For
EPA
Use
Only
ID
#
______________
SECTOR
_________________________

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

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

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

EPA
Form
#
7620­
18a
Pre
Plant
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
The
information
contained
in
this
application
is
critical
to
process
and
assess
the
need
for
methyl
bromide.
Filling
out
this
application
in
its
entirety
will
bolster
the
U.
S.
government's
ability
to
strengthen
the
nomination
package
for
the
international
review
boards.
OMB
Control
#
2060­
0482
WHY
IS
THIS
INFORMATION
NEEDED?
2003
Application
for
Critical
Use
Exemption
of
Methyl
Bromide
for
Pre
Plant
Use
in
2005
and
beyond
in
the
United
States
Click
on
the
Instructions
tab
located
at
the
bottom
of
the
screen
for
additional
information.
WHO
APPLIES?

STATE
CONTACTS
HOW
DO
I
APPLY?

IS
MY
INFORMATION
CONFIDENTIAL?

WHEN
IS
THE
INFORMATION
NEEDED?

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

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

WHERE
DO
I
SUBMIT
THE
APPLICATION?

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

If
you
have
general
questions
about
this
application
call:

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

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

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

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

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

EXCEL
USER
TIPS
Inserting
a
blank
worksheet:

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

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

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

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

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

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

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

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

Navigating
between
worksheets
The
set
of
four
arrows
on
the
bottom
left
of
the
screen
will
help
you
navigate
between
worksheets.
This
is
necessary
to
access
the
remaining
worksheet
tabs
in
the
workbook
that
are
not
viewable.
The
two
arrows
with
vertical
lines
to
either
the
left
or
right
will
take
you
to
the
first
worksheet
and
to
the
last
worksheet
respectively
in
the
workbook.
The
inner
two
arrows
allow
you
move
the
worksheet
tabs
to
the
right
or
to
the
left
incrementally.
The
two
arrows
on
the
bottom
right
of
the
screen
allow
you
to
move
the
worksheet
that
you
are
viewing
to
the
right
or
to
the
left.
This
is
useful
if
the
viewable
area
of
on
the
screen
is
smaller
than
the
entire
page
that
is
in
the
7.
Change
the
title
row
of
the
newly
pasted
worksheet
from
the
old
worksheet
number
to
be
consistent
with
the
worksheet
tab.
EPA
Form
#
7620­
18a
Pre
Plant
If
you
would
like
to
print
all
worksheets
that
are
contained
in
this
workbook,
go
to
the
menu
bar
at
the
top
of
the
screen
and
select
"
File"
and
then
"
Print."
Then
in
the
section
of
the
menu
that
appears
called
"
Print
what,"
select
"
Entire
Workbook."
Yes
No
x
x
Cell
Fax
x
Cell
Fax
Address
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
The
following
information
will
be
used
to
determine
the
amount
of
methyl
bromide
requested
and
the
contact
person
for
this
request.
It
is
important
that
we
know
whom
to
contact
in
case
we
need
additional
information
during
the
review
of
the
application.

Is
this
information
Confidential
Business
Information?

B­
18
Food
Safety
and
Toxicology
Bldg.
Agronomic
Michigan
State
University
East
Lansing,
MI
48824
Economic
517­
663­
5608
Salisbury
Management
Services,
Inc.
2487
S.
Michigan,
P.
O.
Box
10
Eaton
Rapids,
MI
48827­
0010
Agronomic
Economic
Date
Title
Information
in
this
application
may
be
aggregated
with
information
from
other
applications
and
used
by
the
United
States
government
to
justify
claims
in
the
national
nomination
package
that
a
particular
use
of
methyl
bromide
be
considered
"
critical"
and
authorized
for
an
exemption
beyond
the
2005
phaseout.
Use
of
aggregate
data
will
be
crucial
to
making
compelling
arguments
in
favor
of
critical
use
exemptions.
By
signing
below,
you
agree
now
to
assert
any
claim
of
confidentiality
that
would
affect
the
disclosure
by
EPA
of
aggregate
information
based
in
part
on
information
contained
in
this
application.
Print
Name
I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.

Signature
Title
Signature
Date
Print
Name
If
yes,
the
applicant
assumes
responsibility
for
the
secure
transmission
of
electronic
submissions.

Applicant
Name
Primary
Contact
Contact
Name
(
Check
One)
Specialty
Diane
Brown­
Rytlewski
Michigan's
Field
Grown
Herbaceous
Perennial
Growers
E­
mail
Address
Address
Daytime
Phone
517­
663­
5600
bdartt@
salisburymanagment.
com
Barbara
Dartt
517­
432­
0480
rytlews1@
msu.
edu
517­
353­
4995
Specialty
Daytime
Phone
E­
mail
Address
Alternate
Contact
Contact
Name
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
1.
Location
2.
Crop/
Crop
Grouping
3.

6
3
2
4.
Climate
Zone
Zones:
(
check
all
that
apply)

5.
Soil
Type
&
Organic
Matter
Light
x
Medium
x
Heavy
x
0
to
2
%
x
2
to
5
%
x
over
5
%
x
6.
Yes
x
Pounds
213,477
No
7.
Yes
CUE
#

No
x
8.

Year
2005
Acres
2006
Acres
2007
Acres
9.

10.

11.
Yes
Lbs
No
x
12.
Yes
Lbs
No
x
Please
explain
why
methyl
bromide
is
being
requested.
(
Insert
number
or
percentage
of
users
in
each
category)
0
­
25
acres
lbs.
35
lbs.
What
is
the
amount
of
methyl
bromide
being
requested
by
this
application
?
(
Do
NOT
include
QPS
amounts)

10,500
Has
this
applicant
previously
applied
for
Critical
Use
Exemption
of
methyl
bromide?
Range
of
acres
farmed
by
growers
included
in
this
application
Is
this
applicant
eligible
for
Quarantine
and
Preshipment
(
QPS)
uses
of
methyl
bromide?
100
­
200
acres
200
­
400
acres
25
­
50
acres
50
­
100
acres
Michigan,
and
one
grower
in
Illinois
herbaceous
perennials­
two
year
seeded,
three
year
transplant,
two
year
transplant
30
(
Indicate
the
soil
type
and
percent
organic
matter
where
methyl
bromide
would
be
applied.)

Soil
Type:

Organic
Matter:

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

Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
after
January
1,
2005?
to
control
weeds,
nematodes
and
soil­
borne
plant
pathogens
in
field
grown
herbaceous
perennials
Do
you
have
access
to
recycled
methyl
bromide?

If
yes,
please
specify
amount
(
in
pounds).
If
yes,
please
specify
amount
(
in
pounds).
20
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
Total
Pounds
Active
Ingredient
(
a.
i.)
of
Methyl
Bromide
12388
Total
Area
to
be
Treated
2
1
(
check
all
that
apply)
(
Indicate
the
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map
located
at
the
end
of
this
workbook
or
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html.)

1____
2a____
2b____
3a____
3b____
4a____
4b____
5a_
x_
5b_
x_
6a_
x__
6b____
7a____
7b____
8a____
8b____
9a____
9b____
10a____
10b____
11____
over
400
acres
OMB
Control
#
2060­
0482
we
hope
to
begin
phasing
in
alternatives
after
research
is
completed
in
2004­
20066.
lbs.
7000
Please
see
worksheet
titled
CUE
summary
Please
explain
why
there
may
be
variations
in
the
pounds
or
acres
treated
from
year
to
year.
EPA
Form
#
7620­
18a
Pre
Plant
Worksheet
Title
2­
A
Methyl
Bromide
­
Crop
&
Pest
Information
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

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

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

This
worksheet
provides
data
in
actual
usage
for
1997­
2002.

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

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

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

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

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

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

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

Instructions
specific
to
each
worksheet
are
located
at
the
top
of
each
sheet.
Worksheet
2.
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
1.
Crop/
Crop
Grouping
or
Consortium
2.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept
Oct
Nov
Dec
2.
Fumigation
and
Crop
Timeline
Beginning
Fumigation
Cycle
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Continuation
of
Fumigation
Cycle
(
if
needed)

Month
13
Month
14
Month
15
Month
16
Month
17
Month
18
Month
19
Month
20
Month
21
Month
22
Month
23
Month
24
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Which
month
does
your
fumigation
cycle
start?
(
check
only
one)

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

Comments:
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
Michigan's
Field
Grown
Herbaceous
Perennial
Growers
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)

Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
OMB
Control
#
2060­
0482
3.
Target
Pest(
s)
or
Pest
Problem(
s):

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

6.
Representative
User
:
Source
Other
descriptive
factors
regarding
representative
user:
Acres
Acres
(
Please
provide
descriptive
factors
regarding
your
operation.)

Average
Farm
Size
Average
acres
in
this
crop
Average
Area
Treated
with
Methyl
Bromide:
Acres
(
Please
identify
the
top
target
pests
or
pest
problems.
Provide
at
least
common
name
and
genus
and
species
if
possible.
Additional
pests
or
pest
problems
can
be
provided
as
an
attachment.)
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
Common
Name
Genus
Describe
a
few
crops
that
could
follow
this
crop:
Source
Threshold
EPA
Form
#
7620­
18a
Pre
Plant
OMB
Control
#
2060­
0482
Percentage
of
Total
Growing
Area
(
Please
estimate
the
percentage
of
the
consortia's
total
growing
area
with
a
moderate
to
severe
problem
with
these
pests.
Describe
source
of
information
such
as
a
survey
or
expert
estimate.)
(
Please
provide
the
economic
threshold
information
for
each
pest.
Describe
year
and
source
of
information
such
as
survey
or
expert
estimate.)

Units
(
e.
g.
pests/
sq
ft)
EPA
Form
#
7620­
18a
Pre
Plant
1.
Crop/
Crop
Grouping
or
Consortium
2.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept
Oct
Nov
Dec
2.
Fumigation
and
Crop
Timeline
Beginning
Fumigation
Cycle
J
F
M
A
M
J
J
A
S
O
N
D
Fallow
Land
Preparation
Fumigation
Planting
Harvest
Establish
Cover
Crop
Other
Key
Pest
Steps
Continuation
of
Fumigation
Cycle
(
if
needed)

J
F
M
A
M
J
J
A
S
O
N
D
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Establish
Cover
Crop
Other
Key
Pest
Steps
Pre
Plant
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Comments:
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Two­
year
seeded
herbaceous
perennials
(
Delphinium
'
Round
Table
Mix'
is
representative
crop)

(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Which
month
does
your
fumigation
cycle
start?
(
check
only
one)
OMB
Control
#
2060­
0482
Worksheet
2­
A(
2a)
Methyl
Bromide
­
Crop
&
Pest
Information
­
0482
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
3.
Target
Pest(
s)
or
Pest
Problem(
s):

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

6.
Representative
User
:

Pre
Plant
Hemerocallis,
Hosta,
Iris,
Tradescantia
etc
Keik
Yellow
Nutsedge
N.
root
knot
nematode
Rorippa
sylvestris
Canada
Thistle
Cirsium
arvense
(
Please
identify
the
top
target
pests
or
pest
problems.
Provide
at
least
common
name
and
genus
and
species
if
possible.
Additional
pests
or
pest
problems
can
be
provided
as
an
attachment.)

eftover
Herbaceous
Perennial
Cro
Source
Hemerocallis,
Hosta,
Iris,
Tradescantia
etc
Cyperus
esculentus
(
Please
provide
descriptive
factors
regarding
your
operation.)

Average
Farm
Size
Acres
Average
acres
in
this
crop
Average
Area
Treated
with
Methyl
Bromide:
Meloidogyne
hapla
Source
Threshold1
MSU
weed
scientists
MSU
nematologist
10
50­
70
Describe
a
few
crops
that
could
follow
this
crop:
700
60
280
Other
descriptive
factors
regarding
representative
user:
Acres
Acres
The
overall
'
representative
user'
is
a
composite
of
2
large,
and
one
small
sized
growing
operations;
one
base
budget
was
composed
by
each
of
three
growers
for
the
two
year
seeded,
three
year
transplant
and
two
year
transplant
crop
groupings.
The
grower
used
for
the
two­
year
seeded
budget
has
60
acres
in
2
yr
seeded,
240
acres
in
2yr
transplant,
and
300­
400
acres
in
3
yr
transplant.
1Plants
grown
"
for
planting"
must
be
free
of
weeds,
nematodes
and
diseases.
Units
(
e.
g.
pests/
sq
ft)
Common
Name
Genus
75
50
MSU
weed
scientists
MSU
weed
scientists
100
Percentage
of
Total
Growing
Area
(
Please
estimate
the
percentage
of
the
consortia's
total
growing
area
with
a
moderate
to
severe
problem
with
these
pests.
Describe
source
of
information
such
as
a
survey
or
expert
estimate.)
(
Please
provide
the
economic
threshold
information
for
each
pest.
Describe
year
and
source
of
information
such
as
survey
or
expert
estimate.)
1.
Crop/
Crop
Grouping
or
Consortium
2.
M
J
J
A
S
O
N
D
J
F
M
A
2.
Fumigation
and
Crop
Timeline
Beginning
Fumigation
Cycle
M
J
J
A
S
O
N
D
J
F
M
A
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Cover
Crop
Cultivate
(
Mechanical)
Hand
Weeding
Insecticide
&
Fungicide
Continuation
of
Fumigation
Cycle
(
if
needed)
M
J
J
A
S
O
N
D
J
F
M
A
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Cultivate
(
Mechanical)
Hand
Weeding
Insecticide
&
Fungicide
Which
month
does
your
fumigation
cycle
start?
(
check
only
one)

for
this
crop
grouping,
methyl
bromide
is
applied
1x
times
per
3
years.
YEAR
2
Comments:

harvest
sometimes
stretches
into
May
of
the
following
year
Worksheet
2­
A(
2b).
Methyl
Bromide
­
Crop
&
Pest
Information
Three
year
transplanted
herbaceous
perennials
(
Phlox
subulata
is
representative
crop).

(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)

YEAR
1
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
3.
Target
Pest(
s)
or
Pest
Problem(
s):

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

6.
Representative
User
:
Fusarium,
Phytophthora,
Pythium,
Rhizoctonia
N.
root
knot
nematode
lesion
nematodes
weeds
Meloidogyne
hapla
Pratylenchus
sp.

as
described
in
2A
(
2a)
soil­
borne
plant
diseases
Source
10
(
Please
provide
descriptive
factors
regarding
your
operation.)

Other
descriptive
factors
regarding
representative
user:
Acres
Acres
Average
Farm
Size
Average
acres
in
this
crop
Average
Area
Treated
with
Methyl
Bromide:
Acres
This
crop
is
assumed
to
be
sold
wholesale
in
very
large
volume.
Price
is
FOB
at
the
growing
operation.
The
overall
'
representative
user'
is
a
composite
of
2
large,
and
one
small
sized
growing
operations;
one
base
budget
was
composed
by
each
of
three
growers
for
the
two
year
seeded,
three
year
transplant
and
two
year
transplant
crop
groupings.
The
grower
used
for
the
three­
year
transplant
budget
has
2
acres
in
2
yr
seeded,
30
acres
in
2yr
transplant,
and
268
in
3
yr
transplants.
1Plants
grown
"
for
planting"
must
be
free
of
weeds,
nematodes
and
diseases.
stem
and
bulb
nematodes
Ditylenchus
sp.

Describe
a
few
crops
that
could
follow
this
crop:
300
30
75
ajuga,
sedums,
artemesia,
Source
(
Please
identify
the
top
target
pests
or
pest
problems.
Provide
at
least
common
name
and
genus
and
species
if
possible.
Additional
pests
or
pest
problems
can
be
provided
as
an
attachment.)
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
Common
Name
Genus
Threshold1
MSU
nematologist
OMB
Control
#
2060­
0482
50­
70
10
Percentage
of
Total
Growing
Area
(
Please
estimate
the
percentage
of
the
consortia's
total
growing
area
with
a
moderate
to
severe
problem
with
these
pests.
Describe
source
of
information
such
as
a
survey
or
expert
estimate.)
(
Please
provide
the
economic
threshold
information
for
each
pest.
Describe
year
and
source
of
information
such
as
survey
or
expert
estimate.)

Units
(
e.
g.
pests/
sq
ft)
EPA
Form
#
7620­
18a
Pre
Plant
1.
Crop/
Crop
Grouping
or
Consortium
2.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept
Oct
Nov
Dec
2.
Fumigation
and
Crop
Timeline
Beginning
Fumigation
Cycle
J
F
M
A
M
J
J
A
S
O
N
D
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Fertilize
Irrigate
Hand
Weed
Continuation
of
Fumigation
Cycle
(
if
needed)

J
F
M
A
M
J
J
A
S
O
N
D
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Fertilize
Irrigate
Hand
Weed
Which
month
does
your
fumigation
cycle
start?
(
check
only
one)

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

Comments:
Worksheet
2­
A(
2c).
Methyl
Bromide
­
Crop
&
Pest
Information
Two­
year
transplanted
herbaceous
perennials
(
Hosta
is
representative
crop)

(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)

Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
OMB
Control
#
2060­
0482
3.
Target
Pest(
s)
or
Pest
Problem(
s):

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

6.
Representative
User
:
Inula
brittanica,
Rorippa
sylvestris
leftover
perennial
crop,
crop
debris
(
Source
of
diseases,
nematodes)
yellow
woodsorrel
Meloidogyne
hapla
Oxalis
stricta
inula,
keik
Source
N.
root
knot
nematode
50
MSU
weed
scientists
MSU
weed
scientists
(
Please
provide
descriptive
factors
regarding
your
operation.)

Other
descriptive
factors
regarding
representative
user:
Acres
Acres
Average
Farm
Size
Average
acres
in
this
crop
Average
Area
Treated
with
Methyl
Bromide:
Acres
The
overall
'
representative
user'
is
a
composite
of
2
large,
and
one
small
sized
growing
operations;
one
base
budget
was
composed
by
each
of
three
growers
for
the
two
year
seeded,
three
year
transplant
and
two
year
transplant
crop
groupings.
The
grower
used
for
the
2­
year
transplant
budget
grows
only
2
yr
transplants.
1Plants
grown
"
for
planting"
must
be
free
of
weeds,
nematodes
and
diseases.
canada
thistle
Cirsium
arvense
Describe
a
few
crops
that
could
follow
this
crop:
30
30
5
Ajuga,
Vinca
minor,
daylily
Source
(
Please
identify
the
top
target
pests
or
pest
problems.
Provide
at
least
common
name
and
genus
and
species
if
possible.
Additional
pests
or
pest
problems
can
be
provided
as
an
attachment.)
Worksheet
2­
A.
Methyl
Bromide
­
Crop
&
Pest
Information
Common
Name
Genus
Threshold1
MSU
nematologist
50­
70
5­
10
100
75
MSU
weed
scientists
Percentage
of
Total
Growing
Area
(
Please
estimate
the
percentage
of
the
consortia's
total
growing
area
with
a
moderate
to
severe
problem
with
these
pests.
Describe
source
of
information
such
as
a
survey
or
expert
estimate.)
(
Please
provide
the
economic
threshold
information
for
each
pest.
Describe
year
and
source
of
information
such
as
survey
or
expert
estimate.)

Units
(
e.
g.
pests/
sq
ft)
EPA
Form
#
7620­
18a
Pre
Plant
Column
A:

Column
B:

Column
C:

A
B
C
Total
Actual
Pounds
a.
i.
of
Methyl
Bromide
Applied
per
Year
Total
Actual
Acres
Treated
per
Year
Average
Pounds
a.
i.
Applied
per
Acre
per
Year
1997
227850
651
350
1998
223300
638
350
1999
214900
614
350
2000
197400
564
350
2001
111300
318
350
2002
112350
321
350
Worksheet
2­
B.
Methyl
Bromide
­
Historical
Use
for
1997­
2002
Total
Actual
Pounds
a.
i.
of
Methyl
Bromide
Applied
per
Year
Enter
the
total
actual
pounds
active
ingredient
(
a.
i.)
of
methyl
bromide
applied.
Note:
This
number
should
be
the
total
pounds
a.
i.
applied
by
the
individual
user
or
the
entire
consortium,
for
the
year
indicated.
Include
only
the
pounds
active
ingredient
of
methyl
bromide.
Do
not
include
the
pounds
of
chloropicrin
that
may
be
part
of
the
same
product.

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

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

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

______
1___
times
per
__
year__________
OMB
Control
#
2060­
0482
fewer
acres
treated
each
year
due
to
less
total
production
and
higher
production
per
acre
Comments:
EPA
Form
#
7620­
18a
Pre
Plant
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

Column
F:

Column
G:

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

If
this
application
is
for
multiple
crops/
crop
groupings
(
e.
g.
nurseries
producing
evergreens,
deciduous,
and
forbs)
please
indicate
the
proportion
of
land
area
allocated
to
each
crop/
crop
grouping.
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Species
Yield
&
Gross
Revenue
for
2000­
2002
Market
Categories
Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
crop
groupings
in
the
fumigation
cycles
from
2000
to
2002.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
crop
groupings
that
benefit
from
methyl
bromide
in
the
fumigation
cycle.
If
multiple
crops/
crop
groupings
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
crops/
crop
groupings
during
the
entire
interval.

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

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

Column
B:

Column
C:

Column
D:

Column
E:

Column
F:

Column
G:

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

2000
2
Year
Seeded
#
1
Grade
8,985
1
Root
$
0.460
$
4,133.06
2000
2
Year
Seeded
Liners
18,242
1
Root
$
0.310
$
5,655.05
2000
2
Year
Seeded
TOTAL
27,227
$
9,788.11
2001
2
Year
Seeded
#
1
Grade
15,289
1
Root
$
0.470
$
7,185.94
2001
2
Year
Seeded
Liners
31,042
1
Root
$
0.335
$
10,398.99
2001
2
Year
Seeded
TOTAL
46,331
$
17,584.93
2002
2
Year
Seeded
#
1
Grade
14,874
1
Root
$
0.497
$
7,392.26
2002
2
Year
Seeded
Liners
30,198
1
Root
$
0.357
$
10,780.77
2002
2
Year
Seeded
TOTAL
45,072
$
18,173.03
OMB
Control
#
2060­
0482
Gross
revenue
per
acre
for
each
market
category
and
or
each
crop/
crop
grouping
may
be
calculated
using
the
data
you
entered
as
price
times
yield.
If
revenue
is
not
equal
to
price
times
yield,
you
may
enter
a
different
revenue
amount,
but
please
explain
the
difference
in
the
comments
section
below.
Gross
Revenue
Price
Enter
the
unit
of
measurement
for
each
crop/
species
(
lbs,
cwt,
carton,
bin).
If
not
by
weight,
specify
in
the
comments
section
the
average
weight
of
the
measure.
Units
of
Measurement
Enter
average
prices
received
by
the
users
for
that
crop/
crop
grouping
and
market
category.
Average
price
over
all
categories
can
be
calculated
separately,
if
needed.
Enter
marketing
categories
that
determine
prices
received,
for
example,
grade
(
size,
color),
timeliness
(
early
season,
late
season),
or
end
use
(
fresh,
processing).
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
if
lack
of
methyl
bromide
would
effect
the
yields
in
each
category.

Enter
the
yield
per
acre,
or
the
proportion
of
total
yields,
obtained
for
that
category.
For
perennial
crops,
please
enter
yields
at
full
production.
Be
sure
to
indicate
yields
at
other
stages
in
the
timeline
in
Worksheet
2­
A.
Yield
Comments:
If
this
application
is
for
multiple
crops/
crop
groupings
(
e.
g.
nurseries
producing
evergreens,
deciduous,
and
forbs)
please
indicate
the
proportion
of
land
area
allocated
to
each
crop/
crop
grouping.

based
on
the
three
representative
growers,
the
proportion
of
land
allocated
to
this
crop
grouping
would
be
6%
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Species
Yield
&
Gross
Revenue
for
2000­
2002
Market
Categories
Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
crop
groupings
in
the
fumigation
cycles
from
2000
to
2002.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
crop
groupings
that
benefit
from
methyl
bromide
in
the
fumigation
cycle.
If
multiple
crops/
crop
groupings
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
crops/
crop
groupings
during
the
entire
interval.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops/
crop
groupings
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.
Year
Crops/
Crop
Groupings
EPA
Form
#
7620­
18a
Pre
Plant
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

Column
F:

Column
G:

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

2000
3
Year
Transplanted
Phlox
subulata
20,755
1/
2
Flat
(
11x11")
$
3.60
$
74,716.98
2001
3
Year
Transplanted
Phlox
subulata
20,795
1/
2
Flat
(
11x11")
$
3.60
$
74,863.64
2002
3
Year
Transplanted
Phlox
subulata
20,476
1/
2
Flat
(
11x11")
$
3.60
$
73,714.29
If
this
application
is
for
multiple
crops/
crop
groupings
(
e.
g.
nurseries
producing
evergreens,
deciduous,
and
forbs)
please
indicate
the
proportion
of
land
area
allocated
to
each
crop/
crop
grouping.

based
on
the
three
representative
growers,
the
proportion
of
land
allocated
to
this
crop
grouping
would
be
65%
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Species
Yield
&
Gross
Revenue
for
2000­
2002
Market
Categories
Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
crop
groupings
in
the
fumigation
cycles
from
2000
to
2002.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
crop
groupings
that
benefit
from
methyl
bromide
in
the
fumigation
cycle.
If
multiple
crops/
crop
groupings
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
crops/
crop
groupings
during
the
entire
interval.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops/
crop
groupings
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.
Year
Crops/
Crop
Groupings
Comments:
methyl
bromide
is
applied
1x
per
three
years
for
this
crop
grouping.
The
crop
is
designated
as
3
year
transplant
because
production
stretches
over
parts
of
three
years.
OMB
Control
#
2060­
0482
Gross
revenue
per
acre
for
each
market
category
and
or
each
crop/
crop
grouping
may
be
calculated
using
the
data
you
entered
as
price
times
yield.
If
revenue
is
not
equal
to
price
times
yield,
you
may
enter
a
different
revenue
amount,
but
please
explain
the
difference
in
the
comments
section
below.
Gross
Revenue
Price
Enter
the
unit
of
measurement
for
each
crop/
species
(
lbs,
cwt,
carton,
bin).
If
not
by
weight,
specify
in
the
comments
section
the
average
weight
of
the
measure.
Units
of
Measurement
Enter
average
prices
received
by
the
users
for
that
crop/
crop
grouping
and
market
category.
Average
price
over
all
categories
can
be
calculated
separately,
if
needed.
Enter
marketing
categories
that
determine
prices
received,
for
example,
grade
(
size,
color),
timeliness
(
early
season,
late
season),
or
end
use
(
fresh,
processing).
Itemize
or
aggregate
these
factors
to
the
extent
appropriate
if
lack
of
methyl
bromide
would
effect
the
yields
in
each
category.

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

Column
B:

Column
C:

Column
D:

Column
E:

Column
F:

Column
G:

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

2000
2
Year
Transplanted
#
1
(
2­
eye
splits)
250,000
Divisions
0.75
$
187,500
$
2000
2
Year
Transplanted
1­
eye
splits
200,000
Divisions
0.30
$
60,000
$
2000
2
Year
Transplanted
TOTAL
450,000
247,500
$
2001
2
Year
Transplanted
#
1
(
2­
eye
splits)
150,000
Divisions
1.00
$
150,000
$
2001
2
Year
Transplanted
1­
eye
splits
100,000
Divisions
0.30
$
30,000
$
2001
2
Year
Transplanted
TOTAL
250,000
180,000
$
2002
2
Year
Transplanted
#
1
(
2­
eye
splits)
200,000
Divisions
0.88
$
176,000
$
2002
2
Year
Transplanted
1­
eye
splits
150,000
Divisions
0.30
$
45,000
$
2002
2
Year
Transplanted
TOTAL
350,000
221,000
$

If
this
application
is
for
multiple
crops/
crop
groupings
(
e.
g.
nurseries
producing
evergreens,
deciduous,
and
forbs)
please
indicate
the
proportion
of
land
area
allocated
to
each
crop/
crop
grouping.

based
on
the
three
representative
growers,
the
proportion
of
land
allocated
to
this
crop
grouping
would
be
29%
Worksheet
2­
C.
Methyl
Bromide
­
Crop/
Species
Yield
&
Gross
Revenue
for
2000­
2002
Market
Categories
Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
crop
groupings
in
the
fumigation
cycles
from
2000
to
2002.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
crop
groupings
that
benefit
from
methyl
bromide
in
the
fumigation
cycle.
If
multiple
crops/
crop
groupings
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
crops/
crop
groupings
during
the
entire
interval.

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

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

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

Column
B:

Column
C:

Column
D:

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

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

For
inputs
and
operations
detailed
in
Columns
B
and
D,
total
costs
can
be
calculated
as
Column
B
times
Column
D.
Otherwise,
enter
total
cost
of
the
input
or
operation.
As
a
check,
you
may
add
up
Column
E
to
obtain
an
estimate
of
total
variable
operating
costs.
These
will
not
include
fixed
and
overhead
costs,
nor
a
return
to
the
owners'
labor.
It
should,
therefore,
be
less
than
gross
revenues
calculated
in
Worksheet
2­
C.
If
it
is
not,
please
explain
(
for
example,
unusually
poor
yields
or
unusually
poor
prices).
For
perennial
crops,
Column
E
should
only
be
totaled
for
the
years
at
full
production.
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
methyl
bromide,
including
any
material
costs,
for
example,
tarps.
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
units
of
measurement.

Yield
For
harvest
operations,
indicate
average
yields
or
representative
yields
from
Worksheet
2­
C.
OMB
Control
#
2060­
0482
Worksheet
2­
D(
1&
2).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
2002
Enter
all
operating
costs
incurred
during
a
fumigation
cycle.
Users
with
a
relatively
short
fumigation
cycle
(
less
than
five
years)
should
use
version
D(
1);
users
cultivating
perennial
crops
should
use
version
D(
2).
Users
with
multiple
crops,
either
on
the
same
area
in
a
single
fumigation
cycle
or
on
different
areas
treated
separately,
should
copy
this
sheet
and
provide
costs
for
each
crop.
If
multiple
crops
are
cultivated
sequentially
following
a
single
fumigation,
replace
fumigation
costs
in
Pre­
plant
Operations
with
any
additional
pest
control
costs
used
prior
to
the
following
crops.
If
a
fallow
season
is
an
important
part
of
the
fumigation
cycle,
include
costs
incurred
(
for
example,
cultivating
a
cover
crop)
as
a
separate
line
or
as
a
separate
sheet,
if
costs
are
extensive.
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

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

This
field
is
required
only
for
methyl
bromide.
However,
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.
Operation
/
Input
EPA
Form
#
7620­
18a
Pre
Plant
B
C
D
E
Quantity
Used
per
Acre
Units
(
lbs,
hours,
etc)
Unit
Cost
($)
Total
Cost
per
Acre
($)

Constant
Cost
per
Acre
($)
Cost
per
Unit
of
Yield
($)
Yield
Total
Cost
per
Acre
($)

Grading
/
Packing
/
Storage
Other
Costs
Harvest
Operations
Labor
Hauling
Material
Fungicide
Nematicide
Irrigation
Labor
(
manual)

Fuel
/
Machine
Labor
Other
Costs
Cultural
Operations
Seed
/
Seedlings
Fertilizer
/
Soil
Amendments
Pesticides
Insecticide
Herbicide
application
Irrigation
Other
costs
Pre­
plant
Operations
Land
preparation
Fumigation
product
(
methyl
bromide)
Operation
/
Input
OMB
Control
#
2060­
0482
A
Worksheet
2­
D(
1).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
2002
EPA
Form
#
7620­
18a
Pre
Plant
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)
B
(
3)
C
(
3)
D
(
3)
E
(
3)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

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

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

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

PRE
PRODUCTION
YEARS
_______
EPA
Form
#
7620­
18a
Pre
Plant
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)
B
(
3)
C
(
3)
D
(
3)
E
(
3)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

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

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
148
Fumigation
product
312.5
lbs
MB/
chl
$
2.85
891
application
809
Irrigation
Seed
and
Seeding
287
Other
costs
63
63
Cultural
Operations
Fertilizer/
soil
amendments
73
60
Pesticides
Insecticide
Herbicide
12
Fungicide
356
Custom
Application
of
Fungicide
12
applications
15.00
$
180
Irrigation
70
Hand
Hoeing
&
Trimming
120
hrs
12.00
$
1,440
Fuel/
machine
labor
100
Interest
on
Operating
Cap
2,016
$
6.0%
30
7,273
$
6.0%
164
Dpt
of
Ag
Inspection
20
20
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Digging
&
Transporting
876
Grading/
packing
1,495
Cold
Storage
997
Shipping
1,329
OMB
Control
#
2060­
0482
Worksheet
2­
D(
2a).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops­
2yr
seeded
HARVEST
­
YEAR
2
FULL
PRODUCTION
YEARS
_____

PRE
PRODUCTION
­
YEAR
1
see
addendum
1,
an
explanation
of
the
economics
approach
taken
by
the
economist
who
modelled
the
budgets
for
this
application.
EPA
Form
#
7620­
18a
Pre
Plant
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)
B
(
3)
C
(
3)
D
(
3)
E
(
3)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

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

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
98
Fumigation
product
350
lbs
MB/
chl
$
2.85
998
application
807
Cover
Crop
100
Seedlings
38,000
divisions
$
0.033
1,241
Planting
Labor
1,624
Equipment
Operation
(
Planting)
6
Cultural
Operations
Fertilizer/
soil
amendments
42
150
Pesticides
Insecticide
&
Fungicide
150
600
Custom
Application
of
F
3
application$
15.00
45
15
application
15.00
$
225
Hand
Weeding
10
hours
12.00
$
120
40
hours
12.00
$
480
Irrigation
Labor
&
Operation
1.5
hours
15.00
$
23
3.5
hours
15.00
$
53
Labor
(
manual)

Mechanical
Cultivation
10
times
15.00
$
150
Dpt
of
Ag
Inspection
20
20
Interest
on
Operating
Cap
5,273
$
6.0%
158
13,489
$
6.0%
405
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Cutting
(
Mechanical
Operation)
2.7
hr/
ac
15.00
$
41
Cutting
&
Packaging
(
Labor)
522
hours
12.00
$
6,261
Equpment
Rental
Hi­
Los
435
Truck
495
Trailers
275
see
addendum
1,
an
explanation
of
the
economics
approach
taken
by
the
economist
who
modelled
the
budgets
for
this
application.

OMB
Control
#
2060­
0482
Worksheet
2­
D(
2b).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops
3
yr
transplant
HARVEST
­
YEAR
2
PRE
PRODUCTION
­
YEAR
1
Packing
Materials
20,500
flats
0.21
$
4,305
5,273
$
9,589
$

EPA
Form
#
7620­
18a
Pre
P
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
145
Fumigation
product
400
lbs
MB/
chl
$
2.85
1,140
application
609
Field
clean­
up
125
Irrigation
Seedlings
50,000
plants
$
0.87
44,333
Other
costs
Cultural
Operations
Fertilizer/
soil
amendments
450
lbs
$
0.50
243
450
lbs
0.50
$
243
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
16
man
hours
$
15.00
240
16
man
hours
15.00
$
240
Labor
(
manual)

Interest
on
Operating
Cap
49,159
$
6.0%
988
11,162
$
6.0%
335
Hand
weeding
192
man
hours
12.00
$
2,304
192
man
hours
12.00
$
2,304
Dpt
of
Ag
Inspection
20
20
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Digging
Labor
600
Digging
Equipment
55
Storage
Cost
1,700
Processing
0.03
$
200,000
6,000
OMB
Control
#
2060­
0482
Worksheet
2­
D(
2c).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops
2yr
transplant
HARVEST
­
YEAR
2
PRE
PRODUCTION
­
YEAR
1
see
addendum
1,
an
explanation
of
the
economics
approach
taken
by
the
economist
who
modelled
the
budgets
for
this
application.
50,147
$
11,497
$
61,644
$
Year
1
and
2
Total
Cost
per
Acre
EPA
Form
#
7620­
18a
Pre
Plant
Economist's
comments
for
worksheet
2­
D
(
2a)
two­
year
seeded
Land
preparation:
Includes
soil
test,
disk,
plow,
drag,
float,
apply
fert,
drag,
apply
herbicide,
disk,
drag,
float
­
priced
as
custom
rates
so
includes
some
fixed
expense
Application:
Includes
custom
application,
tarp
removal
and
tarp
disposal
Seed
and
seeding,
other
cost:
Post
planting
field
prep
and
cover
crop
­
cover
crop
is
certified
seed
to
minimize
weed
contamination
Irrigation:
Solid
set
and
hard
hose
­
includes
some
fixed
expense
Fuel,
machine
labor:
Field
Maintenance
­
cultivation
and
driveway
and
ditch
maintenance
­
includes
some
fixed
cost
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
6
months
in
Year
1
and
9
months
in
Year
2
Cold
Storage:
$
0.90
per
sq
ft
­
90d
on
#
1
and
50d
on
Liners
Economist's
comments
for
worksheet
2­
D
(
2b)
three­
year
transplant
Year
1
Land
preparation:
Includes
soil
test,
disc,
subsoil,
plant
&
disc
cover
crop,
disc,
plow,
drag
Application:
Includes
custom
application
cost
(
less
materials)
and
plastic
disposal
and
clean­
up
Cover
crop:
Cover
crop
seed
is
certified
to
minimize
weed
contamination
Planting
labor:
Includes
splitting
plants
into
divisions,
transplanting
into
field
and
transport
to
field
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
12
months
in
Year
1
and
12
months
in
Year
2
Equipment
Operation
(
Planting):
Fuel
&
Maint
on
transplanter
Irrigation
Labor
&
Operation:
Includes
labor
(
calculated)
plus
$
0.10
per
application
in
electricity
&
maint
cost
Year
2
Irrigation
Labor
&
Operation:
Includes
labor
(
calculated)
plus
$
0.10
per
application
in
electricity
&
maint
cost
Includes
labor
(
calculated)
plus
$
0.10
per
application
in
electricity
&
maint
cost
Equip.
rental:
10
hi­
los,
Truck
rental
(
4
trucks)
plus
truck
mileage
to
and
from
field,
Trailer
rental
(
3
trailers)
plus
mileage
to
and
from
field
Economist's
comments
for
worksheet
2­
D
(
2c)
two­
year
transplant
Year
1
Land
preparation:
Includes
chisel
plow
3x
and
rototill
once
before
and
once
after
fumigation
Application:
Includes
2
people
on
hand
at
application
to
bury
ends
of
plastic
and
assist
custom
operators
Field
cleanup:
Labor
to
pick
up
plastic,
plastic
disposal
fee
and
tractor
&
trailer
use
(
custom
rate)

Seedlings:
Plants
and
planting
costs
Fertilizer/
soil
amendments:
Includes
material
and
application
cost
Irrigation:
Labor
to
water
about
1"
per
week
June
1­
Sept
30
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
8
months
in
Year
1
and
12
months
in
Year
2
Year
2
Digging
Equipment:
Includes
custom
rates
for
2
tractors
­
1
for
digger
and
1
for
trailer
­
potato
digger
and
trailer
Storage
cost:
Includes
mulch
to
cover
in
polyhouse
and
polyhouse
rental
($
0.50
per
sq
ft
*
3,000
sq
ft
necessary
for
1
acre
hosta
yield)

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

Complete
worksheet
3­
A
for
each
alternative
pest
control
regimen
listed
in
the
"
U.
S.
Matrix"
for
chemical
controls
(
www.
epa.
gov/
ozone/
mbr/
cueqa.
html)
and
the
"
International
Matrix"
for
nonchemical
pest
controls
(
www.
epa.
gov/
ozone/
mbr/
cue).
Each
worksheet
contains
a
place
holder
in
the
title
for
you
to
insert
the
name
of
the
specific
alternative
pest
control
regimen
addressed.
You
should
add
additional
worksheets
as
required.

Enter
all
alternative
pesticides
and
pest
control
methods
(
and
associated
cost
and
yield
data)
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Definition
worksheet
for
a
comprehensive
definition
on
fumigation
cycles.
OMB
Control
#
2060­
0482
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

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

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

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

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
5.

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

Pest
Resistant
To
Alternative
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Quality
Loss
*

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

(
If
yes,
please
explain)
1
2
3
4
Details
%
Pest
Control
*
Alternative:

%
Yield
Loss
*
[
Insert
Alternative
]

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

Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Details
Attached?

Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
OMB
Control
#
2060­
048
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Non­
Chemical
Pest
Control
(
please
describe)
Units
(
gals,
lbs.
Etc.)
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Land
Preparation
Fumigation
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
OMB
Control
#
2060­
048
Comments:
Alternative:
[
Insert
Alternative
]
EPA
Form
#
7620­
18a
Pre
Plant
482
es
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
1
root
1
root
1
root
1
root
4.

No
x
5.

6.

yellow
nutsedge,
kiek,
soil
borne­
diseases
Pest
Resistant
To
Alternative
Restrictions
on
Alternative
Use
Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?

Details
­
Label
Restriction
Regulatory
Restriction
%
of
Area
Yes
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.

Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Soil
Restriction
1
2
3
4
50­
80
11,155
22,649
Details
grower
experiences
an
average
25%
loss
using
this
product
compared
to
methyl
bromide
25%
Alternative:

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

%
Pest
Control
*

Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.

Details
Attached?

EPA
Form
#
7620­
18a
Pre
Plant
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Quality
Loss
*

#
1
Grade
Liners
14,874
30,198
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
OMB
Control
#
2060­
0482
Worksheet
3­
A(
1)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
7.

8.

9.

J
F
M
A
M
J
J
A
S
O
N
D
J
M
A
M
J
J
A
S
O
N
D
J
Spot
Spray
Herbicide
Pre
Plant
Harvest
Fallow
Land
Preparation
Fumigation
Planting
Hand
Hoeing
Fungicide
Non­
Chemical
Pest
Control
(
please
describe)

Establish
Cover
Crop
Herbicide
7
1,3­
dichloropropene
Units
(
gals,
lbs.
Etc.)
lb
Alternative:
Telone
II
Worksheet
3­
A(
1)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
1
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Telone
II
97.5%
393.9
Comments:

areas
where
nematodes
are
the
primary
concern,
and
these
weeds
and
diseases
aren't
present.
One
grower
applies
Telone
II
with
Yetter
coulters
to
get
deeper
soil
penetration
(
12")
and
improved
nematode
control.
Telone
does
not
control
yellow
nutsedge,
kiek,
other
weeds.
Telone
II
does
not
control
soil­
borne
diseases.
It
can
be
used
in
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Fallow
Establish
Cover
Crop
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
(
See
methyl
bromide
alternatives
newsletter.
January
2001,
Application
technology
for
injecting
Telone)
OMB
Control
#
2060­
0482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
Divisions
Divisions
Divisions
Divisions
4.

No
x
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
2)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Pest
Resistant
To
Alternative
Soil
Restriction
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
200,000
150,000
135,520
#
1
(
2­
eye
splits)
Quality
Loss
*

1­
eye
splits
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Market
Category
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.
Alternative:

%
Yield
Loss
*
Grown
in
Artificial
Media
on
Acreage
Prepared
as
Container
Field
(
soilless
culture/
substrates­
plug
production)

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

Details
%
Pest
Control
*

Details
Study
Information
Attached?
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.

For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
1
2
3
4
Yes
­
Label
Restriction
­
Township
Caps
Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
5
Enter
Average
Loss
Splits
lower
due
to
increased
density
of
plants.

Details
203,280
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

J
F
M
A
M
J
J
A
S
O
N
D
J
F
M
A
M
J
J
A
S
O
N
D
Comments:
Alternative:
Grown
in
Artificial
Media
on
Acreage
Prepared
as
Container
Field
(
soilless
culture/
substrates­
plug
production)

Hand
Weed
Harvest
Planting
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
OMB
Control
#
2060­
048
Fallow
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Hand
hoeing
is
decreased
because
artificial
media
does
not
contain
any
weed
seeds.

Fertilize
Planting
Harvest
Fallow
Fertilize
Irrigate
Hand
Weed
Continuation
of
Alternative
Cycle
(
if
needed)
Worksheet
3­
A.(
2)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Units
(
gals,
lbs.
Etc.)
Name
of
Product
and
Formulation
Non­
Chemical
Pest
Control
(
please
describe)

Development
of
a
container
field
involves
leveling
the
ground,
installation
of
below
ground
irrigation
and
gravel
driveways
and
laying
down
of
a
ground
mat
in
beds.
Because
of
driveways,
only
about
70%
of
the
43,560
sq
ft
in
an
acre
can
be
utilized.
In
addition,
after
a
container
field
is
developed,
the
ground
is
not
useable
for
alternative
farming
practices.
Therefore,
a
grower
would
only
develop
owned
ground
into
a
container
field.
Irrigate
Land
Preparation
Fumigation
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
of
eld
nd
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A
(
3)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
expect
similar
results
to
Telone
II
see
worksheet
3
A­(
1)
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Telone
C­
35
under
tarp
is
being
evaluated
under
field
conditions­
see
research
summary
attachment
for
more
detail
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

%
Yield
Loss
*
1,3
Dichloropropene,
Chloropicrin
(
Telone
C­
35)

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

Details
%
Pest
Control
*

research
is
currently
underway;
completion
date
2004
1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)

yellow
nutsedge,
kiek
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
50­
80
root
knot
nematodes,
weeds
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
see
worksheet
3
A­(
1)

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
1,3
Dichloropropene,
Chloropicrin
(
Telone
C­
35)

Telone
does
not
control
yellow
nutsedge,
kiek,
other
weeds.
Telone
C­
35
might
be
expected
to
give
improved
control
of
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

borne
diseases,
where
they
are
present.
It
can
be
used
in
areas
where
nematodes
are
the
primary
concern,
and
these
weeds
aren't
present.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
3)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)
1
65%
1,3
dichloropropene
Telone
C­
35
35
gals
35%
chloropicrin
Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
4)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

%
Yield
Loss
*
1,3
Dichloropropene,
Metam
sodium
Yield
Loss
&
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
Pest
Being
Tested
Study
#
(
list
below)
Provide
numerical
estimates
where
possible.

Details
%
Pest
Control
*

research
is
currently
underway;
completion
date
2004
1
2
3
4
Details
Telone
II
and
metam
sodium
and
telone
C­
35
and
metam
sodium
under
tarp
are
being
evaluated
under
field
conditions­
see
research
summary
attachment
for
more
details
Soil
Restriction
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
not
known
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
30­
35
weeds
northern
root
knot
nematod
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Fusarium
spp.
Pest
Resistant
To
Alternative
80­
90
nurseries
in
urbanized
areas­
odor
problems
with
metam
on
fields
adjacent
to
homes
and
businesses;
most
owned
or
rented
land
in
this
category
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
1,3
Dichloropropene,
Metam
sodium
metam
sodium
has
been
erratic
in
its
performance,
giving
inconsistent
results.
The
fumes
are
a
problem
for
growers
in
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

urbanized
areas.
Metam
sodium
is
not
as
effective
against
Fusarium
spp.
as
methyl
bromide.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
4)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)
1
Telone
II
combined
with
35
gal
metam
sodium
metam
sodium
75
1
gal
(
1:
4
water)
Telone
C­
35
combined
Non­
Chemical
Pest
Control
(
please
describe)
35
75
gal
(
1:
4
water)
gal
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

x
No
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A(
5)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
be
up
to
60
days
before
new
crop
can
be
planted,
depending
on
rate
of
metam­
sodium
used,
and
how
quickly
the
fumigant
clears
from
the
soil.

EPA
Form
#
7620­
18a
Pre
Plant
Yield
with
Methyl
Bromide
Yield
With
Alternative
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Quality
Loss
*
Details
see
attached
methyl
bromide
alternative
research
for
herbaceous
perennials
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

%
Pest
Control
*

research
is
currently
underway;
completion
date
2004
3
4
Details
Quality
Impact
Description
Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
Additional
time
may
be
necessary
between
crops
as
it
may
Yes
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
30­
35
Fusarium
spp.

Other
Restrictions
(
Describe)
­
Township
Caps
weeds
rootknot
nematodes
Soil
Restriction
1
2
80­
90
safety
and
health
issues
make
it
difficult
to
use
in
urbanized
areas
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.

Pest
Resistant
To
Alternative
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
75
gal/
Acre­
(
1:
2
water)
OMB
Control
#
2060­
0482
Alternative:
metam
sodium
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
EPA
Form
#
7620­
18a
Pre
Plant
Comments:

Growers
report
that
metam
applied
through
center
pivot
irrigation
can
be
effective,
but
urbanization
makes
it
impossible.
Metam­
Sodium
is
not
a
technically
feasible
alternative
because
is
does
not
consistently
control
all
the
target
pests.
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Growers
formerly
using
metam­
sodium
report
that
it
does
not
penetrate
into
the
soil
as
well
as
methyl
bromide,
resulting
in
erratic
and
less
than
adequate
control.
Additional
cultivation
to
aerate
the
soil
before
planting
may
be
needed.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
5)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
rates
under
evaluation:
Metam
sodium,
not
tarped­
Metam
sodium,
tarped
75
gal/
Acre­
(
1:
4
water)
75
gal/
Acre­
(
1:
4
water)
Units
(
gals,
lbs.
Etc.)

Metam
sodium,
tarped
Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
6)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
control
weeds
or
nematodes.

Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

Chloropicrin
alone
is
not
under
evaluation
in
current
research
because
it
does
not
adequately
1
2
3
4
Quality
Loss
*

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

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
weeds
rootknot
nematodes
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
chloropicrin
Chloropicrin
alone
is
not
technically
feasible
because
it
is
not
effective
against
nematodes
or
weeds.
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
6)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

x
No
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
7)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
be
up
to
60
days
before
new
crop
can
be
planted,
depending
on
rate
of
metam­
sodium
used,
and
how
quickly
the
fumigant
clears
from
the
soi
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

Chloropicrin
/
metam
sodium
is
not
under
evaluation
in
current
research.
1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
Additional
time
may
be
necessary
between
crops
as
it
may
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
weeds
nroot
knot
nematodes
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
Metam
sodium,
Chloropicrin
metam
sodium
has
been
erratic
in
its
performance,
giving
inconsistent
results.
The
fumes
are
a
problem
for
growers
in
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

urbanized
areas.
Metam
sodium
is
not
as
effective
against
Fusarium
spp.
as
methyl
bromide,
however
the
addition
of
chloropicrin
might
improve
control
of
Fusarium.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
7)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
soil.
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
8)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
be
up
to
60
days
before
new
crop
can
be
planted,
depending
on
rate
of
metam­
sodium
used,
and
how
quickly
the
fumigant
clears
from
the
soi
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

%
Yield
Loss
*
metham
sodium/
crop
rotation
Yield
Loss
&
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
Pest
Being
Tested
Study
#
(
list
below)
Provide
numerical
estimates
where
possible.

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
Additional
time
may
be
necessary
between
crops
as
it
may
Fusarium
spp.
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
30­
35
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
80­
90
safety
and
health
issues
make
it
difficult
to
use
in
urbanized
areas
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:

Metam­
Sodium
concerns
are
expressed
in.
3A
(
5a)
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Growers
already
use
some
crop
rotation
to
lessen
the
buildup
of
nematodes,
but
crop
rotation
doesn't
address
issues
with
weeds.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
8)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
soil.
482
1.

2.

Study
#
1
1
2
2
3.

Units
Units
4.

x
No
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A(
9)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
Proceedings,
2000
An.
Int.
Rsch.
Conf.
On
MB
Alt.

Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
x
Solarization
and
biofumigation
for
field­
grown
flowers
C.
L.
Elmore,
J.
Roncoroni,
J.
MacDonald,
L.
Bolkin,
I.
Zasala,
H.
Ferris
and
S.
Tjosvold
Details
x
Macerated
Brassica
leaves
suppress
Pythium
ultimum
and
Rhizoctonia
solani
mycelial
growth
Craig
S.
Charron
and
Carl
E.
Sams
1998
An.
Int.
Rsch
Conf.
On
MB
Alt.
&
Emission
Reduction
Attached?
broccoli
residue
combined
with
solarization
broccoli
residue
alone
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
Enter
Average
Loss
Alternative:

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

100
Details
%
Pest
Control
*

72.6
90
66
%
reduction
of
fungal
growth
on
petri
plate
compared
to
untreated
control
1
1
2
2
Quality
Loss
*

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

(
If
yes,
please
explain)
6
weeks
for
solarization
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
weed
seedlings
calla
lily
tubers
Pythium
ultimum,
Rhizoctonia
solani
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
EPA
Form
#
7620­
18a
Pre
Plant
Comments:

Additionally,
biofumigation
doesn't
adequately
control
all
the
targeted
pests
to
produce
pest­
free
plants.
Alternative:
Biofumigation
Michigan
growers
are
unlikely
to
have
access
to
the
massive
quantity
of
crucifer
waste
to
treat
needed
acreage.
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Harvest
OMB
Control
#
2060­
0482
technique
was
combined
with
solarization
under
California
conditions.
Study
1­
technique
carried
out
in
petri
plates,
not
in
the
field­
not
enough
research
to
demonstrate
that
process
would
work
under
field
conditions.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Worksheet
3­
A(
9)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
study
2)
Broccoli
waste
applied
at
5
T
and
35
T
per
(
acre?)
rate,
incorporated
into
soil
or
pot
to
2
or
6
inch
depth.
study
1)
Fungal
mycelium
exposed
to
volatiles
from
macerated
brassica
leaves
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
3.

Units
Units
4.

x
No
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
10)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
summer­
lose
income
from
at
least
one
cropping
season
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
x
Effect
of
Soil
Solarization
and
Cover
Crops
on
Populations
of
Selected
Soilborne
Plant
Pathogens
in
Western
Oregon
J.
N
Pinkerton
et
al,
Plant
Disease,
Vol
84,
No
9
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

see
study
for
details
not
reported
as
%
pest
control
1
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?

no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
Solarization
must
be
done
during
the
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Phytophthora
cinnamomi
lesion
nematode
Verticillium
dahliae
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
Solarization
Solarization
is
not
a
technically
feasible
alternative
because
it
does
not
provide
control
of
common
nursery
pests
in
a
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

northern
climate.
In
Michigan,
summer
temperatures
are
too
low,
humidity
is
high,
and
skies
are
often
cloudy.
While
nematodes
populations
were
reduced,
they
were
not
adequately
controlled
to
produce
pest­
free
planting
stock.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
10)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A(
11)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Comments:
One
consortium
grower
has
spent
over
$
200,000
so
far
to
develop
monotube
boilers
to
steam
his
fields.

Steam
also
requires
a
high
initial
investment
of
capital;
it
was
over
twice
the
cost
of
methyl
bromide
for
Yoder
Bros.
Alternative:
Steam
He
is
attempting
to
use
high
temperature,
high
pressure
steam,
which
he
says
is
more
efficient,
but
has
had
difficulty
with
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

regulating
the
equipment.
One
problem
with
steam
is
that
it
adversely
affects
the
carbon
in
the
organic
matter.
Yoder
Bros.
Uses
steam
successfully,
but
MI
growers
do
not
crop
small
acres
continuously,
have
more
organic
matter
in
so
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A
(
11)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A(
12)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Comments:
Alternative:
Biological
control
Biological
controls
have
not
been
developed
for
the
majority
of
pest
problems
faced
by
growers.
Generally.
Biocontrols
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

would
result
in
suppression
of
a
pest,
which
would
not
produce
the
pest­
free
plants
required
for
growing
on.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
12)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Various
biocontrol
agents
(
fungi,
bacteria,
nematodes,
etc.)
are
used
to
suppress
pests.
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A
(
13)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Rorippa
sylvestris
Inula
spp.

Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Comments:
Alternative:
Crop
residue
compost
Composting
crop
debris
alone
is
not
a
technically
feasible
alternative
because
it
will
not
control
target
pests
to
the
degree
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

necessary
to
ensure
pest
and
pathogen­
free
plants
for
planting.
Any
remaining
uncomposted
crop
debris
could
serve
as
a
source
for
disease
organisms
and
nematodes.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
13)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

x
No
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A(
14)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
least
a
year.
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

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

(
If
yes,
please
explain)
Fallowing
requires
that
land
be
taken
out
of
production
for
at
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Rorippa
sylvestris
Inula
spp.

Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Comments:
Alternative:
Crop
rotation/
fallow
Doesn't
allow
growers
to
meet
requirements
for
shipping
propagative
material.
Crop
rotation/
fallow
alone
won't
control
targe
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

pests.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A(
14)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

x
No
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A
(
15)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Soil
flooding
during
the
off­
season
as
an
alternative
to
methyl
bromide
L.
H.
Allen
Jr.,
D.
R.
Sotomayor,
D.
W.
Dickson,
and
Z.
Chen
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

83­
90
Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)
flooding
ties
up
production
land
for
at
least
2­
3
months
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
rootknot
nematode
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
Flooding
and
water
management
Flooding
may
help
to
control
nematodes,
but
will
not
control
most
weeds
and
may
actually
make
some
soilborne
diseases
wo
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Michigan
soils
where
herbaceous
perennials
are
grown
are
typically
sandy
and
wouldn't
readily
lend
themselves
to
flooding.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A
(
15)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
flooding
is
used
to
help
reduce
certain
nematode
populations
and
some
weeds
in
areas
where
there
are
flat,
low­
lying
areas
of
mineral
soils
in
regions
with
abundant
water
supplies
and
seasonally
high
water
tables.
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A
(
16)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

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

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:
Alternative:
General
IPM
general
IPM
is
already
being
practiced
and
while
it
helps
to
reduce
pest
populations,
will
not
result
in
the
pest­
free
plants
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

required
for
shipping.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A
(
16)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
048
Worksheet
3­
A(
17)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

%
Yield
Loss
*
plant
resistance
and
grafting,
resistant
cultivars
Yield
Loss
&
Pest
Control
When
Comparing
This
Alternative
to
Methyl
Bromide
Pest
Being
Tested
Study
#
(
list
below)
Provide
numerical
estimates
where
possible.

Details
%
Pest
Control
*

no
studies
available
1
2
3
4
Quality
Loss
*

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

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
EPA
Form
#
7620­
18a
Pre
Plant
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
048
Comments:

is
of
primary
concern
to
growers.
Alternative:
plant
resistance
and
grafting
,
resistant
cultivars
Literally
thousands
of
different
taxa
are
grown
as
herbaceous
ornamentals.
While
particular
genera
and
cultivars
may
vary
in
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

their
susceptibility
to
nematodes
or
particular
plant
pathogens,
there
would
be
relatively
few
that
would
qualify
as
resistant.
Herbaceous
perennials
in
this
application
are
not
grafted..
Neither
practice
addresses
issues
with
weed
management,
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A
(
17)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
resistance
involves
using
varieties
that
are
resistant
or
tolerant
to
a
specific
pest,
usually,
a
plant
pathogen.
grafting
could
consist
of
a
resistant
rootstock
grafted
to
a
susceptible
scion.
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
EPA
Form
#
7620­
18a
Pre
Plant
482
482
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
4.

No
x
5.

6.
OMB
Control
#
2060­
0482
Worksheet
3­
A
(
18)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
EPA
Form
#
7620­
18a
Pre
Plant
Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Details
Attached?
Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Alternative:

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

Details
%
Pest
Control
*

1
2
3
4
Quality
Loss
*

Are
there
any
variety
or
cultivar
issues
associated
with
this
alternative?
no
Are
there
any
production
delays
(
planting/
harvesting)
associated
with
this
alternative?

(
If
yes,
please
explain)

This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
Pest
Resistant
To
Alternative
*
If
no
yield
or
quality
loss
information
is
given
we
will
assume
no
losses.
Only
provide
pest
control
information
if
yield
or
quality
loss
information
is
not
available.
7.

8.

9.

Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
Month
1
Month
2
Month
3
Month
4
Month
5
Month
6
Month
7
Month
8
Month
9
Month
10
Month
11
Month
12
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Comments:
Alternative:
Organic
amendments,
compost
Organic
amendments
and
composts
generally
act
to
suppress
diseases
rather
than
eliminate
them.
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)

Weeds
and
nematodes
are
not
controlled,
so
pest­
and
pathogen
free
plants
can
not
be
produced
with
this
alternative.
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other
Key
Crop
Steps
Other
Key
Pest
Steps
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
Time
Interval
(
e.
g.
MONTH/
YEAR/
SEASON)
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Worksheet
3­
A
(
18)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Composts
and
organic
matter
contain
beneficial
microorganisms
that
work
as
biocontrol
agents
to
suppress
disease
organisms
in
the
soil.
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
Units
(
gals,
lbs.
Etc.)

Non­
Chemical
Pest
Control
(
please
describe)
1.

2.

Study
#
1
2
3
4
5
3.

Units
Units
1/
2
Flat
(
11x11")
1/
2
Flat
(
11x11")

4.

No
X
5.

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

Pest
Resistant
To
Alternative
50­
65%
Yes
­
Label
Restriction
Organic
Matter
Restriction
Off
Site
Damage
(
outgassing)
Other
Restrictions
(
Describe)
­
Township
Caps
can't
use
where
keik,
inula­
nutsedge
are
present
no
estimates
available
Fusarium
,
other
soil
borne
disease
will
not
be
controlled
This
information
will
be
used
to
determine
the
amount
of
methyl
bromide
needed.
Restrictions
on
Alternative
Use
Regulatory
Restriction
%
of
Area
Details
Soil
Restriction
Quality
Loss
*

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

(
If
yes,
please
explain)
18,450
1
2
3
4
Details
%
Pest
Control
*
Alternative:

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

Study
Information
For
the
information
in
#
1
above
list:
the
study
name,
authors,
publication,
date,
and
if
a
copy
is
attached.
5
Enter
Average
Loss
Details
Attached?

Yield
with
Methyl
Bromide
Yield
With
Alternative
Quality
Impact
Description
Describe
quality
impacts
such
as:
percent
smaller
fruit,
reduced
grade,
smaller
plants,
crop
damage,
disease
vector,
etc.
Refer
to
market
category
question
in
Worksheet
2­
C.

Market
Category
Quality
would
remain
the
same.
Phlox
subulata
20,500
EPA
Form
#
7620­
18a
Pre
Plant
OMB
Control
#
2060­
048
Worksheet
3­
A(
19)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
7.

8.

9.

M
J
J
A
S
O
N
D
J
F
M
A
Cultivate
(
Mechanical)
Hand
Weeding
Insecticide
&
Fungicide
M
J
J
A
S
O
N
D
J
F
M
A
Cultivate
(
Mechanical)
Hand
Weeding
Insecticide
&
Fungicide
Non­
Chemical
Pest
Control
(
please
describe)
Units
(
gals,
lbs.
Etc.)
Worksheet
3­
A(
19)
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
This
alternative
will
include
additional
hand
weeding
and
mechanical
cultivation.
Use
Rate
of
Chemical
Alternative
Quantity
a.
i.
per
Acre
#
of
Acres
Treated
#
of
Applications
per
Year
Active
Ingredient
(
a.
i.)
Name
of
Product
and
Formulation
(
Indicate
when
fumigation,
major
crop
and
pest
management
practices
typically
occur
by
shading
the
appropriate
cells.
Show
a
second
crop
if
part
of
the
fumigation
cycle.
If
the
fumigation
cycle
is
longer
than
one
year
change
the
months
to
an
appropriate
interval.
These
tables
are
for
annual
crops
but
more
than
one
crop
may
benefit
from
one
methyl
bromide
fumigation.
If
application
covers
multiple
crops/
crop
groupings
not
grown
sequentially,
they
will
need
to
provide
this
information
for
all
crops/
crop
groupings.
Please
adjust
timeline
as
necessary.
Please
provide
additional
comments
or
description
below
or
on
a
separate
page.
Please
begin
the
timeline
with
the
first
land
preparation.
For
perennials,
please
begin
with
the
year
of
land
preparation
and
fumigation
and
indicate
the
years
of
production
by
yield
or
percentage
of
full
production.)
Alternative
Timeline
YEAR
1
Beginning
Fumigation
Cycle
Land
Preparation
Fumigation
Planting
Harvest
Fallow
Cover
Crop
YEAR
2
Fallow
Harvest
Continuation
of
Alternative
Cycle
(
if
needed)

Planting
Land
Preparation
Fumigation
OMB
Control
#
2060­
048
EPA
Form
#
7620­
18a
Pre
Plant
Comments:
Alternative:
Physical
removal,
sanitation
This
method
would
be
limited
to
areas
where
the
primary
problems
are.
482
es
482
Column
A:

Column
B:

Column
C:

Column
D:

Column
E:

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

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

Total
Cost
per
Acre
Total
Cost
per
Acre
For
all
inputs
and
operations
detailed
in
Column
B,
please
specify
the
unit
cost.
Also,
indicate
all
costs
of
applying
methyl
bromide,
including
any
material
costs,
for
example,
tarps.
If
custom
applied
and
separate
costs
are
unavailable,
write
'
custom'
and
enter
total
cost
in
Column
E.
Cost
per
Unit
of
Yield
For
harvest
operations,
specify
costs
that
depend
on
amount
of
product
harvested,
for
example,
packing
material,
per
unit
of
produce.

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

Quantity
Used
per
Acre
This
field
is
required
only
for
methyl
bromide.
However,
you
may
include
specific
amounts
of
other
inputs
or
operations
if
you
believe
it
helps
to
document
the
additional
costs
you
would
incur
by
using
an
alternative
fumigant.
Constant
Cost
per
Acre
For
harvest
operations,
specify
costs
that
depend
on
land
area,
for
example,
picking
costs,
per
acre
of
land.

Units
OMB
Control
#
2060­
0482
Worksheet
3­
B(
1&
2).
Alternatives
­
Changes
in
Operating
Costs
Enter
all
operating
costs
incurred
during
a
fumigation
cycle.
Users
with
a
relatively
short
fumigation
cycle
(
less
than
five
years)
should
use
version
B(
1);
users
cultivating
perennial
crops
should
use
version
B(
2).
Users
with
multiple
crops,
either
on
the
same
area
in
a
single
fumigation
cycle
or
on
different
areas
treated
separately,
should
copy
this
sheet
and
provide
costs
for
each
crop.
If
multiple
crops
are
cultivated
sequentially
following
a
single
fumigation,
replace
fumigation
costs
in
pre
plant
Operations
with
any
additional
pest
control
costs
used
prior
to
the
following
crops.
If
a
fallow
season
is
an
important
part
of
the
fumigation
cycle,
include
costs
incurred
(
for
example,
cultivating
a
cover
crop)
as
a
separate
line
or
as
a
separate
sheet,
if
costs
are
extensive.
Please
fill
in
the
unshaded
areas.
The
shaded
areas
can
be
used
if
the
information
is
known.

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

Constant
Cost
per
Acre
($)
Cost
per
Unit
of
Yield
($)
Yield
Total
Cost
per
Acre
($)

Hauling
Material
Grading
/
Packing
/
Storage
Other
Costs
Harvest
Operations
Labor
Fuel
/
Machine
Labor
Other
Costs
Fungicide
Nematicide
Irrigation
Labor
(
manual)
Fertilizer
/
Soil
Amendments
Pesticides
Insecticide
Herbicide
Cultural
Operations
Seed
/
Seedlings
Irrigation
Other
costs
Land
preparation
Fumigation
product
(
methyl
bromide)

application
Pre­
plant
Operations
Alternative:
[
Insert
Alternative]

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

EPA
Form
#
7620­
18a
Pre
Plant
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Alternative:

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

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

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

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
148
Fumigation
product
47.5
gal
Telone
$
12.00
570
application
330
Irrigation
Seed
and
Seeding
287
Other
costs
63
63
Cultural
Operations
Fertilizer/
soil
amendments
73
60
Pesticides
Insecticide
Herbicide
25
Fungicide
356
Custom
Application
of
Fungicide
12
applications
15.00
$
180
Irrigation
70
Hand
Hoeing,
Trimming,
Spot
Spraying
241
hrs
12.00
$
2,892
Fuel/
machine
labor
100
Interest
on
Operating
Cap
1,229
$
6.0%
18
8,725
$
6.0%
196
Dpt
of
Ag
Inspection
20
20
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Digging
&
Transporting
876
Grading/
packing
1,495
Cold
Storage
997
Shipping
1,329
OMB
Control
#
2060­
0482
Worksheet
3­
B(
2).
Alternatives
­
Changes
in
Operating
Costs
for
Perennial
Crops
PRE
PRODUCTION
­
YEAR
1
HARVEST
­
YEAR
2
FULL
PRODUCTION
YEARS
_____

Telone
II
(
expect
similar
costs
for
Telone
C­
35)
EPA
Form
#
7620­
18a
Pre
Plant
1,247
$
8,921
$
10,168
Alternative:

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

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

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

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
98
Fumigation
product
­
­

application
­

Cover
Crop
12
Seedlings
38,000
divisions
0.03
$
1,241
Planting
Labor
1,624
Equipment
Operation
(
Planting)
6
Cultural
Operations
Fertilizer/
soil
amendments
42
150
Pesticides
Insecticide
&
Fungicide
2
applications
75.00
$
150
14
applications
75.00
$
1,050
Custom
Application
of
3
applications
15.00
$
45
21
applications
15.00
$
315
Hand
Weeding
150
hours
12.00
$
1,800
Irrigation
Labor
&
Operat
1.5
hours
15.00
$
23
3.5
hours
15.00
$
53
Labor
(
manual)

Mechanical
Cultivation
15
times
15.00
$
225
Dpt
of
Ag
Inspection
20
20
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Cutting
(
Mechanical
Operation)
2.7
hr/
ac
15.00
$
41
Cutting
&
Packaging
(
Labor)
522
hours
12.00
$
6,261
Equpment
Rental
Hi­
Los
435
Truck
495
Trailers
275
Packing
Materials
18,450
flats
0.21
$
3,875
OMB
Control
#
2060­
0482
Worksheet
3­
B(
2).
Alternatives
­
Changes
in
Operating
Costs
for
Perennial
Crops
HARVEST
­
YEAR
2
PRE
PRODUCTION
­
YEAR
1
Physical
removal,
sanitation
3,261
14,994
EPA
Form
#
7620­
18a
Pre
P
$
18,264
Alternative:

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

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

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

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
768
Fumigation
product
application
Irrigation
Bulb
crates
and
media
11,293
crates
2.50
$
28,233
Seedlings
67,760
plants
$
0.87
72,503
Other
costs
Cultural
Operations
Fertilizer/
soil
amendments
450
lbs
$
1.00
498
450
lbs
$
1.00
498
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
32
man
hours
$
15.00
480
32
man
hours
$
15.00
480
Interest
on
Land
Prep
Co
11,525
$
7.0%
807
11,525
$
7.0%
807
Interest
on
Operating
Cap
104,462
$
6.0%
2,100
16,278
$
6.0%
488
Hand
weeding
96
man
hours
12.00
$
1,152
96
man
hours
12.00
$
1,152
Dpt
of
Ag
Inspection
20
20
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Labor
and
Hauling
1,440
Storage
Cost
3,750
Processing
0.03
$
271,040
8,131
106,561
$
16,766
$
123,327
$
Year
1
and
2
Total
Cost
per
Acre
OMB
Control
#
2060­
0482
EPA
Form
#
7620­
18a
Pre
Plant
Worksheet
3­
B(
2).
Alternatives
­
Changes
in
Operating
Costs
for
Perennial
Crops
HARVEST
­
YEAR
2
PRE
PRODUCTION
­
YEAR
1
Grown
in
Artificial
Media
on
Acreage
Prepared
as
Container
Field
(
Soiless
culture/
plugs
substrates)
1.
1
4
2
5
3
2.
1
4
2
5
3
3.
1
4
2
5
3
4.

5.

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

x
From:

To:

x
9.

Years
Amount
($)
2002­
2003
$
10,000
2002­
2003
$
22,625
10.
$

Cost
11.
Will
economic
impacts
be
measured?

Tarpaulin
(
High
Density
Polyethylene)

Other
Will
yield/
quality
loss
be
measured?
see
attached
research
summary
at
carryover
and
phytotoxicity
to
major
crops;
it
may
also
take
time
to
get
expanded
labeling.
We
anticipate
around
5­
6
years
for
herbicides.
If
methyl
iodide
is
registered,
the
transition
might
happen
more
quickly.
additional
research
on
alternatives
is
funded
until
2006.
see
attached
research
summary
_____%
methyl
bromide,
_____%
chloropicrin
_____%
methyl
bromide,
_____%
chloropicrin
Virtually
Impermeable
Film
(
VIF)

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

Identify
the
top
3
to
5
target
pests
for
your
research.
see
attached
research
summary
Provide
a
list
of
alternative
chemicals
or
cultural
practices
that
have
been
tested.

How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?
We
hope
to
have
some
workable
alternative
fumigants
by
2007­
2008.
Herbicide
testing
will
need
to
be
expanded
to
look
What
would
be
the
best
currently
available
alternative
if
methyl
bromide
were
not
available?
probably
telone
or
telone/
chloropicrin
under
tarp
combined
with
post
emergence
herbicides
Prioritize
the
alternative
chemicals
or
cultural
practices
to
be
tested.

Formulation
Changes
Grant
requests
made
to
USDA,
EPA,
state,
or
other
funding
group.
see
attached­
USDA
Methyl
Bromide
Alternatives
program­
funding
for
2003­
2006
approved.
Investment
Please
provide
an
overview/
timeline
of
the
plan
to
transition
away
from
using
methyl
bromide.
University
research
on
alternate
fumigants
for
herbaceous
perennials
began
in
fall
of
2002;

Michigan
Nursery
and
Landscape
Association/
Michigan
State
University
Other
total
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide?
Formulation
Changes
(
please
specify)

(
check
all
that
apply)

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

perennial
growers
in
consortium/
Michigan
State
University
What
is
the
cumulative
amount
spent
and
the
types
of
contributions
this
consortium
has
made
to
fund
research
to
develop
alternatives
to
methyl
bromide
since
1992?
(
e.
g.
consortium
dues,
direct
research
funding,
etc.)

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

see
attached
herbicides
EPA
Form
#
7620­
18a
Pre
Plant
1.

2.

3.

4.
2005
5.
2005
6.

2006
10,500
lbs.
30
2007
7,000
lbs.
20
Not
Technically
Feasible
Not
Economically
Feasible
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
For
EPA
Use
Only
ID
#
_______________
SECTOR
__________________________

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

Consortium
Name:
Michigan's
Field
Grown
Herbaceous
Perennial
Growers
Location:
Michigan,
one
grower
in
Illinois
Crop:
Pounds
of
Methyl
Bromide
Requested
12,388
lbs.
Acres
Treated
with
Methyl
Bromide
35
Acres
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

Area
Treated
Acres
We
are
still
conducting
research
into
alternatives.
We
hope
to
have
some
workable
alternatives
to
begin
using
in
2006­
2007,
but
anticipate
that
it
may
take
more
time
to
expand
the
use
of
the
alternatives.

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

Potential
Alternatives
Reasons
1,3
D
Dichloropropene
Can't
be
used
where
certain
weeds,
diseases
are
a
problem
1,3­
D
Dichloropropene,
Chloropicrin
Can't
be
used
where
certain
weeds
are
a
problem;
expect
similar
costs
as
Telone
II
1,3­
D
Dichloropropene,
metam
sodium
Metam
sodium­
erratic
control,
can't
use
in
urbanized
areas
Chloropicrin
Does
not
control
nematodes
or
weeds
adequately
metam
sodium
Metam
sodium­
erratic
control,
can't
use
in
urbanized
areas
solarization
not
feasible
under
Michigan
field
conditions
metam
sodium,
chloropicrin
Metam
sodium­
erratic
control,
can't
use
in
urbanized
areas
metam
sodium,
crop
rotation
Metam
sodium­
erratic
control,
can't
use
in
urbanized
areas
OMB
Control
#
2060­
0482
steam
steaming
slow;
best
suited
to
small
acreages;
continuous
cropping.
Initial
capital
investment
high
biological
control
no
biological
controls
developed
to
cover
all
the
pests
crop
residue
compost
does
not
adequately
control
all
targeted
pests;
not
practical
in
a
field
setting.
biofumigation
Doesn't
control
weeds
adequately.
Won't
produce
pest
and
pathogen­
free
plants
for
growing
Not
Technically
Feasible
Not
Economically
Feasible
x
x
x
x
x
x
soilless
culture,
substrates,
plug
plants
very
high
initial
costs
to
convert
from
field
use
to
growing
in
artificial
media
organic
amendments,
compost
Doesn't
control
target
pests­
pest­
and
pathogen
free
plants
can
not
be
produced
with
this
alternative.
general
IPM
doesn't
adequately
control
target
pests.

grafting,
resist.
rootstock,
plant
breeding,
resist.
cultivars
none
of
the
perennials
grown
are
grafted;
very
few
resistant
cultivars,
still
weed
issues
crop
rotation/
fallow
doesn't
adequately
control
target
pests.

flooding
and
water
management
Potential
Alternatives
Reasons
EPA
Form
#
7620­
18a
Pre
Plant
82
Fumigation
cycle:
The
period
of
time
between
methyl
bromide
fumigations.

Year:
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).

Comparable
data:
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.

2­
year
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.

Other
beneficiary
example
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.
Definitions:
OMB
Control
#
2060­
0482
Crop
cycle
change
example:
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.

Crop
Grouping
The
applicant
can
group
simliar
crops
together
if:

(
i)
Crops
would
experience
similar
yield
and
quality
losses
in
the
absence
of
methyl
bromide;
and
(
ii)
Crops
are
grown
on
the
same
fumigation
and
cultivation
cycle
with
similar
operating
costs.

For
example,
nursery
crops
including
various
flower
or
tree
species
can
be
aggregated,
with
average
yields
per
acre
and
prices.
However,
if
crops
are
distinctly
different
in
revenues
and
operating
costs,
or
the
cycles,
the
applicant
may
want
to
present
yield,
price
and
operating
costs
for
each
crop
separately
and
also
indicate
the
proportion
of
land
area
allocated
to
each
crop.

EPA
Form
#
7620­
18a
Pre
Plant
Perennials
CUE
Request
Summary
(
herbaceous
perennials)
soil
type
%
Organic
Eligible
for
QPS
#
MB
for
#
MB
for
Name
of
Nursery
Acreage
Farmed
Matter
yes
no
QPS
CUE
Ponderosa
300
Light
0­
2
x
4,900
2,100
Midwest
Ground
Covers
38
Med
2­
5
x
1,750
0
Heavy
>
5
x
Zelenka
15
Med
2­
5
x
308
92
Sawyer
Nrsy.
300
Med
2­
5
x
22,312
3,938
Emelander/
Sawyer
1.9
Light
0­
2
x
350
315
Walters
Nrsy.
1
80
Light
0­
2
x
3,465
1,485
Ottawa
Kent
4
Med
2­
5
x
32
368
DeGroots
3
50
Light
0­
2
x
3000
1000
Med
2­
5
x
Twixwood
3
35
Light
0­
2
x
1,540
460
Heavy
>
5
x
NewLife
1
15
Light
0­
2
x
703
347
DenHaan
and
Son
13
Light
0­
2
x
1,920
480
Heavy
>
5
x
Newhouse
30
Light
0­
2
x
5,197
53
Taylor
Flowers
15
Light
0­
2
x
1,750
Walters
Gardens
2
700
Light
0­
2
x
168,000
0
Total
1596.9
213,477
12,388
Explanation
of
economics
approach
taken
by
economist
"
Estimating
the
annual
cost
of
using
machinery
and
equipment
is
a
challenge
when
doing
enterprise
budgeting.

In
other
studies
of
horticultural
crops,
focus
groups
constructed
a
representative
farm
with
fixed
acreage
and
then
constructed
the
buildings,

machinery,
and
equipment
needed
to
operate
this
farm.
They
also
generated
associated
labor
needs
and
repair
and
operating
costs.

This
approach
has
the
advantage
of
being
very
tangible
but
also
makes
it
difficult
to
interpret
results
for
alternative
farm
sizes
In
addition,
most
growers
have
very
diverse
farm
operations.
They
rarely
have
records
that
can
allocate
machinery
costs
to
particular
farm
enterprises.

For
the
attached
budgets,
an
alternative
approach
was
taken.
Machinery
and
services
were
priced
to
the
enterprise
on
a
"
custom"
basis.

Further,
services
such
as
land
preparation
were
priced
to
the
enterprise
as
a
"
bundled"
service/
task
reflecting
both
the
machinery
and
labor
components
of
the
service.

This
approach
requires
some
judgment
because
costs
such
as
buildings
to
house
machinery
and
equipment,
the
farm
shop,
and
labor
used
in
maintenance
of
machinery
and
equipment
must
be
included
in
the
"
custom
fee"
as
well
as
the
"
depreciation
and
interest"
on
the
machinery
and
equipment.

The
fact
that
this
custom
fee
approach
was
used
does
not
imply
that
custom
operators
did
all
the
tasks.
It
simply
means
the
tasks
are
priced
to
the
enterprise
as
if
a
custom
operator
had
completed
them.
The
services
may
well
have
been
provided
by
the
"
machinery
services
enterprise"
of
the
farm.

While
the
above
approach
may
include
some
fixed
or
overhead
costs,
it
seems
to
be
the
most
accurate
method
of
attributing
machinery
and
equipment
costs
to
enterprise
budgets.
The
same
approach
was
used
for
both
methyl
bromide
and
alternative
budgets.
No
cost
of
building
or
land
was
included
in
budgets
unless
they
were
necessary
to
appropriately
model
a
methyl
bromide
alternative."
Michigan
Herbaceous
Perennials
CUE
Application
Perennial
Returns
Annualized
Revised:
19­
Oct­
2005
Budget
Years
2
2
2
2
2
2.1
Pest
Control
Regimen
Wksht
3
MeBr
­
2YS
MeBr
­
3YT
MeBr
­
2YT
Telone
II
sanitation
Alt
Media
%
Yield
Loss
Wksht
3­
A
0%
0%
0%
25%
10%
3%

Yield
Wksht
2­
C
or
3­
A
45,072
20,500
350,000
33,804
18,450
338,800
Average
Price
Revenue/
Yield
0.40
$
3.60
$
0.63
$
0.40
$
3.60
$
0.63
$

Revenue
Wksht
2­
C
9,087
$
36,900
$
110,500
$
6,815
$
33,210
$
103,514
$

Total
Operating
Costs
Wksht
2­
D(
2)
or
3­
B(
2)
4,741
$
9,662
$
30,822
$
5,084
$
9,127
$
60,573
$

Net
Cash
Returns
=
Revenue
­
Total
Op
Costs
4,345
$
27,238
$
79,678
$
1,731
$
24,083
$
42,941
$

Operating
Profit
Margin
=
Net
Cash
Returns
÷
Revenue
48%
74%
72%
25%
73%
41%

Loss
per
Acre
=
Difference
Btwn
NCR
for
MeBr
&
Alt
2,615
$
3,155
$
36,737
$

Pounds
of
MeBr
per
Acre
Application
Rate
ai
306
343
392
Loss
per
ai
MeBr
=
Loss
per
Acre
÷
Pounds
ai
Requested
per
Ac
8.54
$
9.20
$
93.72
$

Loss
as
a
%
Revenue
=
Loss
per
Acre
÷
Baseline
Revenue
per
Ac
28.8%
8.5%
33.2%

Loss
as
a
%
of
Net
Cash
Returns
=
Loss
per
Acre
÷
Baseline
NCR
per
Ac
60.2%
11.6%
46.1%

Alternative
Pest
Control
Regimens
TEAP
does
not
recommend
CUEs
where
technically
feasible
alternatives
are
registered
and
available
and
can
be
implemented
at
a
cost
less
than
the
median
cost
of
Multilateral
Fund
projects
to
reduce
MeBr
use.
This
median
cost
is
$
24
per
ozone
depeleting
potential
kg
or
$
14.40
per
kg
of
MeBr
or
$
6.55
per
lb
of
MeBr.

Row
Heading
Instructions
Baseline
