OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

For EPA Use Only ID # _____________ 

 SECTOR ________________________

UNITED STATES 

ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

2011 Application for Critical Use Exemption of Methyl Bromide 

for Pre Plant Use in the United States in 2014

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.
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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 2014 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 for 2014 must apply 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 August 12.
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

WHERE DO I 

SUBMIT THE 

APPLICATION?

Electronic Address for applications: 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

(6205 J)

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

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

More information is also at http://www.epa.gov/ozone/mbr
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST 

INFORMATION FOR 2014

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.
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST 

INFORMATION FOR 2014 (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://www.usna.usda.gov/Hardzone/ushzmap.html. 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____

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 #: ________
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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 of Exemption Request 2013 2014 2015

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 after January 1, 2012:

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 ___

_______________________________________________________________________
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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 2006 – 2010

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 2006-2010.

2-C Methyl Bromide - Crop/Crop grouping Yield and Gross Revenue for 2006-2010

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 2006 through 

2010.

The purpose of this worksheet is to determine past gross revenues when methyl 

bromide is used. This forms the baseline for evaluating the revenue impacts of using an 

alternative to replace methyl bromide.

2-D(1 & 2) Methyl Bromide - Baseline - Operating Costs for 2010

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

representative user for the consortium.

This data is needed to estimate a baseline for operating costs in order to estimate 

changes in costs and the impact on operating profit and short-run economic viability as 

a result of not using methyl bromide and to provide required information to the 

international review board.

The purpose of this worksheet is to determine operating expenses when methyl bromide 

is used. This forms the baseline for evaluating the cost impacts of using an alternative 

to replace methyl bromide. The data requested are designed to help you identify how 

your operation would change if methyl bromide were unavailable, which will be shown in 

Worksheet 3-B. Worksheet 2-D(1) is for users with a fumigation cycle of less than 5 

years. Worksheet 2-D(2) is for users growing perennial crops following a single 

fumigation at establishment.

In collaboration with USDA, we will estimate fixed and overhead costs across 

crops and regions to ensure consistency within the U.S. nomination.
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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: 
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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: 
OMB Control# 2060-0482

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EPA Form # 5900-136 Pre-Plant

WORKSHEET 2-B: METHYL BROMIDE – HISTORICAL USE FOR 2006 –

2010

Row A: 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 B: Use: Broadcast or Strip Bed Treatment

Indicate whether broadcast or strip bed treatment is used.

Row C: 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 D: 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 E: 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 F: Use Rate (lbs a.i/acre)

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

For the years shown specify: 2006 2007 2008 2009 2010

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)

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: 
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

WORKSHEET 2-C: METHYL BROMIDE – CROP/SPECIES YIELD & 

GROSS REVENUE FOR 2006 – 2010

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 from 2006 to 2010. 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: 
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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

OPERATING COSTS FOR 2010

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: preproduction (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).
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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

COSTS FOR 2010

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
OMB Control# 2060-0482

Expires 10/31/2011

EPA Form # 5900-136 Pre-Plant

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
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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.
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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: 
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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
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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: 
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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).
OMB Control# 2060-0482

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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
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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
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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 between 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 year.

Methyl 

Bromide Rate

Reduction

2006

_____ lbs/acre 2011_____ lbs/acre

2010 _____ lbs/acre 2015 _____ lbs/acre

Less Frequent 

Application

2006 ____ times per____ 2011 ____ times per____

2010 ____ times per____ 2015 ____ times per____

Formulation 

Changes 

(please 

specify)

2006 _____% MeBr, _____% Pic 2011 _____% MeBr, _____% Pic

2010

_____% MeBr, _____% Pic

2015

_____% MeBr, _____% Pic

Tarpaulin 

(High Density 

Polyethylene)

2006 2011

2010 2015

High Barrier 

Films

2006 2011

2010 2015

Virtually 

Impermeable 

Film (VIF)

2006 2011

2010 2015

Cultural 

Practices 

(please 

specify)

2006 2011

2010 2015

Other 

Pesticides 

(please 

specify)

2006 2011

2010 2015

Non-Chemical 

Methods 

(please 

specify)

2006 2011

2010 2015

Other 

Measures 

(please 

specify)

2006 2011

2010 2015

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

future, state reasons:
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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:
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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:
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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. Pounds of Methyl Bromide Requested: 2013 ________ lbs. 2014 ________ lbs.

5. Acres Treated with Methyl Bromide: 2013 ________ acres 2014 ________ acres

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

2013 ___________ lbs. Area Treated ___________ acres

2014 ___________ lbs. Area Treated ___________ acres

2015 ___________ lbs. Area Treated ___________ 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
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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.
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