For EPA Use Only ID # _____________   

            SECTOR  ________________________	

	UNITED STATES 

ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

Application for Critical Use Exemption of Methyl Bromide 

for Pre Plant Use 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 (yields, crops/crop groupings, 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 38 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.



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 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.

WHAT INFORMATION IS REQUIRED?	

Critical use exemptions are valid for only one year and do not renew
automatically.  Users desiring to obtain an exemption must apply
annually to EPA.  Because of the latest changes in registrations, costs,
and economic aspects for producing critical use crops and commodities,
all applicants will be required to fill out the application form
completely.  If these Worksheets are not submitted, EPA will not include
the application in the U.S. nomination submitted for international
consideration.  



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.



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, and 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 September 15.

WHERE DO I SUBMIT THE APPLICATION?

 

 	Electronic Address for applications:   HYPERLINK
"mailto:arling.jeremy@epa.gov"  arling.jeremy@epa.gov 

When submitting an application electronically, you should also sign
Worksheet 1 and email or fax it to 202-343-2338

	

Mailing Address for applications being submitted by mail directly to the
EPA:

US Environmental Protection Agency

Methyl Bromide Critical Use Exemption

Office of Air and Radiation

Stratospheric Protection Division 

(6205T)

1200 Pennsylvania Ave, NW

Washington, DC 20460

	

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

1201 Constitution Ave, NW

Room 4355RR

Washington, DC  20004

HOW CAN I RECEIVE ADDITIONAL INFORMATION?	For general questions about
this application:

      Stratospheric Ozone Information Inbox at   HYPERLINK
"mailto:spdcomment@epa.gov"  spdcomment@epa.gov   

More information is also at http://www.epa.gov/ozone/mbr



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:	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 38 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 (continued)

1. Location: Enter the state, region, or county.

2. Crop/Crop Grouping: Include all crops/crop groupings that benefit
from an application of methyl bromide in a fumigation cycle. For a
definition of fumigation cycle, see Definitions page at end of
application.

3. Summary of Crop System: Enter the type of crop system used, e.g.,
open field [including tunnels added after treatment], permanent
glasshouses (enclosed), open ended polyhouses, others (please describe).

4. Range of acres farmed by growers included in this application: Insert
number or percentage of users in each category.

0 - 25 acres	 	100 - 200 acres	 

25 - 50 acres	 	200 - 400 acres	 

50 - 100 acres	 	over 400 acres	 



5. Climate Zone: Indicate the climate zone designation by reviewing the
U.S. climate zone map located at the end of this application or online
at http://planthardiness.ars.usda.gov/PHZMWeb/. Please check all that
apply.

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

6. Soil Type & Organic Matter: Indicate the soil type and percent
organic matter where methyl bromide would be applied. Please check all
that apply.

Soil Type:		Light ___		Medium ___		Heavy ___

Organic Matter:	0 to 2% ___		2 to 5% ___		over 5% ___

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

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

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

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

9. 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.

 	Year:______	Year:______

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

B	Use: Broadcast or Strip/Bed Treatment	 	 

C	If strip, then what percentage is treated with strip formulation?
(E.g., If 30 inches out of a total of 60 inches are treated with strip,
the percent is 50%)	 	 

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

E	Total Area to be Treated with the Methyl Bromide or MB/Pic Formulation
 	 

F	Use Rate (lbs a.i./acre)	 	 



10. Please explain why there may be variations in the pounds or acres
treated from year to year, especially if the request is higher this year
than in previous years:

11. Please explain why methyl bromide is being requested:

12. For the region where methyl bromide is being requested, if only part
of the crop area is treated with methyl bromide, indicate the reason why
methyl bromide is not used in the other area.  Additionally, identify
what alternative strategies are used to control the target pathogens and
weeds without methyl bromide in that area:

12a. Would it be feasible to expand the use of these methods to cover at
least part of the crop that has requested use of methyl bromide?  What
changes would be necessary to enable this:

13. Do you anticipate that you will have any methyl bromide in storage?

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

14. Have you adjusted the request for the following issues?:

Regulatory Issues:	Yes ___No ___		Disease Pressure:	 Yes ___No ___	

Soils Issues:		Yes ___No ___		Other (Please Explain): Yes ___No ___

_______________________________________________________________________

WORKSHEET 2: METHYL BROMIDE

Purpose of Data:  To establish a baseline estimate of crop/crop grouping
yields, gross revenue and costs using methyl bromide.  

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

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

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 the last five years.

2-C

	Methyl Bromide - Crop/Crop grouping Yield and Gross Revenue

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
the last five years.

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

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.

WORKSHEET 2-A: METHYL BROMIDE – CROP & PEST INFORMATION

1. Crop/Crop Grouping or Consortium: 

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

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

 	 	 	 	 	 	 	 	 	 	 	 



3. Fumigation and Crop Timeline: 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 the 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.

Beginning Fumigation Cycle

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

	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)

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

	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	 	 	 	 	 	 	 	 	 	 	 	 



4. What is the typical soil temperature range during methyl bromide:
______ to ______ °F

Comments: 

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 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.

 	Percentage of Total Growing Area	Source

Pest 1	 

%	 

Pest 2	 

%	 

Pest 3	 

%	 

Pest 4	 

%	 

Pest 5	 

%	 



8. Representative User: Please provide descriptive factors regarding
your operation.

	Average farm size: _________ acres

	Average acres in this crop: _________ acres

	Average area treated with methyl bromide: _________ acres

	Describe a few crops that could follow this crop: 

	Other descriptive factors regarding representative user:  

WORKSHEET 2-B: METHYL BROMIDE – HISTORICAL USE

Row A:	Year

	Enter dates for the last five years. For example, for applications
filled out in 2015, provide data from 2010-2014.

Row B:

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

	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.

Row C:	Use: Broadcast or Strip Bed Treatment

	Indicate whether broadcast or strip bed treatment is used.

Row D:	If strip, then what percentage is treated with strip formulation?

	If strip treatments are used, enter the percentage treated with strip
formulation (e.g., if 30 inches out of a total of 60 inches are treated
with strip, the percent is 50%).

Row E:	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 F:	Total Area to be Treated with the Methyl Bromide or MB/Pic
Formulation

	Enter the total area to be treated with methyl bromide or MB/Pic
Formulation.

Row G:	Use Rate (lbs a.i/acre)

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



A.	Year





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





	C.	Use: Broadcast or Strip Bed Treatment





	D.	If strip, then what percentage is treated with strip formulation?
(E.g., if 30 inches out of a total of 60 inches are treated with strip,
the percent is 50%)





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





	F.	Total Area to be Treated with the Methyl Bromide or MB/Pic
Formulation





	G.	Use Rate (lbs a.i/acre)





	

What is the frequency of methyl bromide applied per area: (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: METHYL BROMIDE – CROP/SPECIES YIELD & GROSS REVENUE

Column A:  	Year

 	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 for the last
five years.  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:  	Crops/Crop Groupings

 

 	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.

Column C:  	Market Categories

 	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 affect the yields in
each category.  

Column D:  	Yield

 	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.

Column E:  	Units of Measurement

 	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. 

Column F: 	Price 

 	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.

Column G:  	Gross Revenue

 	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.  

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:

Comments: WORKSHEET 2-D (1&2): METHYL BROMIDE – BASELINE –
OPERATING COSTS

Enter all operating costs incurred during a fumigation cycle.  Users
with a relatively short fumigation cycle (less than five years) should
use Worksheet 2-D(1); users cultivating perennial crops should use
Worksheet 2-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 or 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.

Column A:

	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.  

Operation / Input for Perennial Crops

For perennial crops in Worksheet 2-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.

Column B:

	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.

Column C:

	Units

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

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.

Column D:

	Unit Costs

	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. 

Yield

For harvest operations, indicate average yields or representative yields
from Worksheet 2-C

Column E:

	Total Cost per Acre 

	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 Question
#2.  If it is not, please explain any variations in yields and prices. 
For perennial crops, Column E should only be totaled for the years at
full production.

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).

WORKSHEET 2-D(1): METHYL BROMIDE – BASELINE – OPERATING COSTS FOR
2013

A	B	C	 D 	 E 

Operation / Input	Quantity Used per Acre	Units                          
   (lbs, hours, etc)	 Unit Cost ($) 	 Total Cost per Acre ($) 

Pre-plant Operations	 	 	 	 

Land preparation	 	 	 	 

Fumigation	 	 	 	 

    product (MeBr)	 	 	 	 

    application	 	 	 	 

Irrigation	 	 	 	 

Other costs	 	 	 	 

 	 	 	 	 

 	 	 	 	 

 	 	 	 	 

Cultural Operations	 	 	 	 

Seed / Seedlings	 	 	 	 

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 per Acre ($) 

Labor	 	 	 	 

Hauling	 	 	 	 

Material	 	 	 	 

Grading / Packing / Storage	 	 	 	 

Other Costs	 	 	 	 

	 	 	 	 

 	 	 	 	 

WORKSHEET 2-D(2): METHYL BROMIDE – BASELINE – OPERATING COSTS FOR
PERENNIAL CROPS

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)

 	PRE PRODUCTION YEARS 	INITIAL PRODUCTION YEARS 	FULL PRODUCTION YEARS


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	 



 	 	 	 	 	 	 	 

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 (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. 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 Definition 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 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.



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 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.  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, EPA will estimate fixed and overhead costs
across crops and regions to ensure consistency within the U.S.
nomination.



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 – TECHNICAL FEASIBILITY OF ALTERNATIVES
TO METHYL BROMIDE

Name of Alternative: _______________

1. Yield Loss & Pest Control When Comparing This Alternative to Methyl
Bromide: Provide numerical estimates where possible.  Please add
additional rows if necessary.

Study # (list below)	Pest Being Tested	% Yield Loss *	% Pest Control *
Details 

1	 	 	 	 

2	 	 	 	 

3	 	 	 	 

4	 	 	 	 

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.

+Please report Quality Loss in Table 3.  

2. Study Information: For the information in #1 above list: the study
name, authors, publication, date, and if a copy is attached. Please add
additional rows if necessary.

Study # 	Attached?	Details

1	 	 

2	 	 

3	 	 

4	 	 

5	 	 



3. Quality Loss*+: Describe quality impacts such as: percent smaller
fruit, reduced grade, smaller plants, crop damage, disease vector, etc. 

Market Category	Yield with Methyl Bromide	Units	Yield With Alternative
Units	Quality Impact Description

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 



4. Are there any production delays (planting/ harvesting) associated
with this alternative:

	Yes ___	No ___		If yes, please explain: 

5. Are there any variety or cultivar issues associated with this
alternative: 

Yes ___	No ___		If yes, please explain: 

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

 	% of Area	Details

Regulatory Restriction 	 	 

   -  Label Restriction 	 	 

   -  Township Caps 	 	 

Soil Restriction 	 	 

Pest Resistant To Alternative	 	 

Organic Matter Restriction	 	 

Off Site Damage (outgassing)	 	 

Other Restrictions (Describe)	 	 



7. Use Rate of Chemical Alternative:

Active Ingredient          (a.i.)	Name of Product and Formulation
Quantity a.i. per Acre	Units                      (gals, lbs. Etc.)	# of
Acres Treated	Number of Applications per Year

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 

 	 	 	 	 	 



8. Non-Chemical Pest Control: Please describe.

9. Alternative Timeline: 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 the 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.

Beginning Fumigation Cycle

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

	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 Alternative Cycle (if needed)

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

	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	 	 	 	 	 	 	 	 	 	 	 	 

Comments: 

WORKSHEET 3-B: ALTERNATIVES – CHANGES IN OPERATING COSTS

Name of Alternative: ________________

Column A:  

 

 

 	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.

Operation / Input for Perennial Crops

For perennial crops (Worksheet 3-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.

Column B:  

 

 

 	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.

Column C:  

 

 

 	Units

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

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.

Column D:  

 

 

 	Unit Costs

	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. 

Yield

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

Column E:  

 

 

 	Total Cost per Acre 

	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 any variations in yields and prices. 
For perennial crops, Column E should only be totaled for the years at
full production.

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).

WORKSHEET 3-B(1): ALTERNATIVES – CHANGES IN OPERATING COSTS

Name of Alternative: 

A	B	C	 D 	 E 

Operation / Input	Quantity Used per Acre	Units                          
   (lbs, hours, etc)	 Unit Cost ($) 	 Total Cost per Acre ($) 

Pre-plant Operations	 	 	 	 

Land preparation	 	 	 	 

Fumigation	 	 	 	 

    product (methyl bromide)	 	 	 	 

    application	 	 	 	 

Irrigation	 	 	 	 

Other costs	 	 	 	 

 	 	 	 	 

 	 	 	 	 

Cultural Operations	 	 	 	 

Seed / Seedlings	 	 	 	 

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 per Acre ($) 

Labor	 	 	 	 

Hauling	 	 	 	 

Material	 	 	 	 

Grading / Packing / Storage	 	 	 	 

Other Costs	 	 	 	 

 	 	 	 	 

 	 	 	 	 

WORKSHEET 3-B(2): ALTERNATIVES – CHANGES IN OPERATING COSTS FOR
PERENNIAL CROPS

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)

 	PRE PRODUCTION YEARS 	INITIAL PRODUCTION YEARS 	FULL PRODUCTION YEARS


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	 



 	 	 	 	 	 	 	 



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 you currently using?

Please state the emission reduction amounts.	What further use/emission
reduction methods will be used for critical uses? Please project the
reduction amounts for the year being requested.

Methyl Bromide Rate Reduction	_____ lbs/acre	_____ lbs/acre

	_____ lbs/acre	_____ lbs/acre

Less Frequent Application	____ times per____	____ times per____

	____ times per____	____ times per____

Formulation Changes (please specify)	_____% MeBr, _____% Pic	_____%
MeBr, _____% Pic

	_____% MeBr, _____% Pic	_____% MeBr, _____% Pic

Tarpaulin (High Density Polyethylene)



High Barrier Films



Virtually Impermeable Film (VIF)



Cultural Practices (please specify)



Other Pesticides (please specify)



Non-Chemical Methods (please specify)



Other Measures (please specify)





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:

Yes ___	No ___		If yes, please describe: 

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:

Yes ___	No ___		If yes, please describe: 

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

8. 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:

9. Will yield/quality loss be measured:	Yes ___	No ___

10. Will economic impacts be measured:	Yes ___	No ___

11. 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 ($)

 	 	 





 	 	 



12. 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: APPLICATION 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. Year:

5. Pounds of Methyl Bromide Requested:	________ lbs.		

6. Acres Treated with Methyl Bromide:	________ acres		

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 Alternative 	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
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

Expires 6/30/15

 EPA Form # 5900-136		Pre-Plant

OMB Control# 2060-0482

Expires 6/30/15

 EPA Form # 5900-136		Pre-Plant

