 

 

	

UNITED STATES 

ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

2009 Application for Critical Use Exemption of Methyl Bromide 

for Post Harvest Use in 2011 and Beyond in the United States

WHY IS THIS INFORMATION NEEDED?	

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 was 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 (commodity prices, revenues, and costs) for your use of
methyl bromide with uses of alternative pest control regimens.  



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.  

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 39 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.

For EPA Use Only ID # _______

SECTOR ___________________ 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 …"  

WHO 

APPLIES?

 

 	If you anticipate that you will need methyl bromide in 2011 and
beyond 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 post harvest users with similar commodity, pest,
and structural 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 types of commodities) 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.

WHAT INFORMATION IS REQUIRED?	If a user group submitted a complete
application to EPA in 2008, the user is only required to complete
selected Worksheets, though the entire application must be submitted to
EPA.  These required Worksheets include 1, 2B, 2C, 2D, 4, and 5.  If
these Worksheets are not submitted, EPA will not include the application
in the U.S. nomination submitted for international consideration. 
Additional information on Re-Application Information is available at
www.epa.gov/ozone/mbr.  The remaining worksheets must only be completed
if any information has changed since 2008.  If a user has previously
submitted a critical use exemption application to EPA but did not submit
an application in 2008 (seventh round) then all the worksheets in the
application must be submitted again in their entirety.

HOW DO 

I APPLY?	You may either complete an electronic (Microsoft Word or Excel)
or a printed version of the application.  Please fill out each section
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. 

IS MY INFORMATION CONFIDENTIAL?

 	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.

WHEN IS THE INFORMATION NEEDED?	This application must be postmarked to
the EPA address below no later than [Insert Date].

WHERE DO I SUBMIT THE APPLICATION?

 

 	Electronic Address for applications:





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

	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

Methyl Bromide Critical Use Exemption

Office of Air and Radiation

Stratospheric Protection Division 

(6205 J)

1200 Pennsylvania Ave, NW

Washington,  DC  20460

	US Environmental Protection Agency

Methyl Bromide Critical Use Exemption

Office of Air and Radiation

Stratospheric Protection Division

1310 L Street, NW

Suite 1047E

Washington, DC  20005

HOW CAN I RECEIVE ADDITIONAL INFORMATION?	If you have general questions
about this application call:

Stratospheric Ozone Hotline

1-800-296-1996

WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST INFORMATION FOR 2011
AND BEYOND

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:	Yes ___	No ___

If yes, the applicant assumes responsibility for the secure transmission
of electronic submissions.

Applicant Name: 

Primary Contact: 

Contact Name: 

Address: 

Daytime Phone:

Cell:

Fax:

Email Address

Specialty: (check one)  Agronomic ___	Economic ___

Alternate Contact: 

Contact Name: 

Address: 

Daytime Phone: 

Cell: 

Fax: 

Email Address: 

Specialty: (check one)  Agronomic ___		Economic ___

I certify that all information contained in this document is factual to
the best of my knowledge.

Signature: ______________________________________________	Date: _______

Print Name: _____________________________________________	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.  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.

Signature: ______________________________________________	Date: _______

Print Name: _____________________________________________	Title: _______

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 39 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.

WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST INFORMATION FOR 2011 AND
BEYOND (continued)

1. Location of Facility(ies): Enter the name and physical address of the
facility(ies) where the proposed critical use of methyl bromide will
take place.  Provide more details about the location if relevant to the
feasibility of alternatives to methyl bromide.

2. Commodity: Include all commodities that benefit from the application
of methyl bromide in a fumigation cycle. 

3. Range of structure/facility size by processors included in this
application: Insert number or percentage of users in each category.

0 to 1,000 (1,000 cu ft)	 	10,000 to 50,000 (1,000 cu ft)	 

1,000 to 5,000 (1,000 cu ft)	 	50,000 to 100,000 (1,000 cu ft)	 

5,000 to 10,000 (1,000 cu ft)	 	over 100,000 (1,000 cu ft)	 



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

1____  2a____  2b____  3a____  3b____  4a____  4b____  5a____  5b____ 
6a____  6b____ 7a____  7b____  8a____  8b____   9a____  9b ____  10a____
 10b____  11____

5. Is this applicant eligible for Quarantine and Preshipment (QPS) uses
of methyl bromide:

	Yes ___	 No ___ 	If yes, indicate amount: ____ lbs

6. Has this applicant previously applied for Critical Use Exemption of
methyl bromide:

	Yes ___	 No ___		If yes, indicate CUE #: ________

7. What is the amount of methyl bromide being requested by this
application: (Do NOT include QPS amounts) If a consortium is submitting
this application, the data should be the total for the consortium.

	2011	2012	2013

A.	Total Pounds Active Ingredient (a.i.) of Methyl Bromide



	B.	Total Actual Volume (1000 cu. ft.) Treated



	C.	Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE



	D.	Use Rate (lbs a.i./1000 cu. ft.)



	8. Please explain why there may be variations in the pounds or volume
(1,000 cu ft) treated from year to year, especially if the request is
higher this year than in previous years:

9. Please explain why methyl bromide is being requested:

10. Do you have access to recycled methyl bromide:

	Yes ___	No ___		If yes, please specify amount: _______ lbs

11. Do you anticipate that you will have any methyl bromide in storage
after January 1, 2011:

Yes ___	No ___		If yes, please specify amount: _______ lbs

12. Have you adjusted the request for the following issues:

Regulatory Issues:	     Yes ___No ___	Pest Pressure:		 Yes ___No ___	

Adoption of Alternatives: Yes ___No ___	Other (Please Explain): Yes
___No ___

_______________________________________________________________________

WORKSHEET 2: METHYL BROMIDE

Purpose of Data:  To establish a baseline estimate of commodity treated,
gross profits, and costs using methyl bromide.   

Instructions specific to each worksheet are located at the top of each
sheet.

Worksheet	Title

2-A	Methyl Bromide - Pest and Commodity 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
commodity 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 2004 - 2008

 	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 2004 - 2008. 

2-C	Methyl Bromide - Commodity Treated and Gross Profits for 2004 - 2008

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

 	This worksheet provides commodity treated and gross profits for 2004
through 2008.

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

2-D	Baseline - Operating Costs for 2008

 	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.

 	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-A: METHYL BROMIDE – PEST & PROCESSING INFORMATION

1. Commodity or Consortium: 

2. What month does your fumigation cycle start: Please check only one.

Jan	Feb	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec

 	 	 	 	 	 	 	 	 	 	 	 



3. Fumigation Timeline: Indicate when fumigation, major commodity and
pest management practices typically occur.  If the fumigation cycle is
longer than one year, change the months to an appropriate interval.

Beginning Fumigation Cycle	Time Interval ______________________    

(e.g. WEEKS/MONTH/YEAR/SEASON)

(please define time periods)	 	 	 	 	 	 	 	 	 	 	 	 

Facility Preparation	 	 	 	 	 	 	 	 	 	 	 	 

Sealing	 	 	 	 	 	 	 	 	 	 	 	 

Cleaning	 	 	 	 	 	 	 	 	 	 	 	 

Fumigation Timeline	 	 	 	 	 	 	 	 	 	 	 	 

Reception of Raw Materials	 	 	 	 	 	 	 	 	 	 	 	 

Processing	 	 	 	 	 	 	 	 	 	 	 	 

Storage	 	 	 	 	 	 	 	 	 	 	 	 

Raw Materials	 	 	 	 	 	 	 	 	 	 	 	 

Finished Product	 	 	 	 	 	 	 	 	 	 	 	 

Packing	 	 	 	 	 	 	 	 	 	 	 	 

Shipping	 	 	 	 	 	 	 	 	 	 	 	 

Retail Market Window	 	 	 	 	 	 	 	 	 	 	 	 

Other Pest Treatments	 	 	 	 	 	 	 	 	 	 	 	 

Other 	 	 	 	 	 	 	 	 	 	 	 	 

 	 	 	 	 	 	 	 	 	 	 	 	 



4. Please provide a simplified schematic diagram which illustrates the
basic steps of the commodity moving through the process from raw
material to finished product:

4a. Provide a narrative of market channel for each commodity, where it
is fumigated, and how the fumigation effects market availability and
commodity sale:

5. Target Pest(s) or Pest Problem(s): Please identify the key target
pests or pest problems for which methyl bromide is requested.  Provide
at least common name and genus and species if possible.  Additional
pests or pest problems can be provided as an attachment.  Please also
explain the specific reasons why methyl bromide is being requested for
each pest [e.g., effective herbicide is available, but not registered
for this crop; mandatory requirement to meet certification for disease
tolerance].

 	Common Name	Genus	Specific Reasons why Methyl Bromide is Needed

Pest 1	 	 	 

Pest 2	 	 	 

Pest 3	 	 	 

Pest 4	 	 	 

Pest 5	 	 	 



6.  Pest Economic Threshold: Please provide the economic threshold
information for each pest.  Describe year and source of information such
as survey or expert estimate.

 	Threshold	Units (e.g. pests/sq ft)	Year	Source

Pest 1	 	 	 	 

Pest 2	 	 	 	 

Pest 3	 	 	 	 

Pest 4	 	 	 	 

Pest 5	 	 	 	 



7. Target Pest Infestation: Please estimate the percentage of this
user's total structural/facility volume with a moderate to severe
problem with these pests.  Describe source of information such as a
survey or expert estimate.

 	Percentage of Total Structure/Facility	Source

Pest 1	%

	Pest 2	%

	Pest 3	%

	

8. Representative User: Please provide descriptive factors appropriate
for your operation.

a. Number of Facilities: _____

b. Gastightness Estimate (if available):* _________

* Give gastightness estimates where possible according to the following
scale: good - less than 25% gas loss within 24 hours or half loss time
of pressure difference greater than 1 minute; medium - 25-50% gas loss
within 24 hours or half loss time of pressure difference greater than 10
seconds; poor - 50-90% gas loss within 24 hours or half loss time of
pressure difference 1-10 second; very poor - more than 90% gas loss
within 24 hours or a pressure half loss time of less than 1 second.

9. In what part and phase of the operation does the methyl bromide
fumigation take place:  Please check all that apply and indicate
exposure time.

Structure / Facility: _________

Fumigation Chamber: _________

Commodity: _________

Prior to Storage: _________

Storage: _________

Prior to Shipping: _________

All: _________

Other: _________

10. For what percentage of the operation have alternative(s) replaced
methyl bromide in processing this commodity and if so, during what phase
of the process:

Alternative	% Replaced	Phase of Process	Details

Phosphine (Alone)	 	 	 

Heat Treatment	 	 	 

Phosphine in Combination	 	 	 

Other	 	 	 



11. Please provide a brief description of any equipment fumigated in
this operation:

WORKSHEET 2-B: METHYL BROMIDE – HISTORICAL USE 2004 - 2008

Row A:	Total Actual Pounds a.i. of Methyl Bromide Applied 

 	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.
 

Row B:	Total Actual Volume (1,000 cu ft) Treated

 	Enter the total actual volume (1,000 cu ft) treated.  Note:  This
number should be the total actual volume (1,000 cu ft) treated by the
individual user or total actual volume (1,000 cu ft) treated for the
entire consortium, for the year indicated.  

Row C:	Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE

 	Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic
70:30).

Row D:	Use Rate (lbs a.i./1000 cu. ft.)

 	Enter the use rate in pounds a.i. of methyl bromide per area.



For the years shown specify:	2004	2005	2006	2007	2008

A.	Total Actual Pounds a.i. of Methyl Bromide Applied





	B.	Total Actual Volume (1,000 cu ft) Treated





	C.	Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE





	D.	Use Rate (lbs a.i./1000 cu. ft.)





	

What is the frequency of methyl bromide applied per volume (1,000 cu
ft): (1x / year, 2x / year, 1x / 3 years, etc.)

_______ times per _______

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: 

Comments:

WORKSHEET 2-C: BASELINE – METHYL BROMIDE – COMMODITY TREATED &
GROSS PROFIT FOR 2004 - 2008

Column A:  	Year

 	Be sure to enter the year. Use as many rows as needed for each year
for all the commodities in the fumigation cycles from 2004 to 2008.  If
a fumigation cycle overlaps more than one calendar year, then the year
of the fumigation cycle is the year methyl bromide was applied.

Column B:  	Commodity

 	Enter all commodities that benefit from methyl bromide in the
fumigation cycle (interval between fumigations). See the Definitions
page for a comprehensive definition of the fumigation cycle.

	If someone other than the applicant benefits from the application of
methyl bromide in the fumigation cycle and you do not have the
quantitative data for the commodity treated in the same
facility/structure, please indicate so in the comments section below.

Column C:  	Market Categories

 	Enter marketing categories that determine prices received, for
example, grade (quality, taste, color) or timeliness (holiday market
season, early season, late season).  Itemize or aggregate these factors
to the extent appropriate if lack of methyl bromide would effect the
price in each category. 

Column D:  	Unit of Commodity

 	Enter the unit of measurement for each commodity (lbs, tons, cwt). 
If not by weight, specify in the comments section the average weight of
the measure.  For the international review board, all measures will be
converted to metric.

Column E:  	Total Commodity Treated

 	Enter the total units of commodity treated with methyl bromide and
processed/sold per area

Column F:  	Price

 	Enter average prices received by the users for that commodity and
category.  For the total line, you do not have to enter a price. 
Average price over all categories can be calculated separately, if
needed.  If a commodity treated is never owned by the facility, indicate
the fees charged for all services.

Column G: 	Cost of Goods Sold

 	Enter the total cost of goods sold (raw materials purchased) during
the period.  If this expense is not relevant to your post-harvesting
operation, please skip this column.

Column H:  	Gross Profit

 	Gross profit may be calculated using the data you entered as the
Total Commodity Treated times Price minus the Cost of Goods Sold.  If
gross profit is not equal to total commodity sold times price subtracted
by cost of goods sold ((Column E * Column F) - Column G), you may
override the formula and enter a different revenue amount.  Please
explain why this gross profit amount is different in the comment section
below.

A	B	C	D	E	F	G	H

Year	Commodity	Market Category

(grade, time, end use)	Unit of Commodity (e.g., lbs, tons)	Total
Commodity Treated        (per unit of commodity)	 Price

(per unit of commodity)	 Cost of Goods Sold

(per unit of commodity)	Gross Profit

(per unit of commodity)

 	 	 	 	 	 	 

	 	 	 	 	 	 	 	 

 	 	 	 	 	 	 	 

 	 	 	 	 	 	 	 









	Comments: WORKSHEET 2-D: METHYL BROMIDE – OPERATING COSTS FOR 2008

The purpose of this section 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.  Please fill in the unshaded areas.  The shaded areas can
be used if the information is known.

Column A:	Operating Expense Items

 	Identify the operations to which the costs apply.  You may add or
delete lines as necessary.  The operating expense items listed here are
not meant to be exhaustive or be representative of your specific
operating system. Other operating expenses include, but are not limited
to, wage/salary, advertising and selling, utilities, rent and lease,
insurance, and supplies. Be as precise as necessary to explain how lack
of methyl bromide would affect your operation, otherwise you may
aggregate operating expenses.  These are meant to provide suggestions
and to help you identify how your operation would change if methyl
bromide were unavailable. 

Column B:	Quantity Used per Volume (1,000 cu ft) or Weight (tons
(short))

 	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. 

Column C: 	Units (lbs. hours, etc.)

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

Column D:	Unit Cost ($)

 	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 (e.g. tarps).  If custom applied and
separate costs are unavailable, write 'custom' and enter total cost in
Column E.

Column E:	Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons
(short))

 	Enter all appropriate costs of operations per volume (1,000 cu ft) or
weight (tons (short)).  You may add or delete lines as necessary.   

 	If operation is defined in either cost per volume or cost per weight,
please keep the continuity of units.

A	B	C	D	E

Operating Expense Items	Quantity Used per Volume (1,000 cu. ft.) or
Weight (tons (short))	Units           (lbs., hours, etc.)	Unit Cost ($)
Cost ($) per Volume (1,000 cu. ft.) or Cost ($) per Weight (tons
(short))

1. Pest Management Costs (a+b+c+d)	 	 	 	 

a) Sanitation    	 	 	 	 

b) Pest Control	 	 	 	 

c) Methyl Bromide Fumigation (c1+c2)	 	 	 	 

c1) Product	 	 	 	 

c2) Application	 	 	 	 

d) Other Pest Management Costs	 	 	 	 

2. Repairs / Maintenance / Replacement	 	 	 	 

3. Interest	 	 	 	 

4. Depreciation for Plant Assets	 	 	 	 

5. Other Operating Expenses	 	 	 	 

TOTAL OPERATING COST	 

WORKSHEET 3: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE PEST CONTROL
REGIMENS

Purpose of Data: To estimate the loss as a result of not having methyl
bromide available.  EPA needs to compare data (commodity prices, gross
profit, operating expenses, etc.) on the use of methyl bromide and
alternative pest control regimens.

Complete Worksheet 3-A for each alternative pest control regimen. 
Please indicate the name of the specific alternative pest control
regimen addressed and add additional pages 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 Definitions
page for a comprehensive definition on fumigation cycles.

Worksheet	Title

3-A	 Alternatives - Technical Feasibility of Alternatives to Methyl
Bromide

 	You must complete one worksheet for each alternative.  Please insert
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 or we will assume no production or quality loss.

3-B	Alternatives - Changes in Operating Costs

 	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.

 	Please fill out this worksheet for each alternative for which the
economic evaluation would bolster the case that methyl bromide is
needed.

 	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.  

3-C	Alternatives - Economic Feasibility of Alternatives to Methyl
Bromide

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

 	Please include in this worksheet data for each alternative included
in worksheets 3-A and 3-B.



WORKSHEET 3-A: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE PEST CONTROL
REGIMENS

Name of Alternative: 

1. Pest Control When Comparing This Alternative to Methyl Bromide: 
Provide numerical estimates where possible.

Study # 	Pest Being Tested	Relative % Pest Control 	Scale of Study (e.g.
pilot, plot)	Resulting Damages (please specify)

1	 	 	 	 

2	 	 	 	 

3	 	 	 	 

4	 	 	 	 

5	 	 	 	 



2. Study Information: For the cited studies above, please list: study
name, authors, publication, date, and indicate with a checkmark if a
copy is attached and if it is on the EPA website.

Study # 	Copy?	EPA?	Month/Year project started and finished (e.g. Nov
'99 - Oct '04)	Details

1	 	 	 	 

2	 	 	 	 

3	 	 	 	 

4	 	 	 	 

5	 	 	 	 



3. Are there any production delays (downtime) associated with this
alternative?	Yes ___	No ___

	If yes, please continue with 3a, 3b, 3c.

	3a. Please specify the number of days per year of downtime:	 _________
days/year

	3b. What is the cost of production delays or downtime per year? $
_________  per year

	3c. Please explain the details of going into downtime and why it is
necessary with this alternative:

4. What is the estimated probability of the commodity not meeting
consumer quality standards with and without methyl bromide or
alternative treatments: Please explain.

5. Restrictions/Limitations on Alternative Use: This information will
be used to determine the amount of methyl bromide needed.

 	% of Structure/Facility/Volume	Details

Regulatory Restriction 	 	 

   -  Label Restriction 	 	 

Climate Restriction	 	 

Pest Resistant To Alternative	 	 

Structural Limitations	 	 

Facility Limitations	 	 

Other Restrictions/Limitations (Describe)	 	 



6. Why is this alternative not suitable to replace 100% of methyl
bromide use in processing this commodity:

7. Use Rate of Chemical Alternative:

Active Ingredient          (a.i.)	Name of Product and Formulation
Quantity per Volume            (1,000 cu ft)	Units                     
(gals, lbs, etc.)	Volume (1,000 cu ft) Treated	# of Applications per
Year

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 



8. Non-Chemical Pest Control: Please describe.

9. Fumigation Timeline: Indicate when fumigation, major commodity and
pest management practices typically occur.  If the fumigation cycle is
longer than one year, change the months to an appropriate interval.

Fumigation Cycle	Time Interval (e.g. WEEKS/MONTH/YEAR)

 	1	2	3	4	5	6	7	8	9	10	11	12

Facility Preparation	 	 	 	 	 	 	 	 	 	 	 	  

Sealing	 	 	 	 	 	 	 	 	 	 	 	 

Cleaning	 	 	 	 	 	 	 	 	 	 	 	 

Fumigation Timeline	 	 	 	 	 	 	 	 	 	 	 	 

Reception of Raw Materials	 	 	 	 	 	 	 	 	 	 	 	 

Processing	 	 	 	 	 	 	 	 	 	 	 

	Storage	 	 	 	 	 	 	 	 	 	 	 

	Raw Materials	 	 	 	 	 	 	 	 	 	 	 	  

Finished Product	 	 	 	 	 	 	 	 	 	 	 	 

Packing	 	 	 	 	 	 	 	 	 	 	 	 

Shipping	 	 	 	 	 	 	 	 	 	 	 	 

Retail Market Window	 	 	 	 	 	 	 	 	 	 	 	 

Other Pest Treatments	 	 	 	 	 	 	 	 	 	 	 	 

Other	 	 	 	 	 	 	 	 	 	 	 	 

Comments:

WORKSHEET 3-B: ALTERNATIVE – CHANGES IN OPERATING EXPENSES

Name of Alternative: 

Column A:  	Operating Expense Items

 	Identify the operations to which the costs apply.  You may add or
delete lines as necessary.  The operating expense items listed here are
not meant to be exhaustive or be representative of your specific
operating system. These are meant to provide suggestions and to help you
identify how your operation would change if methyl bromide were
unavailable.  

Column B:	Quantity Used per Volume (1,000 cu ft) or Weight (tons
(short))

 	This field is required only for alternatives.  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. 

Column C: 	Units (lbs. hours, etc.)

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

Column D:	Unit Cost ($)

 	For all inputs and operations detailed in Column B, please specify
the unit cost.  Also, indicate all costs of applying alternatives,
including any material costs (e.g. tarps).  If custom applied and
separate costs are unavailable, write 'custom' and enter total cost in
Column E.

Column E:	Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons
(short))

 	Enter all appropriate costs of operations per volume (1,000 cu ft) or
weight (tons (short)).  You may add or delete lines as necessary.   

 	If operation is defined in either cost per volume or cost per weight,
please keep the continuity of units.

A	B	C	D	E

Operating Expense Items	Quantity Used per Volume (1,000 cu ft) or Weight
(Tons (short))	Units (lbs., hours, etc.)	Unit Cost ($)	Cost ($) per
Volume (1,000 cu. ft.) or Cost ($) per Weight (tons (short))

1. Pest Management Costs (a+b+c+d)	 	 	 	 

    a) Sanitation    	 	 	 	 

    b) Pest Control	 	 	 	 

    c) Fumigation (c1+c2)	 	 	 	 

         c1) Product	 	 	 	 

         c2) Application	 	 	 	 

    d) Other Pest Management Costs	 	 	 	 

2. Repairs / Maintenance / Replacement	 	 	 	 

3. Interest	 	 	 	 

4. Depreciation for Plant Assets	 	 	 	 

5. Other Operating Expenses	 	 	 	 

 	 	 	 	 

                        TOTAL OPERATING COST	 



4. What are the additional new investments (structures, facilities,
equipment, fumigation chambers, etc.) needed to utilize this
alternative: Establish necessary capital expenditures required for the
uses of alternatives. For example, the incremental costs to convert to
heat treatment might include installing a steam heating system,
purchasing generators, installing necessary ductwork, and retrofitting
other components to make them amenable to heat treatment.

Type of Investment	Total Investment ($)	Life of Investment (# of years)
Salvage Value ($)	Interest Rate (%)

 	 	 	 	 

 	 	 	 	 

 	 	 	 	 

 	 	 	 	 



Comments:

WORKSHEET 4: EMISSION CONTROL

1. How do you currently minimize use and/or emissions of methyl bromide,
and how do you plan to further reduce use and/or emissions in the
future: For all use/emissions reduction technique that you use, please
fill out the text, where provided, or state the adoption rate and/or
describe changes.

 	What use/emission reduction methods are presently adopted?

Please state the emission reduction amounts for each listed year.	What
further use/emission reduction steps will be taken for the methyl
bromide used for critical uses? Please project the reduction amounts for
each listed year.

Methyl Bromide Dosage Reduction	1999	_____ lbs/acre	2009	_____ lbs/acre

	2008	_____ lbs/acre	2013	_____ lbs/acre

Less Frequent Application	1999	____ times per____	2009	____ times
per____

	 2008	____ times per____	2013	____ times per____

Formulation Changes (please specify)	1999	_____% methyl bromide, _____%
chloropicrin	2009	_____% methyl bromide, _____% chloropicrin

	 2008	_____% methyl bromide, _____% chloropicrin	2013	_____% methyl
bromide, _____% chloropicrin

Reclamation	1999

2009



2008

2013

	Sealing Buildings	1999

2009



2008

2013

	Integrated Pest Management (IPM)	1999

2009



2008

2013

	Cultural Practices (please specify)	1999

2009



2008

2013

	Other Pesticides (please specify)	1999

2009



2008

2013

	Non-Chemical Methods (please specify)	1999

2009



2008

2013

	Other Measures (please specify)	1999

2009



2008

2013

	

2.  If methyl bromide emission reduction techniques are not being used,
or are not planned for the future, state reasons:

WORKSHEET 5: FUTURE RESEARCH PLANS

1. Identify the top 3 to 5 target pests for your research:

	1. 

	2. 

	3. 

	4. 

	5. 

2. Provide a list of alternative chemicals or cultural practices that
have been tested:

1. 

	2. 

	3. 

	4. 

	5. 

3. Prioritize the alternative chemicals or cultural practices to be
tested:

1. 

	2. 

	3. 

	4. 

	5. 

4. What would be the best currently available alternative if methyl
bromide were not available:

5. Are there any other potential alternatives under development which
are being considered to replace methyl bromide:

6. Are there technologies being used to produce the crop which avoid the
need for methyl bromide?  Please explain whether such technologies could
replace a proportion of proposed methyl bromide use:

7. Please provide an overview/timeline of the plan to transition away
from using methyl bromide:

8. Will you include incidence reports where a commodity fails:

9. Please describe the management strategies that are in place or
proposed to eliminate the use of methyl bromide for the nominated
critical use, e.g., measures to avoid any increase in methyl bromide
consumption, measure to encourage the use of alternatives, information
on the market penetration of newly deployed alternatives and
alternatives that may be used in the near future:

10. 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.:  Please add additional rows if necessary.

Years	Name of Organization / Research Institution	Amount ($)

 	 	 

 	 	 

11. Other total investments, if any, made to reduce your reliance on
methyl bromide: $ ________

Describe each investment and its associated costs (e.g. specialized
machinery, etc.).  Please add additional rows if necessary.

Investment	Cost

 	 

 	 

 	 

 	 



13. Grant requests made to USDA, EPA, state, or other funding group:

For EPA Use Only ID # _________

SECTOR _____________________

WORKSHEET 6: SUMMARY

This section will be posted on the web to notify the public of requests
for critical use exemptions beyond the 2005 phaseout for methyl bromide.
 Therefore, this section cannot be claimed as CBI.

1. Consortium Name:

2. Location:

3. Crop:

4. Pounds of Methyl Bromide Requested:     2011 ______ lbs.	   	    2012
________ lbs.

5. Volume Treated with Methyl Bromide:      2011 ______ (1,000 cu. ft.) 
2012 ________ (1,000 cu. ft.)

6. If methyl bromide is requested for additional years, reason for
request:

	2011 ________ lbs.		Volume Treated ________ (1,000 cu. ft.)

	2012 ________ lbs.		Volume Treated ________ (1,000 cu. ft.)

	2013 ________ lbs.		Volume Treated ________ (1,000 cu. ft.)

7. Summary of Alternatives Not Feasible: 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.  Please add additional rows if
necessary.

Potential Alternatives	Not Technically Feasible	Not Economically
Feasible	Reasons

 	 	 	 

 	 	 	 

 	 	 	 

 	 	 	 

 	 	 	 

 	 	 	 

 	 	 	 



Definitions:

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 2003 fumigation cycle began in 2003 and would end in 2005.  The
data should cover the methyl bromide costs and usage for the methyl
bromide fumigation made in 2003, 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 2011 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.

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 similar 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.



 

OMB Control # 2060-0482

EPA Form # 5900-137		Post-harvest

 

