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SECTOR ________________________



# UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

2011 Application for Critical Use Exemption of Methyl B r omide

for Pre Plant Use in the United States in 201 4

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 wil l 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. Fil ling 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, m aintain, 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

i nformation, 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 informat ion; 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 3 8

hours per response and assumes a large p ortion 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 contr ol number.OMB Control# 2060

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## 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

de cided 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? I f 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 appli cation.)

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 t he 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 automati cally. 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 applica tion 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 comple te 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 suit able 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 fac ilitate 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 disclose d by EPA only to the extent, and by means of the procedures

set forth under 40 CFR Part 2 Subpart B; 41 FR 36 902, 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 mu st be postmarked to the EPA address below no later than August 1 2

.OMB Control# 2060

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SUBMIT THE

APPLICATION? Electronic Address for applications: arling.jeremy@epa.gov

When submitting an application electronicall y, 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

S tratospheric 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 Hotlin e 1

- 800

- 296

- 1996

More information is also at http://www.epa.gov/ozone/mbrOMB Control# 2060

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## WORKSHEET 1 : CONTACT AND METHYL BROMIDE REQUEST

INFORMATION FOR 201 4

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 Co nfidential Business Information: Yes ___ No ___

If yes, the applicant assumes respons ibility 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:

Addr ess:

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 natio nal 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

EP A of aggregate information based in part on information contained in this application.

Signature: ______________________________________________ Date: _______

Print Name: _____________________________________________ Title: _______

Burden means the tota l 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, inst all, and

utilize technolog y 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 inst ructions

and requir ements; 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 collecti on of

inform ation 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 respo nd to, a collection of information unless it displays a current OMB control number.OMB Control# 2060

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## WORKSHEET 1 : CONTACT AND METHYL BROMIDE REQUEST

INFORMATION FOR 201 4 (continued)

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

2. Crop/Crop Grouping: Include all cr ops/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 fiel d [including tunnels

added after tre atment], permanent glasshouses (enclosed) , open ended poly houses, 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.u sda.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 m ethyl 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 eligibl e for Quarantine and Preshipme nt (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

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QPS amounts

. )

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

Year of Exemption Request 20 1 3 201 4 201 5

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 i n 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 me thyl bromide is being requested:

12. For the region where methyl bromide is being requested, if only par t 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 with out methyl bromide in that a rea:

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 wo uld be necessary to enable this:

13 . Do you anticipate that you will have any methyl brom ide i n 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

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## WORKSHEET 2 : METHYL BROMIDE

Purpose of Data: To establish a baseline estimate of crop/crop grouping yields, gross revenue and

costs using methy l 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

represent ative 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 Me th yl Bromide

- Historical Use 2006

– 2010

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

the consortium.

This worksheet provid es data in actual usage for 2006

- 2010

. 2

- C Methyl Bromide

- Crop/Crop grouping Yiel d 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 200 6 through

2010

.

T he 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 C osts 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 im pact 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 ov erhead costs across

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

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## WORKSHEET 2

- A : METHYL BROMIDE

– CROP & PEST INFORMATION

1. Crop/Crop Grouping or Consortium:

2. Which month d oes your fumigation cycle start: Please check only on e.

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 par t 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 multip le crops/crop groupings not grown

sequentially, they will need to provide this information for all crops/crop groupings. Pleas e adjust timeline

as necessary. Please provide additional comments or description below or on a separate page.

Please begin the t imeline with the first land prepa ration. 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/YE AR/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 Mo nth

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

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methyl bromide is req u ested. 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 suc h 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 inform ation 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 b romide:

_________ acres

Describe a few crops that could follow this crop:

Other descriptive factors regarding representative user:OMB Control# 2060

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## WORKSHEET 2

- B : METHYL BROMIDE

– HISTORICAL USE FOR 200 6

–

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. applie d 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 A rea to be Treated with the Me thyl 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 wit h

strip, the percent is 50%)

D

. Formulation (Ratio of MB/Pic Mixture) to

be Used for the CUE

E

. Total A rea to be Treated with the Methyl

Bromide or MB/Pic Formulation

F

. Use Rate (lbs a.i/acre)

What is the frequency of methyl brom ide 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 :

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## WORKSHEET 2

- C : METHYL BROMIDE

– CROP/SPECIES YIELD &

GROSS REVENUE FOR 200 6

– 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 cycl es from 20 0 6 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 cro ps/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,

pleas e 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 a ffect 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,

ple ase 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.

Colum n 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 amoun t, 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 alloc ated to each crop/crop

grouping:

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## WORKSHEET 2

- D (1&2): METHYL BROMIDE

– BA SELINE

– 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 cu ltivating 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 operati ons/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 a s 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. Pleas e 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 producti on. 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 performi ng 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, p er

acre of land.

Column

C: Units

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

Cost per Unit of Yield

For harvest operations, specify costs that depend on amount of product harvested, for example,

packin g 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 inc lude

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

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## WORKSHEET 2

- D(1): METHYL BROMIDE

– BASELINE

– O PERATING

COSTS FOR 20 10

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 To tal Cost

per Acre ($)

Labor

Hauling

Material

Grading / Packing / Storage

Other CostsOMB Control# 2060

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## 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

Ac re 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 costsOMB Control# 2060

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## WORK SHEET 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 us e 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 a ll 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.

Works heet 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

inf ormation 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 appl ication, 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 opera ting 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 an d 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

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## WORKSHEET 3

- A : ALTERNATIVES

– TECHNICAL FEASIBILITY OF

ALTERNATIVES TO METHYL BROMIDE

Name of Alternative:

1. Yield Loss & P est 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* + : Desc ribe 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) a ssociated with this alternative:

Yes ___ No ___ If yes, please explain:

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

Yes _

__ No ___ If yes, please explain:OMB Control# 2060

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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 : P lease describe

.

9. Alternativ e 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 pre paration 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 StepsOMB Control# 2060

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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

Pes t Steps

Comments:OMB Control# 2060

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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

spe cific 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. Ple ase

ensure that the timeline in Worksheet 3

- A indicates the years of each peri od. 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 period s 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 sp ecify 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 in puts 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

C olumn 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' labo r. It should, therefore,

be less than gross reve nues 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

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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 CostsOMB Control# 2060

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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 Quan tity

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 costsOMB Control# 2060

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## WORKSHEET 4 : EMISSION CONTROL

1. How do you currently min imize 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 desc ribe 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? Pleas e project the

reduction amounts for each year.

Methyl

Bromide Rate

Reduction 200 6 _____ lbs/acre 20 1 1 _____ lbs/acre

20 10 _____ lbs/acre 201 5 _____ 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

sp ecify) 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:OMB Control# 2060

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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 practic es to be tested:

1.

2.

3.

4.

5.

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

5. Are there any other potential alternatives under development which are being consi dered to

replace methyl brom ide:

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:OMB Control# 2060

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methyl brom ide 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. Wi ll 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 dev elop 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 inve stment 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:OMB Control# 2060

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SECTOR _______________________



## WORKSHEET 6 : APPLICATION SUMMARY

This section will be posted on the web to notify the public of requests for critical use e xemptions

beyond the 2005 phase out for methyl bromide. Therefore, this section cannot be claimed as CBI.

1. Consortium Name:

2. Location:

3. Crop:

4. Pounds of Methyl B romide Requested : 201 3

________ lbs. 201 4

________ lbs.

5. Acres Tr eated with Methyl Bromide: 2013

________ acres 20 14

________ 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 Trea ted

____ ___ ____ 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 n ot feasible. Please add additional rows if necessary.

Potential

Alternative Not

Technically

Feasible Not

Economically

Feasible ReasonsOMB Control# 2060

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## Definitions:

Fumigation cycle: The period of time bet ween 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 m ade every 2 years, then the 2003

fumigation cycle began in 2003 and w ould 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 methy l

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 benefic iary 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 be nefits 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 h ave 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 o ne 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 tomat oes.

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 qu ality 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 p er 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 alloca ted to each crop.OMB Control# 2060

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