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
x
Medium
x
Heavy
0
to
2%
x
2
to
5
%
x
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.
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Sacramento,
CA
95814
adowns@
exponent.
com
Anne
Downs
916.443.2793
916.443.3071
910
K
Street,
Suite
325
Location
(
Enter
the
state,
region,
or
county.
Provide
more
detail
about
the
location
if
relevant
to
the
feasibility
of
alternatives
to
methyl
bromide.)

Crop/
commodity
(
Include
all
crops/
commodities
that
benefit
from
the
application
of
methyl
bromide
in
a
fumigation
cycle.
A
fumigation
cycle
is
the
period
of
time
between
methyl
bromide
fumigations.)

Climate
(
Individual
users
should
enter
their
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
climate
zone.
This
map
is
located
at
the
end
of
this
workbook
or
it
can
be
reviewed
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html).

Various,
mediterranean
to
arid
910
K
Street
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
The
following
information
will
be
used
to
determine
the
amount
of
methyl
bromide
requested
and
the
contact
person
for
this
request.
It
is
important
that
we
know
whom
to
contact
in
case
we
need
additional
information
during
the
review
of
the
application.

Other
geographic
factors
that
may
affect
crop/
commodity
yield
(
e.
g.,
water
table).

CAN
Citrus
&
Avocado
Nursery
CUE
Southern
California
and
San
Joaquin
Valley
Citrus
and
avocado
nursery
Soil
Type:

Organic
Matter:
Soil
type
Check
the
box(
es)
for
the
soil
types
and
percent
organic
matter
that
apply
to
your
area.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
soil
type.

Consortium
name
Sacramento,
CA
95814
jwells@
exponent.
com
916.443.3071
Contact
name
Address
916.443.2793
E­
mail
Jim
Wells
Exponent
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
42,000
lbs.

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

19.

20.

20a.

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

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

There
are
very
few
citrus
nursery
stock
producers
for
commercial
plantings.
All
but
one
producer
grow
plants
in
the
field.
30
acres
is
an
average
size
for
field
grown
citrus
nursery
stock.
The
representative
citrus
user
harvests
approximately
30
acres
of
field
grown
citrus
nursery
stock
annually.
The
stock
is
sold
to
commercial
producers
of
citrus
fruit.
The
ground
is
fumigated
pre­
plant
with
methyl
bromide
every
growing
cycle
for
nematode,
disease
and
weed
control.
The
grower
participates
in
the
California
nursery
certification
program.
The
representative
avocado
user
grows
avocado
nursery
stock
in
containers
for
comercial
planting.
The
container
substrate
is
fumigated
with
methyl
bromide.
Because
the
container
growerd
use
of
methyl
bromide
is
substantially
different
from
the
representative
grower.
Supplemental
worksheets
have
been
added
where
necessary.
How
much
area
will
this
be
applied
to?
Please
list
units.
105
For
EPA
Use
Only
ID#

Explain
why
this
user
represents
the
typical
user
in
the
consortium.
105
Industry
standards
and
regulatory
requirements
require
commercially
clean
nursery
stock.
None
of
the
available
alternatives
to
date
have
demonstrated
that
these
standards
can
be
met
consistently
in
all
soil
types
and
growing
areas.

2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
42,000
Area
to
be
Treated
105
If
yes,
please
list
year
and
quantity
active
ingredient
(
ai)
of
methyl
bromide
requested
in
the
table
below
and
explain
why
you
need
authorization
for
multiple
years.

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

Phytophthora
cinnamomi.
Armillaria
mellea.
Dry
Root
Rot.
42,000
Unit
of
Area
Treated
Nematodes,
e.
g.
Tylenchulus
semipenetrans,
Radopholus
similis,
Meloidogyne
spp.

Soil
fungi,
e.
g.
Phytophthora
citrophthora,
Phytophthora
parasitica.
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
California
Association
of
Nurserymen
Citrus
and
Avocado
Nursery
Production
Narrative
The
market
for
wholesale
citrus
and
avocado
nurseries
in
California
is
divided
into
two
sectors:
1)
commercial
fruit­
producing
orchard
operations,
and
2)
retail/
garden
center
outlets.
This
consortium
consists
of
nursery
growers
producing
trees
for
use
in
orchards
for
fruit
production.
Most
trees
produced
for
the
retail/
garden
center
are
container
grown.
Nearly
all
of
the
citrus
trees
produced
for
commercial
fruit
production
are
grown
in
the
ground
(
field
grown).
The
nurseryman's
objective
in
producing
these
trees
is
to
furnish
the
California
agricultural
industry
with
trees
of
known
genetic
properties,
which
are
free
from
pests
and
diseases.

Commercial
producers
prefer
field
grown
nursery
stock
because
it
is
larger,
stronger,
adapts
to
the
orchard
better
and
begins
producing
earlier
than
container
grown
stock.
This
is
important
to
the
commercial
fruit
producer
who
must
produce
income
from
a
planting
as
early
as
possible
to
offset
growing
costs
(
18
[
All
references
are
attached
to
1,3­
D
worksheet]).

CITRUS
Citrus
trees
for
commercial
fruit
production
consist
of
a
seedling
rootstock,
which
is
budded
to
a
fruiting
scion
variety.
The
production
process
consist
of
two
phases:
1)
seedling
production
until
transplanting,
and
2)
field
growing.

Seedling
production
Seeds
are
harvested
from
orchard
trees
of
known
lineage,
which
are
grown
specifically
for
seed
production.
These
trees
are
produced
from
registered
bud
lines
maintained
by
the
Clonal
Citrus
Protection
Program
(
CCPP)
and
overseen
by
the
California
Department
of
Food
and
Agriculture
(
CDFA).
Seeds
can
be
harvested
from
a
nursery's
own
registered
seeds
trees
or
procured
from
other
producers.

Seeds
are
generally
sown
into
flats,
seedbeds
or
other
seedling
containers
in
the
greenhouse
or
other
protected
growing
area
during
the
spring.
Off­
season
sowing
is
fairly
common,
as
seeds
can
be
maintained
in
acceptable
condition
for
several
months
under
controlled
conditions.
As
seedlings
emerge,
they
are
inspected
for
off­
types
and
weak
individuals,
which
are
discarded.
The
resulting
selected
seedlings
are
grown
up
to
the
desired
height,
which
can
vary
from
8"­
24"
depending
on
the
nursery's
techniques,
time
of
year
and
the
prospective
demand
for
nursery
trees.
In
some
cases
the
seedlings
are
transplanted
into
larger
interim
containers
which
do
not
exceed
3"
diameter
x
12"
tall.
During
this
phase,
the
seedlings
are
usually
grown
in
a
clean
soilless
substrate.
Routine
inspections
are
performed
to
detect
any
pests
or
diseases,
and
appropriate
treatments
are
administered.
Weak
or
otherwise
under
performing
seedlings
are
continuously
sought
and
discarded.

When
the
seedlings
have
reached
the
desired
size
they
are
transplanted
into
the
field.
Production
of
field
ready
seedlings
can
take
anywhere
from
4­
12
months.

Field
Growing
In
this
phase,
the
selected
seedlings
are
removed
from
the
greenhouse
or
protected
growing
area
and
transplanted,
either
into
larger
pots
that
are
typically
7"
diameter
x
17"
tall
or
directly
into
the
ground.
In
either
case
the
growing
area
is
outdoors
and
exposed
to
full
sunlight.
Most
of
the
growers
in
this
consortium
grow
in
the
ground
(
see
discussion
above).
One
grower
produces
lemon
trees
for
commercial
planting
in
containers
for
a
niche
market
in
a
particular
growing
region
of
California.

The
substrate
in
pots
generally
consists
of
a
mixture
of
topsoil,
sand
and
organic
material.
These
materials
are
usually
brought
to
the
nursery
from
outside
sources
and
stockpiled,
sometimes
for
many
years.
For
in­
ground
production
the
substrate
is
the
native
soil.
Organic
amendments
may
be
worked
into
the
soil.
In
either
case,
the
California
Department
of
Food
&
Agriculture
(
CDFA)
requires
that
the
substrate
be
commercially
clean
of
pests
and
diseases
(
8).
Of
particular
concern
are
nematodes,
which
are
the
subject
of
a
mandatory
certification
program
administered
by
CDFA.
To
comply
with
these
requirements,
as
well
as
with
the
implicit
covenant
the
nursery
has
with
its
customer
to
supply
materials
that
are
free
of
pests
and
disease,
the
substrate
is
fumigated
with
methyl
bromide.
This
ensures
freedom
from
nematodes,
as
well
as,
other
pests
such
as
soil
borne
fungi
and
noxious
weeds.

In
the
case
of
pot
culture,
the
soil
is
blended
to
the
desired
makeup
by
large
machinery,
then
spread
and
fumigated
in
compliance
with
CDFA
regulations.
Pots
are
then
filled
with
the
fumigated
substrate.
For
in­
ground
production,
the
soil
is
worked
and
irrigated
to
the
proper
moisture
levels
and
fumigation
is
performed
in
place.

The
seedlings
are
developed
in
the
field
until
they
reach
the
desired
size
for
budding.
This
can
be
a
period
as
short
as
three
months
or
as
long
as
a
year,
depending
on
variety,
nurseryman's
preference,
and
market
conditions.

The
plant
materials
utilized
in
budding
are
the
progeny
of
the
Citrus
Registration
/
Certification
program
which
is
administered
by
CDFA.
Under
this
program,
only
bud
sources
that
are
approved
by
CDFA,
as
being
free
from
Citrus
Tristeza
Virus,
are
utilized.
Sources
of
bud
material
are
tested
on
a
recurring
basis
by
CDFA.
Budding
is
accomplished
by
the
insertion
of
a
single
bud
of
the
desired
fruiting
variety
under
the
bark
of
the
stem
of
the
seedling,
at
a
height
6"­
12"
above
the
soil.
The
budding
site
is
then
wrapped
with
clear
polyethylene
budding
tape
to
provide
physical
support
and
prevent
desiccation.
The
seedling
is
then
bent
over
to
encourage
sap
flow
to
the
budding
site
and
discourage
terminal
growth
of
the
seedling.
In
approximately
three
weeks
the
bud
heals
into
the
tissue
of
the
seedling
and
begins
to
grow.
At
this
point
the
budding
tape
is
removed
and
the
new
sprout
emerges.

It
is
necessary
to
retain
the
bent
over
seedling
because
the
leaves
on
this
portion
of
the
plant
act
as
a
sink
for
nutrients
as
well
as
collectors
of
the
sun's
energy.
This,
in
turn,
helps
to
sustain
a
healthy
root
system
while
the
new
bud
develops.

During
subsequent
months
the
bud
elongates
and
becomes
the
principal
stem
of
the
nursery
tree.
The
seedling
is
maintained
in
its
bent
over
position
and
growth
that
sprouts
from
this
portion
of
the
plants
is
removed
by
hand.
When
the
new
stem
has
attained
a
height
of
approximately
30"
and
developed
a
sufficient
amount
of
leaves,
the
seedling
growth
is
removed
above
the
point
where
the
bud
was
inserted,
leaving
the
growth
from
the
bud
as
the
sole
leaf­
bearing
portion
of
the
plant.

The
bud
is
grown
up
to
a
height
of
36"
 
60",
then
pruned
back
to
approximately
30"
prior
to
sale.
Elapsed
time
from
budding
to
sale
is
highly
variable,
depending
mostly
upon
the
vigor
of
the
budded
variety.
In
general,
it
ranges
from
8
 
16
months.

During
the
field­
growing
phase,
frequent
inspections
are
performed
to
identify
and
remedy
any
problems.
These
may
include
infestations
of
pests
and
disease,
weak
trees
or
nutritional
imbalances.
An
entomologist
performs
weekly
inspections.
Inferior
trees
are
identified
and
destroyed.

Method
of
harvest
is
distinct
for
each
type
of
tree.
In
the
case
of
in­
ground
production,
trees
are
dug
from
the
ground
by
hand
with
a
cylinder
of
soil
around
the
principal
roots.
This
root
cylinder
is
then
wrapped
in
burlap
for
physical
protection
and
to
avoid
desiccation.
For
pot
culture,
the
potted
trees
are
simply
loaded
onto
a
delivery
vehicle.
In
either
case,
the
fumigated
substrate
is
delivered
with
the
nursery
tree
and
is
not
reused
by
the
nursery.

Total
time
to
produce
a
saleable
tree
is
12­
28
months.
The
variables
are
the
vigor
of
the
seed
and
bud
varieties,
weather
and
temperature
conditions
in
the
nursery,
and
decisions
on
the
nurseryman's
part
on
when
to
transplant
and
sell.

The
resulting
product
is
a
nursery
tree
of
known
genetic
characteristics
that
has
been
produced
under
stringent
controlled
conditions
to
avoid
the
presence
or
introduction
of
harmful
pests
and
diseases.
Orchard
operators
therefore
can
utilize
these
trees
with
confidence
that
their
lifespan
and
productivity
will
be
up
to
industry
standards
without
risk
of
the
proliferation
of
dangerous
pests
and
diseases.

AVOCADOS
The
production
process
for
avocados
is
substantially
similar
to
that
of
citrus.
As
with
citrus,
the
process
can
be
divided
into
two
phases,
1)
greenhouse
propagation,
and
2)
field
growing.
The
principal
differences
in
production
techniques
are
(
1)
avocados
are
grafted
rather
than
budded,
and
(
2)
the
grafting
takes
place
in
the
greenhouse
phase
rather
than
the
field­
growing
phase.

Another
aspect
of
avocado
nursery
tree
production
is
that
avocado
trees
are
susceptible
to
Phytophthora
cinnamomi
(
Pc),
a
soil
borne
fungus
that
attacks
avocado
roots.
This
fungus
is
especially
damaging
to
avocado
trees,
having
the
ability
to
attack
and
kill
perfectly
healthy
trees
in
a
relatively
short
period.
In
past
years,
nurseries
unfortunately
proved
to
be
a
very
effective
means
of
distribution
of
this
fungus,
to
the
point
that
the
future
of
avocado
production
in
California
was
at
risk.
For
this
reason,
CDFA
established,
and
still
maintains,
an
Avocado
Nursery
Certification
Program
that
specifies
steps
that
complying
avocado
nurseries
must
take
to
prevent
the
presence
of
this
fungus
in
the
nursery,
and
by
extension
avoid
distribution
of
the
fungus
in
infested
nursery
trees
(
8).
The
vast
majority
of
avocado
trees
produced
in
California
are
from
nurseries
that
participate
in
this
program.

Greenhouse
propagation
Avocado
nursery
trees
for
commercial
fruit
production
consist
of
two
types:
trees
grafted
to
seedling
rootstocks,
and
trees
grafted
to
clonal
rootstocks.
From
a
nursery
production
perspective,
the
difference
between
them
is
that
the
clonal
rootstocks
require
extra
steps
during
the
greenhouse
phase
to
produce
roots
from
asexual
tissue,
as
opposed
to
seedling
rootstocks
that
utilize
the
sexually
reproduced
seed
as
the
permanent
rootstock
tissue.
For
purposes
of
this
discussion,
the
two
processes
do
not
differ
from
each
other
in
a
meaningful
way,
so
the
more
straightforward
seedling
rootstock
process
will
be
described.

Fruit
are
harvested
from
trees
of
known
varieties
that
have
desirable
rootstock
characteristics.
This
occurs
during
the
period
from
October­
January.
The
fruit
are
allowed
to
soften,
and
the
seeds
are
extracted
by
hand
and
cleaned
of
all
pulp.
The
seeds
are
surface
dried,
then
in
accordance
with
the
Certification
Program,
immersed
in
hot
water
at
a
temperature
of
120­
122
°
F
for
a
period
of
not
less
than
30
minutes.
This
treatment
is
sufficient
to
kill
any
fungi
that
may
be
present
on
the
seeds
and
thereby
eliminates
seeds
as
a
source
of
introduction
of
Pc.

The
seeds
are
bedded
in
clean
soilless
substrate
in
lug
boxes
inside
the
greenhouse
under
controlled
temperatures.
After
approximately
15
days
they
germinate.
As
germination
occurs,
seeds
with
healthy
initial
root
development
are
selected
and
transplanted
into
bags
measuring
2"
diameter
x
12"
deep.
Three
passes
are
made
through
a
given
lot
of
bedded
seeds,
after
which
the
remaining
seeds
are
discarded.
The
transplanted
seeds
develop
into
seedlings
in
the
greenhouse
over
the
course
of
4­
8
weeks.
During
this
period
they
are
frequently
inspected
for
pests
and
diseases,
and
seedlings
that
are
slow
to
develop
are
discarded.

When
the
seedlings
reach
a
height
of
12­
20"
they
are
grafted
with
a
fruiting
scion
variety.
The
graft
material
is
harvested
from
orchard
trees
of
known
desirable
varieties.
Before
entering
the
certified
nursery,
the
grafting
material
is
disinfested
with
a
chemical
treatment.

Grafting
differs
from
budding
in
that
instead
of
placing
a
single
bud
under
the
bark
of
the
stem,
a
cutting
measuring
3­
5"
long
and
of
approximately
pencil
diameter
and
bearing
several
buds
is
inserted
directly
into
the
stem
of
the
seedling.
The
seedling
is
cut
off
at
a
height
of
approximately
6"
and
a
cut
is
made
directly
into
the
cut
surface,
splitting
the
stem
into
two
equal
halves
to
1"
from
the
top.
A
corresponding
wedge
cut
is
made
to
the
bottom
of
the
graft
stick,
and
the
graft
stick
is
inserted
into
the
seedling
stem
so
that
the
cut
surfaces
mate.
The
site
of
the
graft
union
is
then
wrapped
with
an
elastic
strip
to
sustain
the
intimate
contact
of
the
mated
surfaces
and
avoid
desiccation.

After
three
weeks
the
mated
surfaces
will
'
knit'
together
and
sap
will
flow
across
the
bud
union.
At
this
point
the
buds
on
the
graft
begin
to
grow.
Plants
that
are
slow
to
develop
are
removed
and
grafted
a
second
time.
As
the
plants
grow,
they
are
sorted
numerous
times
to
ensure
uniformity,
and
shoots
that
develop
from
latent
buds
on
the
rootstock
are
eliminated.

After
an
additional
4­
12
weeks
the
plants
will
have
developed
sufficient
size
to
be
transplanted
into
the
larger
field
pots.
At
this
point
they
are
removed
from
the
greenhouse
environment
and
placed
under
50%
shade
for
'
hardening
off',
which
prepares
them
for
outdoor
conditions.
They
remain
under
shade
for
7­
10
days,
after
which
they
are
placed
under
full
sun
without
protection.

Field
Growing
The
plants
are
then
transplanted
into
pots
in
the
same
manner
as
the
citrus
seedlings,
In
the
case
of
avocados;
fumigation
of
the
potting
substrate
is
especially
critical,
given
that
Pc
is
a
soil
borne
fungus.
Within
two
days
of
transplanting,
stakes
are
placed
in
the
pots
and
the
young
plants
are
tied
to
the
stakes
to
ensure
an
upright
growth
habit.

From
this
point
the
avocados
trees
are
'
visited'
by
nursery
staff
an
average
of
once
per
week,
and
any
necessary
training,
pruning
and
weeding
is
performed.
Weak
trees
are
identified
and
destroyed.
Weekly
inspections
are
performed
by
an
entomologist
to
identify
any
insect
pests
and
prescribe
remedial
treatment.
The
elapsed
time
in
the
field
is
6­
18
months.

Prior
to
delivery,
cardboard
trunk
protectors
are
applied
to
the
base
of
the
stem
to
protect
trees
from
sunburn
in
the
orchard.
Harvest
is
accomplished
by
loading
the
trees
directly
into
the
delivery
vehicle.
As
is
the
case
with
citrus,
the
fumigated
soil
is
delivered
with
the
tree
and
is
not
re­
used.

As
with
citrus,
the
resulting
product
is
one
that
the
orchard
operator
can
utilize
with
the
confidence
that
the
trees
will
perform
to
expectations
without
the
risk
of
introduction
of
dangerous
insects
and
pathogens.
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
100
37,600
376
98
36,750
375
102
37,944
372
105
34,125
325
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
100
37,600
376
98
36,750
375
102
37,944
372
105
34,125
325
Comments:

All
members
of
the
consortium
have
not
reported.
Above
figures
probably
underestimate
acres
treated
with
methyl
bromide.

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
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
12,500
250
0.02
11850
237
0.02
12600
252
0.02
27000
540
0.02
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
Comments:

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

Formulation
of
Methyl
Bromide
1997
1998
1999
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.

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.

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.

The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
area
are
automatically
calculated
from
the
previous
2
columns.

For
EPA
Use
Only
ID#

Worksheet
2­
A.
Methyl
Bromide
­
Use
1997­
2000
If
a
consortium
is
submitting
this
application,
all
data
should
reflect
the
actual
data
for
the
consortium.
For
EPA
Use
Only
ID#

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

1997
trees
20,080
$
8.65
$
173,692.00
1998
trees
19,859
$
9.14
$
181,511.26
1999
trees
17,861
$
9.43
$
168,429.23
2000
trees
19,339
$
9.60
$
185,654.40
$
0.00
Total
Revenue
for
1997
$
173,692.00
Total
Revenue
for
1998
$
181,511.26
Total
Revenue
for
1999
$
168,429.23
Total
Revenue
for
2000
$
185,654.40
Average
Revenue
Per
Year
$
177,321.72
Comments:

OMB
Control
#
2060­
0482
Citrus
Nursery
Stock
Citrus
Nursery
Stock
Citrus
Nursery
Stock
Citrus
Nursery
Stock
B
Col.
E:
Price
Col.
F:
Revenue
Crop/
Commodity
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

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

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

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.
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
trees/
acre
Price
(
per
unit
of
crop/
commodity)
tree
Revenue
(
per
area)

1997
each
169,356
$
11.42
$
1,934,045.52
1998
each
186,678
$
12.05
$
2,249,469.90
1999
each
213,622
$
12.81
$
2,736,497.82
2000
each
242,942
$
13.06
$
3,172,822.52
$
0.00
Total
Revenue
for
1997
$
1,934,045.52
Total
Revenue
for
1998
$
2,249,469.90
Total
Revenue
for
1999
$
2,736,497.82
Total
Revenue
for
2000
$
3,172,822.52
Average
Revenue
Per
Year
$
2,523,208.94
Comments:

OMB
Control
#
2060­
0482
Nursery
trees­
subtropical
fruiting
Crop/
Commodity
Nursery
trees­
subtropical
fruiting
Nursery
trees­
subtropical
fruiting
Nursery
trees­
subtropical
fruiting
Average
Revenue
per
Year:
The
average
revenue
per
year
is
calculated
automatically
using
the
summary
data
you
enter
for
each
year.

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

B
Col.
F:
Revenue
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.

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

Col.
D:
Crop/
Commodity
Yield
Enter
the
number
of
units
of
crop/
commodities
produced
per
area.

Col.
E:
Price
Enter
the
average
prices
received
by
the
users
for
the
year
and
crop/
commodity
indicated
(
1997­
2000).

Col.
B:
Crop/
Commodity
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.

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.
C:
Unit
of
Crop/
Commodity
Enter
the
unit
of
measurement
for
each
crop/
commodity.

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.

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
1997
­
2000
when
using
methyl
bromide.
Post­
harvest
and
structural
users
may
work
with
EPA
to
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.

Col.
A:
Year
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.
For
EPA
Use
Only
ID#

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

Citrus
Nursery
Stock
none
­
price
remains
fairly
constant
trees
18,344
$
10.32
189,310.00
Total
Revenue
189,310.00
Comments:
Not
all
trees
are
marketable
due
to
substandard
size
or
uniformity.

Not
all
trees
are
sold
within
the
same
year.
Some
trees
are
replanted
into
pots
for
future
sales
to
retail
outlets.

All
figures
are
on
a
per
acre
basis.

OMB
Control
#
2060­
0482
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
2001
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

The
purpose
of
this
worksheet
is
to
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.

Col.
A:
Crop/
Commodity
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.

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.

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
unit
of
measurement
for
each
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor.

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.
For
EPA
Use
Only
ID#

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

Nursery
Trees
each
258,350
$
12.95
3,345,632.50
Total
Revenue
3,345,632.50
Comments:

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

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

Enter
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

Revenue
is
automatically
calculated
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
the
comment
section
below.

Enter
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,

market
(
e.
g.
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
row.
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
in
making
the
case
that
the
use
of
methyl
bromide
affects
these
price
factors.

Enter
the
unit
of
measurement
for
each
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor.

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

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

Col.
A:
Crop/
Commodity
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
2001
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Area
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Area
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Area
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Area
over
95%
methyl
bromide
302
$
3.12
$
265.00
$
387.00
101
$
1,594.24
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
302
$
3.12
$
265.00
$
387.00
101
$
1,594.24
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.
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Area
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Area
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Area
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Area
over
95%
methyl
bromide
2lb./
cu
ft.
$
3.59
4.63/
100
cu
ft
3.35/
100
cu
ft.
33400cu
ft.
$
15.16
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
Comments:

OMB
Control
#
2060­
0482
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.

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
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).

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.
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.

For
EPA
Use
Only
ID#

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

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
Land
Prep
$
112.00
Disk/
Ripper
Amendments
$
253.00
Irrigation
$
322.00
$
824.00
$
2,833.00
$
3,979.99
Planting
$
8,341.00
$
8,341.00
Harvest
$
2,805.00
$
9,458.00
$
12,263.00
Pest
Control/
Fertilizer
$
8,224.00
$
2,791.00
$
5,507.00
Sprayer/
Tractor
Fertilizer
Total
Custom
per
Area
$
687.00
User
Total
per
area
$
30,090.99
Comments:

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:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
Total
Custom
per
Area
User
Total
per
area
Comments:
Costs
for
worksheets
2­
E
and
2­
F
from
this
grower
not
available.

OMB
Control
#
2060­
0482
Operation
Custom
Operation
Cost
per
Area
Operation
Done
by
User
If
you
do
not
incur
custom
operation
costs,
enter
the
labor
cost
per
area.

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

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.

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

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.
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.

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

Worksheet
2­
E.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
Do
not
include
methyl
bromide
costs.

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

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.
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
Rent
lease
$
666.00
Depreciation
on
nursery
equipment
$
165.00
Management
foremen
salaries
$
5,990.00
Administration
office
overhead
+
administration
$
36,473.00
Total
$
43,294.00
Comments:

OMB
Control
#
2060­
0482
Worksheet
2­
F.
Methyl
Bromide
Fixed
and
Overhead
Costs
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

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

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

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

Please
describe
the
cost
in
more
detail.

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

Enter
the
cost
per
area
of
methyl
bromide
treated.

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

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

3­
C
Alternatives
­
Crop/

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

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

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

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

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

Alternative:
Study:

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

1a.
Full
use
permitted
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
See
attachments
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.

Telone
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.
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#

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Citrus
Worksheet
3A
1,3­
D
&
1,3­
D
with
chlorpicrin
and/
or
metam
sodium
Studies:
No
formal
studies
of
alternatives
have
been
conducted
directly
on
citrus
nursery
production
in
California.
With
respect
to
the
critical
pests
of
citrus
nurseries,
nematodes,
diseases
and
weeds,
work
conducted
in
deciduous
nurseries
and
strawberry
is
illustrative.
References
are
provided
below.

Section
I.
1
There
are
township
caps
for
1,3­
D
in
California.
Citrus
for
farm
planting
must
be
certified.
California
nursery
stock
regulations
require
citrus
to
be
commercially
clean.
Section
II.
1
References
7,
9,
11­
15
&
17
are
on
the
EPA
website.
2
Authors,
various,
see
above
3
3.
See
above
4
location
of
study:
various,
see
above
5
name
of
alternative:
1,3­
D
alone
and
in
combination.
6
Crop
yield
for
citrus
not
measured
7
Effectiveness
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
(
17),
this
is
not
always
the
case
(
7).
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.
Growers
who
have
used
1,3­
D
in
citrus
nurseries
reported
that
control
of
pests
and
pathogens
was
not
equivalent
to
that
obtained
with
methyl
bromide
and
that
nursery
stock
planted
into
soils
treated
with
1,3­
D
were
of
substandard
quality
due
to
persistence
of
residues.
Phytotoxicity
has
also
been
reported
in
an
Italian
study
in
tomatoes
(
grower
communication,
7).
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.
No
yield
data
available
for
alternatives
in
citrus
e.
1,3­
D
does
not
move
well
in
medium
or
heavy
soils
or
in
soils
with
more
than
12%
moisture
(
1,2,3)

References:
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)
California
Management
Plan:
1,
3­
Dichloropropene.
California
Department
of
Pesticide
Regulation.
January
30,
2002
7)
1,2,
D,
A
valid
alternative
to
methyl
bromide
for
the
control
of
plant
parasitic
nematodes.
F.
Lamberti,
Bari,
Italy.
On
the
EPA
Website.
8)
Approved
Treatment
and
Handling
Procedures
to
Ensure
Against
Nematode
Pest
Infestation
of
Nursery
Stock.
California
Department
of
Food
and
Agriculture.
9)
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.
10)
Weeding
Time
Estimates
in
Commercial
Scale
Shank­
Applied
Fumigant
Evaluations
at
Oxnard,
CA.
S.
Fennimore
et
al.
Report
to
California
Strawberry
Commission.
11)
Alternative
fumigants
for
control
of
soil
pests:
strawberry
as
a
model
system.
S.
Fennimore
and
J.
Duniway.
On
the
EPA
Website
12)
Metam
Sodium
as
an
Alternative
to
Methyl
Bromide
for
Fruit
and
Vegetable
Production.
U.
S.
EPA.
On
the
EPA
Website.
13)
Metam
Sodium
as
an
Alternative
to
Methyl
Bromide
for
Fruit
and
Vegetable
Production
and
Orchard
Replanting.
U.
S.
EPA.
On
the
EPA
Website.
14)
Strawberry
Response
to
Fumigants
applied
by
Drip
Irrigation
Systems.
Tom
Trout
and
Husein
Ajwa.
On
the
EPA
Website.
15)
Chloropicrin
application
in
Italy
by
soil
injection
and
drip
irrigation:
Effect
against
soil
borne
fungal
pathogen.
A.
Minuto,
et
al.
On
the
EPA
Website.
16)
Evaluation
of
the
Weed
Control
Efficacy
of
Chloropicrin
in
Strawberry,
Milt
Haar
et
al.
Report
to
California
Strawberry
Commission.
2000.
17)
Replacing
Methyl
Bromide
for
Preplant
Soil
Fumigation
with
1,3­
D,
Chloropicrin
and
Tillam
Combination
Treatments.
U.
S.
EPA.
18)
Letter
to
Jackie
Maxwell,
California
Citrus
Nursery
Advisory
Board
from
Gary
Caviglia,
Crystal
Cove
Farms.
Citrus
Chloropicrin
Studies:
No
formal
studies
of
alternatives
have
been
conducted
directly
on
citrus
nursery
production
in
California.
With
respect
to
the
critical
pests
of
citrus
nurseries,
nematodes,
diseases
and
weeds,
work
conducted
in
deciduous
nurseries
and
strawberry
is
illustrative.

Please
refer
to
Reference
List
in
worksheet
for
1,3­
D.
Studies
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
(
8)
for
either
nematodes
or
soil
borne
pathogens.

Section
II.
1
References
7,
9,
11­
15
&
17
are
on
the
EPA
website.
2
Authors,
various,
see
above
3
3.
See
above
4
location
of
study:
various,
see
above
5
name
of
alternative:
Chloropicrin.
6
Crop
yield
for
citrus
not
measured
7
Effectiveness:
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
(
8).
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
nursery
situations
(
3,
11,
14).
b.
Control
of
Pathogens.
Chloropicrin
does
not
provide
consistent
control
of
soil
borne
pathogens:
Verticillium
dahliae
(
13,
14,
15),
Rhizoctonia
solani
(
15),
Fusarium
melonis
(
15)
and
F.
lycopersici
(
15)
Phytophthora
cactorum
(
4,
15).
Chloropicrin
did
provide
control
of
Pythium
ultimum
in
nursery
fields
(
11).
c.
Weed
Control.
Neither
Chloropicrin
nor
methyl
bromide
controlled
mallow
(
16)
and
very
high
levels
of
chloropicrin
were
needed
to
control
purslane
and
knotweed
(
16).
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
(
10).
Citrus
Metam
sodium
Studies:
No
formal
studies
of
alternatives
have
been
conducted
directly
on
citrus
nursery
production
in
California.
With
respect
to
the
critical
pests
of
citrus
nurseries,
nematodes,
diseases
and
weeds,
work
conducted
in
deciduous
nurseries
and
strawberry
is
illustrative.
References
are
provided
in
the
worksheet
for
1,3­
D.

Section
I.
1
There
are
no
township
caps
for
metam
sodium
in
California.
Citrus
for
farm
planting
must
be
certified.
California
nursery
stock
regulations
require
citrus
to
be
commercially
clean.
Section
II.
1
References
7,
9
,
11­
15
&
17
are
on
the
EPA
website.
2
Authors,
various,
see
above
3
See
above
4
location
of
study:
various,
see
above
5
name
of
alternative:
metam
sodium.
6
Crop
yield
for
citrus
not
measured
7
Effectiveness
a.
Nematode.
Control
of
Nematodes.
While
nematode
control
has
been
achieved
in
various
commodity
crops
(
12,
13),
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
root­
knot
nematode
(
9)
and
Heterodera
carotae
(
7)
).
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,
9,
grower
communication).
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
(
9).
Citrus
AlternativBasamid
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
(
8).

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.
Citrus
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
(
8).
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.

Soilless
substrates
do
constitute
a
significant
proportion
of
the
media
used
in
tree
nurseries
but
the
industry
has
been
unable
to
escape
the
necessity
of
including
soil
in
the
blend.
The
reason
for
this
has
to
do
with
the
survival
of
the
trees
when
planted
in
the
orchard.
When
the
orchard
operator
plants
his
tree
into
native
soils,
the
textural
interface
between
the
soil
blend
from
the
nursery
and
the
orchard
soil
cannot
be
too
great,
or
water
will
not
move
properly
across
that
interface,
resulting
in
roots
that
are
either
asphyxiated
due
to
drowning
(
more
common)
or
drying
out
(
less
common).
As
long
as
a
certain
volume
of
soil
is
present
in
the
nursery
soil,
water
will
be
properly
conducted
across
the
interface
between
nursery
and
native
soils,
and
trees
can
be
adequately
irrigated.

Soilless
culture
is
less
acceptable
to
the
nursery
that
supplies
trees
foer
commercial
planting
than
for
one
that
supplies
the
garden
center/
retail
trade.
Orchard
operators
need
every
advantage
available
to
them,
and
their
success
or
failure
depends
in
large
part
on
the
quality
of
trees
that
they
use
to
establish
the
orchard.
The
nursery
stock
for
commercial
plantings
requires
a
large
root
biomass
in
the
purchased
product
to
produce
a
successful
grove
of
trees
(
3,
grower
communication).
There
is
no
tolerance
for
a
tree
that
is
handicapped
by
a
small
infestation
of
nematodes,
or
a
slight
touch
of
soil
fungus.
While
these
might
seem
unimportant
to
the
layman,
such
deficiencies
can
easily
cause
a
cropping
performance
of
5%
less
than
clean
trees,
and
this
can
spell
the
difference
between
profit
and
loss
for
the
farmer.
The
standard
for
cleanliness
that
applies
to
nurseries
that
supply
the
agricultural
industry
is
high,
and
this
is
a
cornerstone
of
the
continuing
success
of
the
nursery
and
orchard
industries.
Generally,
trees
produced
by
soilless
culture
(
container
trees)
do
not
meet
the
demand
of
the
commercial
consumer.
One
grower
in
this
consortium,
who
produces
container
lemon
trees
for
commercial
planting
for
a
niche
market
in
two
counties
is
the
exception.
Soil
solarization
is
not
an
option
for
cooler,
coastal
growing
areas.
Solarization
also
does
not
control
nematodes
and
diseases
deeper
than
8­
12"
(
3).

Steam
is
an
alternative
for
container
growers
who
may
already
have
steam
heat
in
a
greenhouse
setting.
The
costs
of
establishing
a
steam
plant,
and
subsequent
energy
costs
are
prohibitive
for
growers
of
trees
for
commercial
planting.

Although
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
alone
or
in
combination
can
replace
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
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)

See
attachments
[
Insert
Study
Title]
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)
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
0.00
Comments:

There
is
no
data
from
growers
to
use
here.

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:
See
attachments
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
$
0.00
Comments:

No
experience
with
alternative
methods
or
chems
for
production
for
commercial
plantings
OMB
Control
#
2060­
0482
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:
[
Insert
name
of
alternative]

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

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,

you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
the
comment
section
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.

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.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Custom
per
Area
$
0.00
User
Total
per
area
$
0.00
Comments:

OMB
Control
#
2060­
0482
[
Insert
name
of
alternative]

Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

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

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

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

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

Enter
custom
operation
costs
that
change
in
Col.
B.

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

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

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

The
citrus
nursery
growers
are
entertaining
proposals
for
alternative
research.
At
this
date,
no
proposals
have
been
approved.
Worksheet
4.
Alternatives
­
Future
Research
Plans
1.

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

x
Virtually
impermeable
film
(
VIF)

Cultural
practices
(
please
specify)

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

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

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

3.

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

4.

$

5.

6.

When
do
you
expect
these
to
occur?

7.

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

1
2
Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
on
January
1,
2005?

Research
with
alternatives
that
demonstrates
satisfactory
control
of
nematodes
and
diseases
so
stock
can
be
certifie
Adequate
weed
control
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?

Do
you
have
access
to
recycled
methyl
bromide?

none
by
the
ass'n
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.

Growers
have
conducted
trials
with
chemical
alternatives
on
their
nurseries
Worksheet
5.
Additional
Information
(
continued)

8.

0
­
5,000
sq.
ft.

5,001
­
10,000
sq.
ft.

10,001
­
20,000
sq.
ft.

1
20,001
­
40,000
sq.
ft.

40,001
­
80,000
sq.
ft.

80,001
­
160,000
sq.
ft.

2
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
9­
Sep­
02
James
W.
Wells
consultant
Sept.
9,
2002
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#
ified.
es
the
time
ining
spond
to
a
ollection
of
omide.
An
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
4,200
5.
Area
Treated
with
Methyl
Bromide
2005
105
acres
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

2006
4,200
lbs.
Area
Treated
105
acres
units
2007
4,200
lbs.
Area
Treated
105
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
Citrus
and
Avocado
Growers
Citrus
and
Avocado
Southern
and
Central
California
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.

Potential
Alternatives
1,3­
D
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
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.
