPR
2000.
2)
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Soil
Fumigation
at
Commercial
Fruit
and
Nut
Tree
Nurseries.
Michael
McKenry,
Report
to
DPR
2001.
3)
The
Replant
Problem
and
Its
Management.
Michael
McKenry,
Catalina
Publishing,
1999.
4)
Strategies
for
Management
of
Phytophthora
on
California
Strawberries,
G.
T.
Browne,
Report
to
California
Strawberry
Commission,
March
19,
2002
5)
Impact
of
Township
Caps
on
1,3­
D
Use
in
California.
Tom
Trout.
California
Strawberry
Commission
Pink
Sheet
June
11,
2001.
6)
Management
of
Verticillium
Wilt
in
Strawberry
Nurseries.
Tom
Gordon.
Report
to
California
Strawberry
Commission.
1999
and
2000.
7)
Weeding
Time
Estimates
in
Commercial
Scale
Shank­
Applied
Fumigant
Evaluations
at
Oxnard,
CA.
S.
Fennimore
et
al.
Report
to
California
Strawberry
Commission.
8)
Weeding
Time
Estimates
in
Commercial
Scale
Drip
Applied
Fumigant
Evaluations
at
Oxnard,
CA.
S.
Fennimore
et
al.
Report
to
California
Strawberry
Commission.
9)
Weed
Control
Efficacy
of
Alternative
Fumigants
at
Oxnard,
CA.
S.
Fennimore
et
al.
Report
to
California
Strawberry
Commission.
10)
California
Management
Plan:
1,
3­
Dichloropropene.
California
Department
of
Pesticide
Regulation.
January
30,
2002
11)
Alternative
fumigant
efficacy
on
Weeds
in
Strawberry
Nursery
and
Fruiting
Fields.
S.
Fennimore
et
al.
Report
to
California
Strawberry
Commission.
12)
Weeding
time
estimates
in
commercial
scale
fumigant
evaluations
at
Oxnard,
Ca.
S.
Fennimore,
et
al.
Report
to
California
Strawberry
Commission.
13)
Evaluation
of
the
Weed
Control
Efficacy
of
Chloropicrin
in
Strawberry,
Milt
Haar
et
al.
Report
to
California
Strawberry
Commission.
2000.
14)
Alternative
fumigants
for
control
of
soil
pests:
strawberry
as
a
model
system.
S.
Fennimore
and
J.
Duniway.
On
the
EPA
Website.
15)
Strawberry
Response
to
Fumigants
applied
by
Drip
Irrigation
Systems.
Tom
Trout
and
Husein
Ajwa.
On
the
EPA
Website.
16)
Replacing
Methyl
Bromide
for
Preplant
Soil
Fumigation
with
1,3­
D,
Chloropicrin
and
Tilliam
Combination
Treatments.
U.
S.
EPA.
17)
Chemical
and
Cultural
Alternatives
to
Methyl
Bromide
Fumigation
of
Soil
for
Strawberry.
J.
M.
Duniway.
On
the
EPA
Website.
18)
Chemical
Alternatives
to
Methyl
Bromide
for
Strawberry
Production
in
North
Carolina.
Ge.
E.
Fernandez.
On
the
EPA
Website.
19)
Distribution
of
Drip
Applied
Fumigants
Under
Various
Conditions.
H.
Ajwa
and
T.
Trout.
On
the
EPA
Website.
20)
Strawberry
Growth
and
Yield
with
Three
Years
of
Drip
Fumigation.
H.
Ajwa
and
T.
Trout.
On
the
EPA
Website.
21)
1,2,
D,
A
valid
alternative
to
methyl
bromide
for
the
control
of
plant
parasitic
nematodes.
F.
Lamberti,
Bari,
Italy.
On
the
EPA
Website.
22)
Chloropicrin
application
in
Italy
by
soil
injection
and
drip
irrigation:
Effect
against
soil
borne
fungal
pathogen.
A.
Minuto,
et
al.
On
the
EPA
Website.
23)
Approved
Treatment
and
Handling
Procedures
to
Ensure
Against
Nematode
Pest
Infestation
of
Nursery
Stock.
California
Department
of
Food
and
Agriculture.
24)
Metam
Sodium
as
an
Alternative
to
Methyl
Bromide
for
Fruit
and
Vegetable
Production.
U.
S.
EPA.
On
the
EPA
Website.
25)
Metam
Sodium
as
an
Alternative
to
Methyl
Bromide
for
Fruit
and
Vegetable
Production
and
Orchard
Replanting.
U.
S.
EPA.
On
the
EPA
Website.
26)
Basamid
for
the
Forest
Nursery
Industry.
U.
S.
EPA.
On
the
EPA
Website.
27)
Options
to
Methyl
Bromide
for
the
Control
of
Soil­
Borne
Disease
and
Pests
in
California.
A.
Braun
and
D.
Supkoff.
July
1994.
Pest
Management
Analysis
and
Planning
Program.
California
Department
of
Pesticide
Regulation.
Worksheet
3A.

Alternative:
Chloropicrin
Studies:
Please
refer
to
Reference
List
in
worksheet
for
1,3­
D.

Section
I.
1
Chloropicrin
alone
is
not
approved
as
a
stand­
alone
fumigant
by
the
California
Department
of
Food
and
Agriculture
for
certified
nursery
crops
(
23)
for
either
nematodes
or
soil
borne
pathogens.

Section
II.
1
Studies
1­
13
and
23
are
not
on
EPA
website,
Studies
14­
22
and
24­
27
are
on
the
EPA
website.
2
Author:
various,
as
stated
above
3
Publication
date:
various
as
above.
4
Multiple
locations
as
per
studies
above
5
Chloropicrin
is
being
compared
to
methyl
bromide.
6
Yield
was
specifically
studied
using
only
Chloropicrin
for
fruit/
nut
trees.
7
Effectiveness
of
Chloropicrin
compared
to
Methyl
Bromide
a.
Control
of
Nematodes.
Chloropicrin
is
not
approved
as
a
nematocide
by
the
California
Department
of
Food
and
Agriculture
for
tree
nurseries
in
the
certification
program
(
23).
Since
it
is
necessary
for
the
nurseries
to
be
participants
in
the
certification
program
in
order
to
maintain
their
customer
base,
they
are
unable
to
use
chloropicrin
as
a
stand­
alone
fumigant.
Chloropicrin
does
not
provide
adequate
control
of
nematodes
in
nurseries
situations
(
3,
14,
15).

b.
Control
of
Pathogens.
Chloropicrin
does
not
provide
consistent
control
of
soil
borne
pathogens:
Verticillium
dahliae
(
14,
15,
22),
Rhizoctonia
solani
(
22),
Fusarium
melonis
(
22)
and
F.
lycopersici
(
22)
Phytophthora
cactorum
(
4,
15).
Chloropicrin
did
provide
control
of
Pythium
ultimum
in
nursery
fields
(
14).

c.
Weed
Control.
Neither
Chloropicrin
nor
methyl
bromide
controlled
mallow
(
13)
and
very
high
levels
of
chloropicrin
were
needed
to
control
purslane
and
knotweed
(
13).
Chloropicrin
EC
was
weak
for
weed
control
in
comparison
with
either
methyl
bromide
or
1,3­
D.
Therefore,
the
associated
weeding
times
and
cost
of
weeding
for
Chloropicrin
was
significantly
higher
(
8).
Conclusions:

Because
Chloropicrin
is
not
approved
as
a
stand­
alone
fumigant
for
nematode
or
soil
borne
pathogen
control,
it
is
not
used
commercially
as
an
alternative
to
methyl
bromide.
Although
this
compound
has
been
included
in
many
studies
examining
alternatives
to
Methyl
Bromide,
it
does
not
appear
to
be
useful
as
a
stand­
alone
alternative.
It
does
appear
to
be
useful
in
combination
with
Methyl
Bromide
and
in
combination
with
1,3­
D.
Worksheet
3A.

Alternative:
Metam
Sodium
Studies:
Studies:
Please
refer
to
Reference
List
in
1,3­
D
worksheet.

Section
I.
1
While
there
are
no
township
caps
associated
with
metam
sodium,
there
is
a
problem
with
consistent
application
of
this
material.
Metam
sodium
moves
in
water
and
does
not
fumigate
soil
that
is
not
within
the
wetted
front
(
3).
Any
pockets
of
saturated
soil,
or
near
saturated
soil
in
the
profile,
will
not
receive
an
effective
dose
of
fumigant.
Metam
sodium
is
not
approved
by
the
California
Department
of
Food
and
Agriculture
as
a
fumigant
for
the
nursery
certification
process
(
23).

Section
II.
1
Studies
1­
13
and
23
are
not
on
EPA
website,
Studies
14­
22
and
24­
27
are
on
the
EPA
website.
2
Author:
various,
as
stated
above
3
Publication
date:
various
as
above.
4
Multiple
locations
as
per
studies
above
5
Metam
sodium
is
being
compared
to
Methyl
Bromide.
6
Yield
was
not
studied
for
Metam
Sodium
as
a
stand­
alone
fumigant
in
fruit/
nut
trees.
7
Effectiveness
of
Metam
Sodium
to
Methyl
Bromide
a.
Control
of
Nematodes.
While
nematode
control
has
been
achieved
in
various
commodity
crops
(
24,
25),
most
of
the
work
was
done
in
shallower
soils.
Metam
sodium
was
not
as
effective
as
1,3­
D
(
there
was
not
a
methyl
bromide
control
in
the
study)
for
control
of
rootknot
nematode
and
Heterodera
carotae
(
21).
Metam
sodium
alone
does
not
provide
the
long
term,
deep
control
of
nematodes
needed
by
nursery
growers
(
3).
Rates
of
metam
sodium
needed
to
move
the
material
five
feet
down
in
the
soil
profile
result
in
phytotoxic
effects
(
3).

b.
Control
of
Pathogens.
When
digging
the
nursery
stock,
root
material
is
left
in
the
soil.
Depending
on
soil
type
and
environmental
conditions,
these
roots
may
remain
in
the
soil
up
to
several
years.
Because
of
this,
it
is
necessary
to
have
a
fumigant
that
can
penetrate
the
roots
and
kill
pathogens
such
as
Oak
Root
Fungus
(
Armillaria
mellea)
and
nematodes
residing
in
the
roots.
Metam
sodium
does
not
effectively
penetrate
root
tissue
(
3).

c.
Weed
Control.
Metam
sodium
has
been
effective
in
controlling
chickweed,
purslane
and
knotweed
but
is
not
effective
for
mallow
or
fillare
(
communication
from
S.
Fennimore).
If
properly
applied,
Metam
sodium
was
shown
to
be
95%
effective
in
controlling
weeds
in
the
top
few
inches
of
soil
in
orchards
(
3).

d.
Movement
in
the
Soil
Profile.
Movement
is
limited
in
the
soil
to
the
wetted
front
of
the
fumigation
zone
(
3).
Due
to
limited
movement,
there
may
be
pockets
of
soil
that
are
not
fumigated.
In
heavier
soils,
or
years
with
higher
rainfall
levels,
this
can
be
a
particular
problem.

Conclusions.
Metam
sodium
alone
is
not
a
feasible
alternative
for
methyl
bromide
in
deciduous
nursery
production.
In
addition,
the
California
Department
of
Food
and
Agriculture
does
not
approve
the
use
of
Metam
sodium
as
a
standalone
fumigant
in
the
Nursery
Certification
Program.
Some
growers
are
using
this
compound,
but
it
is
always
used
in
combination
with
other
materials.
Worksheet
3A.

Alternative:
Basamid
Studies:
See
Reference
List
in
worksheet
for
1,3­
D.

Section
I.
1
There
are
no
town
ship
caps
for
Basamid.
Basamid
is
not
approved
by
the
California
Department
of
Food
and
Agriculture
as
a
stand­
alone
fumigant
for
use
in
the
nursery
certification
program
(
23).

Section
II.
1
All
studies
are
referenced
in
the
3A
worksheet
for
the
1,3­
D
chemical
alternatives.
2
Author:
various,
as
stated
above
3
Publication
date:
various
4
Multiple
locations
as
per
studies
above
5
Alternative
is
Basamid.
6
Yield
was
not
studied
for
fruit/
nut
trees.
7
Effectiveness
of
Basamid
as
compared
to
Methyl
Bromide
a.
Due
to
the
difficulty
with
uniform
application
of
this
material,
effective
control
of
nematodes
and
soil
borne
pathogens
is
not
possible
(
3).

b.
Movement
of
in
the
Soil
Profile.
Uniform
application
of
the
granular
material,
which
contains
various
grain
sizes,
is
difficult.
Further
studies
on
dissolution
rate
of
the
granules
as
well
as
methods
to
optimize
penetration
of
the
material
into
soils
need
to
be
conducted.
Worksheet
3A.

Alternative:
Non
Chemical
Alternatives
 
Biofumigation,
Solarization,
Steam
Heat,
BioControl,
Cover
crop/
Mulch,
Crop
Rotation,
Flood
and
Water
Management,
Graft
Resistant
Rootstocks,
Organic
Amendments,
Physical
Removal/
Sanitation,
Resistant
Cultivars,
Soilless
culture,
Substrates/
plug
plants.

Studies:
Please
refer
to
Reference
List
in
worksheet
for
1,3­
D.

None
of
the
non­
chemical
alternatives
is
approved
by
the
California
Department
of
Food
and
Agriculture
for
use
in
the
certification
program
(
23).
California
regulations
require
stock
be
free
of
nematodes
in
order
to
ship
the
material
from
a
nursery
to
a
buyer.
None
of
the
non­
chemical
alternatives
can
achieve
the
99.9%
nematode
free
stock
needed
to
meet
this
requirement.
Since
the
buyers
of
the
nursery
stock
for
commercial
plantings
require
a
large
root
biomass
in
the
purchased
product
to
produce
a
successful
grove
of
trees
(
3),
soilless
culture
(
container
trees)
is
not
an
option
that
can
meet
the
demand
of
the
consumer.
Although
some
of
the
non­
chemical
alternatives
are
used
by
growers
as
part
of
integrated
systems
(
cover
crop,
crop
rotation,
water
management,
graft
resistant
rootstocks)
in
combination
with
chemical
fumigation,
none
of
these
alternatives
is
a
stand­
alone
replacement
for
chemical
fumigation.
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
DE
F
GH
I
J
K
L
M
NO
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
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)

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.

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.

Example
Research
Summary
Table
Example
Provide
one
summary
table
for
each
study
being
described.
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)

Telone
Nematodes
1,3­
D
custom
$
2,300.00
Metam
Sodium
Weeds
MITC
application
$
0.00
$
0.00
Telone
Nematodes
1,3­
D
custom
$
1,900.00
Chloropicrin
Pathogens
Chloropicrin
application
$
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
$
2,100.00
Comments:

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

OMB
Control
#
2060­
0482
For
EPA
Use
Only
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.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Telone
Combinations
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.

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
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
$
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
Control
P
Pest
J,
Pest
K
$
500.00
Total
$
5,360.00
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:
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.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
per
area
For
EPA
Use
Only
ID#

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

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.
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
see
comments
Comments:

No
direct
information
available
on
yield
with
alternative
regimes
OMB
Control
#
2060­
0482
The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.
Post­
harvest
and
structural
users
may
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.

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

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

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternative:
Telone
Combinations
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
below.

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.
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
Weed
Control
1295
$
1,295.00
hand
weeding
$
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
$
1,295.00
Comments:

With
the
use
of
Telone
Combinations,
weed
populations
increased
which
resulted
in
increased
hand
labor
to
remove
weeds.

OMB
Control
#
2060­
0482
Typical
Equipment
Used
Operation
Done
by
User
Telone
Combinations
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,

not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operation
costs,
or
in
Col.
C
and
D
for
operations
done
by
user.

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

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

Enter
custom
operation
costs
that
change
in
Col.
B.

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

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

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
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
7.

OMB
Control
#
2060­
0482
See
attached
sheet
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.)
Will
crop
yield
be
measured
in
the
study?
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
Research
Funded
by
the
Fruit
Tree,
Nut
Tree,
and
Grapevine
Improvement
Advisory
Board
(
IAB)
from
1999
through
2002*

Year
Proposal
Researcher
Affiliation
Amount
Approved
1991­
1998
Alternatives
to
Methyl
Bbromide
McKenry
UC
Kearney
Ag
$
50,000
2000­
2001
Alternatives
to
Methyl
bromide
on
stone
fruit
and
walnut
Eayre
USDA
$
40,000
2001­
2002
Plant
Growth
Promoting
Rhizobacteria
in
Walnut
and
Prunus
Nurseries
and
Orchards
Eayre
USDA
$
20,000
1999­
2000
Epidemilogy
and
control
of
crown
gall
on
walnuts
Epstein
UC
$
20,000
2000­
2001
Epidemilogy
and
control
of
crown
gall
on
walnuts
Epstein
UC
$
20,000
2001­
2002
Epidemilogy
and
control
of
crown
gall
on
walnuts
Epstein
UC
$
19,298
1999­
2000
Evaluation
of
alternatives
to
methyl
bromide
for
fumigation
at
commercial
fruit
and
nut
tree
nurseries
McKenry
UC
Kearney
Ag
$
27,000
2000­
2001
Evaluation
of
alternatives
to
methyl
bromide
for
fumigation
at
commercial
fruit
and
nut
tree
nurseries
McKenry
UC
Kearney
Ag
$
27,000
2001­
2002
Evaluation
of
alternatives
to
methyl
bromide
for
fumigation
at
commercial
fruit
and
nut
tree
nurseries
McKenry
UC
Kearne
Ag
$
27,000
1999­
2000
Evaluation
of
broccoli
residue
for
nematode
control
on
nursery
fruit
and
nut
tree
rootstocks
and
grapevines
Westerdahl
UC
$
20,095
2001­
2002
Evaluation
of
broccoli
residue
for
nematode
control
on
nursery
fruit
and
nut
tree
rootstocks
and
grapevines
Westerdahl
UC
$
20,095
2001­
2002
Tarped
metam
sodium
as
a
replacement
for
methyl
bromide
for
nematode
control
on
nursery
fruit
and
nut
tree
rootstocks
and
grapevines
under
northern
California
nursery
conditions
Westerdahl
UC
$
26,679
2000­
2001
Evaluation
of
alternatives
to
methyl
bromide
for
grapevine
nurseries
Schneider
$
55,650
2001­
2002
Evaluation
of
alternatives
to
methyl
bromide
for
grapevine
nurseries
Schneider
$
55,650
Total
Spent
between
1999­
2000
and
2001­
2002
$
378,467
Note:
This
is
the
amount
of
funding
by
the
IAB,
there
is
an
equal
amount
of
funding
the
researcher's
institute.
Research
Funded
by
the
Fruit
Tree,
Nut
Tree,
and
Grapevine
Improvement
Advisory
Board
(
IAB)
for
the
2002­
2003
Production
Year
Proposal
Researcher
Affiliation
Amount
Requested
Amount
Approved
Location
Alternative
to
be
Tested
Crop
yield
Measured?

Investigation
of
the
Etiology,
Epidemiology
and
Control
of
Crown
Gall
on
Walnuts,

and
the
Detection
of
its
Pathogenic
Agents
Epstein/
Mircetich
Joint
with
California
Walnut
Board,
UC
$
38,395
$
38,395
no
Propagation
and
Retesting
of
Walnut
Rootstock
Genotypes
Putatively
Resistant
to
Phytophthora,
Crown
Gall
and
Nematodes
Hackett
California
Walnut
Board,
UC
$
43,408
$
43,408
UC
Davis,

UC
Kearney
Ag
Center
resistant
rootstock
yes
Four
Possible
Approaches
to
Treatment
of
Finer
Textured
Nursery
Soils
after
2005
McKenry
UC
$
30,000
$
30,000
UC
Davis,

UC
Kearney
Ag
Center
Chloropicrin,
methyl
iodine,
high
rates
of
Telone
with
multiple
tarps
yes
Development
of
Molecular
Assay
for
Identification
of
Plant
Parasitic
Nematode
Species
in
Soil
Samples
Williamson
$
33,057
$
33,057
Bacteriophage
for
Control
of
Crown
Gall
Eayre
USDA
$
30,000
$
30,000
biocontrol
no
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Grapevie
nurseries
Schneider
USDA
$
59,135
$
59,135
Iodomethane,
Telone+
Metam
Sodium,
Sodium
Asize,
Propargyl
Bromide,
Chloropicrin
all
with
different
application
methods
Tarped
metam
Sodium
as
a
Replacement
for
Methyl
Bromide
for
Namatode
Control
on
Nursery
Fruit
and
Nut
Tree
Rootstocks
and
Grapevines
under
Northern
California
Nursery
Conditions
Westerdahl
UC
Davis
$
28,007
$
28,007
Shank
injected
Metam
Sodium
with
and
with
out
tarps,

Chloropicrin,
Telone
II
no
$
262,002
$
262,002
Note:
This
is
the
amount
of
funding
by
the
IAB,
there
is
a
equal
amount
of
funding
from
the
researchers
institute.
1.

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

x
Virtually
impermeable
film
(
VIF)

x
Cultural
practices
(
please
specify)

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

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

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

3.

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

4.

$

5.

6.

When
do
you
expect
these
to
occur?

7.

0­
10
acres
10­
25
acres
25­
50
acres
50­
100
acres
100­
200
acres
200­
400
acres
over
400
acres
Worksheet
5.
Additional
Information
For
EPA
Use
Only
ID#

1
1
Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
on
January
1,
2005?
deep
injection
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)?
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Integrated
pest
management
Do
you
have
access
to
recycled
methyl
bromide?
Some
growers
are
using
1,3­
D/
chloropicrin
combinations
where
soil
and
moisture
conditions
allow.
%
Chloropicrin
in
the
MB/
pic
formulation
has
been
increased
re
MB
378,467
1
3
Range
of
acres
farmed
by
growers
included
in
this
application?
(
insert
number
of
users
in
each
category)
Other
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide.
Describe
each
investment
and
its
associated
cost.
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.

6
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
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
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintainin
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
resp
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
colle
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
brom
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)

James
W.
Wells
Consultant
James
W.
Wells
Consultant
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#
re
relative
to
es
the
time
ining
spond
to
a
ollection
of
omide.
An
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
495,000
5.
Area
Treated
with
Methyl
Bromide
2005
1,650
acres
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

2006
495,000
lbs.
Area
Treated
1,650
acres
units
2007
495,000
lbs.
Area
Treated
1,650
acres
units
Not
Technically
Feasible
Not
Economically
Feasible
X
Trees
not
yet
harvested
by
grower
who
tried
this
X
X
X
X
X
X
For
EPA
Use
Only
ID#

Worksheet
6.
Application
Summary
This
worksheet
will
be
posted
on
the
web
to
notify
the
public
of
requests
for
critical
use
exemptions
beyond
the
2005
phase
out
for
methyl
bromide.
Therefore,
this
worksheet
cannot
be
claimed
as
CBI.

Name
of
Applicant:

Location:

Crop:
California
Association
of
Nurserymen
Deciduous
Fruit
&
Nut
Tree
Peaches,
Prunes,
Nectarines,
Cherries,
Plums,
Apples,
Pears,
Asian
Pears,
Apricots,
Ornamental
Peach,
Ornamental
Plum,

Ornamental
Cherry,
Almonds,
Walnuts,
Pistachios,
Pecans,
Chestnuts.

San
Joaquin
Valley
&
Sacramento
Valley
of
Californa
1,3­
D
and
metam
sodium
can
give
phytotoxic
effects
if
applied
at
the
same
time.
Sequential
applications
require
a
long
period
of
time
for
the
fumigation
process.
This
combination
does
not
provide
adequate
nematode
and
pathogen
control.

This
material
does
not
control
weeds.
1,3­
D
does
not
control
pathogens
or
nematodes
deeply
enough
in
the
soil
profile
to
keep
the
pathogens
and
nematodes
out
of
the
rooting
zone
of
nursery
trees.
There
are
township
caps
associated
with
this
material.

Reasons
Even
in
association
with
chloropicrin,
1,3­
D
does
not
control
weeds.
1,3­
D/
chloropicrin
combinations
do
not
control
pathogens
or
nematodes
deep
enough
in
soil
profile.
This
is
a
very
expensive
mix.

1,3­
D
in
association
with
chloropicrin
and
metam
sodium
have
not
been
shown
to
be
effective
deep
enough
in
the
soil
profile.
This
is
a
prohibitively
expensive
mix.

1,3­
D,
Chloropicrin
1,3­
D,
Chloropicrin,
Metam
Sodium
Chloropicrin
is
an
expensive
product
and
large
amounts
are
needed
if
applied
alone.
The
efficacy
of
this
material
is
inconsistent
for
control
of
pathogens.

Metam
Sodium
only
moves
in
water
and
does
not
fumigate
soil
that
is
not
within
the
wetted
soil
front.
Control
of
pathogens,

nematodes
and
weeds
has
been
inconsistent
with
this
material.

There
is
no
indication
that
acceptable
alternatives
will
be
in
place
sufficient
to
meet
state
nursery
certification
requirements.

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.

Chloropicrin
Metam
Sodium
1,3­
D,
Metam
Sodium
Basamid
Potential
Alternatives
1,3­
D
Basamid
is
difficult
to
apply
uniformly
and
thus
does
not
provide
even
control.
Fumigation
cycle:

Year:
Comparable
data:

2­
year
example:

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

and
all
yields
and
revenues
received
during
that
2­
year
interval.
Other
pest
control
and
other
costs
would
only
need
to
be
provided
for
that
interval
if
they
would
change
from
what
they
were
with
methyl
bromide.

If
someone
other
than
the
applicant
benefits
from
a
methyl
bromide
fumigation,
you
should
comment
on
these
benefits
if
you
do
not
have
quantitative
data
for
the
entire
fumigation
cycle.

For
example,
if
a
rotational
crop
in
the
second
year
benefits
from
a
methyl
bromide
fumigation
a
year
earlier,
but
there
is
quantitative
data
only
on
the
first
crop,
then
the
data
on
the
alternatives
should
cover
only
the
first
crop,
and
the
benefits
of
methyl
bromide
and
the
additional
pesticides
that
would
have
to
be
used
on
the
rotational
crop
should
be
discussed
in
the
comments
sections.

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

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

Fumigation
Cycle
Definitions:

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

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

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

The
period
of
time
between
methyl
bromide
fumigations.
