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_______ SECTOR __________________

_



# UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

2011 Application for Critical Use Exemption of Methyl Bromide

for Post Harvest 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 s upport 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

t echnically and economically feasible alternatives are available.

In order to estimate the loss as a result of not having methyl

bromide available, EPA needs to compare data (commodity

prices, revenues, and costs) for your use of methyl bromide with

uses o f 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 th e 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 infor mation is estimated to average 3 8 hours per response and assumes a large

portion of applications will be submitted by consortia on behalf of many individual users of methyl brom ide. 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

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## INSTRUCTIONS

The information pr ovided 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 qua lify 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 econom ically 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 bromi de in 201 4 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 use rs. We encourage users with similar circumstances of use to

submit a single application (for example, any number of post harvest users with similar

commodity, pest, and structural conditions can submit a single application.)

If a consortium is applying f or multiple methyl bromide users, the economic data should be for

a representative or typical user within the consortium unless otherwise noted. If economic or

technical factors (such as types of commodities) affecting the ability of this "representative

user" to use alternatives are significantly different than other users in the consortium, more

than one application should be submitted to reflect these differences.

Please contact your local, state, regional

, or national commodity association and/or stat e

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 a n 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

Wo rksheets 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 busin ess 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 lan guage 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 handli ng by

EPA. If the applicant desires confidential treatment only until a certain date or until the

occurrence of a certain event, the notice should so state. Information covered by a claim of

confidentiality will be disclosed by EPA only to the extent, and by means of the procedures

set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no

claim of confidentiality accompanies the information when it is received by EPA, it may be

made available to the public by EPA without further notice to the applicant.

Applicants submitting their application via e

- mail assume responsibility for the confidentiality

of the electronic message transmission.

WHEN IS THE

INFORMATION

NEEDED? This application must be postmarked to the EPA address b e low no later than August 12

.OMB Control # 2060

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SUBMIT THE

APPLICATION? Electronic a ddress 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 a ddress 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:

U S Environmental Protection Agency

Methyl Bromide Critical Use Exemption

Office of Air and Radiat ion

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 at 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 impor tant 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 o f 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:

Em ail 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 particu lar 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 p art on information contained in this application.

Signature: ______________________________________________ Date: _______

Print Name: _____________________________________________ Title: _______

Burden means the total time, effort, or financial resource s 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 col lecting, 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

3 9 hour s 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 un less 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 (con t inued )

1. Location of Facility( ies) : Enter the name and physical address of the facility(ies) where the proposed

critical use of methy l bromide will take place. Provide more details about the location if relevant to the

feasibility of alternatives to methyl bromide.

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

fumigation cycle.

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

percentage of users in each category

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

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

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

4. Climate Average Minimum Temperature : Individual users should enter their climate zone designation

by reviewing the U.S. climate zone map located at the end of this workbook or it can be reviewed onli ne

at http://www.usna.usda.gov/ Hardzone/ushzmap.html. If a consortium is submitting this application,

please indicate the estimated percentage of consortium users in each climate zone. Please check all that

apply.

1____ 2a____ 2b____ 3a___ _ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____

7b____ 8a____ 8b____ 9a____ 9b ____ 10a____ 10b____ 11____

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

Yes ___ No ___ If yes, indic ate amount: ____ lbs

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

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

7. What is the amount of methyl bromide bein g requested by this application: (Do NOT include

QP S amounts ) If a consortium is submitting this application, the data should be the total for the

consortium.

201 3 201 4 2015

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

Bromide

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

C. Formulation (Ra tio of MB/Pic) to be Used for the

CUE

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

8. Please explain why there may be variations in the pounds or volume (1,000 c u ft) treated from

year to year , especially if the request is higher this year than in previous years :

9. Please explain why me thyl bromide is being requested:OMB Control # 2060

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- harvest 10 . Do you anticipate that you will have any methyl bromide in storage after January 1, 2013 :

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

11 . Have you adjusted the reque st for the following issues:

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

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

_______________________________________________________________________OMB Control # 2060

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## WORKSH EET 2 : METHYL BROMIDE

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

methyl bromide.

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

Worksheet Title

2

- A Methyl Brom ide

- Pest and Commodity Information

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

representative user for the consortium.

The purpose of this worksheet is to determine pest infestation and commodity

infor mation where methyl bromide is used. This forms the baseline for evaluating the

impacts of using an alternative to replace methyl bromide.

2

- B Meth yl Bromide

- Historical Use 2006

- 20 10

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 200 6

- 2010

.

2

- C Methyl Bromide

- Commodity Tr eated and Gross Profits for 2006

- 20 10

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

representative user for the consortium.

This worksheet provides commodity tr eated and gro ss profits for 2006 through 2010

. The purpose of this worksheet is to determine past gross profits when methyl bromide is

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

to replace methyl bromide.

2

- D Bas eline

- Operating Costs for 20 10

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

representative user f or the consortium.

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

changes in costs and the impact on operating profit and short

- run economic viability as

a result of not using methyl bromide.

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

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

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

operation w ould change if methyl bromide were unavailable, which will be shown in

Worksheet 3

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## WORKSHEET 2

- A : METHYL BROMIDE

– PEST & PROCESSING

INFORMATION

1. Commodity or Consortium:

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

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

3. Fumigation Timeline: Indicate when fumigation, major commodity and pest management practices

typically occur. If the fumigation cycle is longer than one year

, change the months to an appropriate

interval.

Beginning Fumigation Cycle Time Interval ______________________

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

(please define time periods)

Facility Preparation

Sealing

Cleaning

Fumigation Timeline

Reception of Raw Materials

Processing

Storage

Raw Materials

Finished Pr oduct

Packing

Shipping

Retail Market Window

Other Pest Treatments

Other

4. Pl ease provide a simplified schematic diagram which illustrates the basic steps of the

commodity moving through the process from r aw material to finished product:

4a. Provide a narrative of market channel for each commodity, where it is fumigated, and how the

fumigation effects market availability and commodity sale:OMB Control # 2060

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. Target Pest(s) or Pest Problem(s): Please identify the key target pests or pest problems for which

methyl bromide is req u ested. Provide at least common name and genus and speci es 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; ma ndatory 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 econ omic 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 . Targ et Pest Infestation : Please estimate the percentage of this user's total structural/facility volume

with a moderate to severe problem with these pests. Describe source of information such as a survey or

expert estimate.

Percentage of Total

Structure/Fac ility Source

Pest 1 %

Pest 2 %

Pest 3 %

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

a. Number of Facilities:

_____ b. Gastightness Estimate (if available) :*

_________

* Give gastightness estimates whe re possible according to the following scale: good

- less than 25% gas loss within 24 hours or half

loss time of pressure difference greater than 1 minute; medium

- 25

- 50% gas loss within 24 hours or half loss time of pressure

difference greater than 10 se conds; poor

- 50

- 90% gas loss within 24 hours or half loss time of pressure difference 1

- 10 second;

very poor

- more than 90% gas loss within 24 hours or a pressure half loss time of less than 1 second.

9

. In what part and phase of the operation does the methyl bromide fumigation take place : Please

c heck all that apply and indicate exposure time

. Structure / Facility :

_________ Fumigation Chamber :

_________ Commodity :

_________ Prior to Storage :

_________ Storage :

_________ Prior to Shipping :

_________ Al l :

_________ Other :

_________OMB Control # 2060

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- harvest 10 . For w hat percentage of the operation have alternative(s) replaced methyl bromide in

processing this commodity and if so, d uring what phase of the process:

Alternative % Replaced Phase of

Process Details

Phosphine (Alone)

Heat Treatment

Phosphine in Combination

Sulfuryl Fluoride

Other

11

. Please provide a brief description of any equipment fumigated in th is operation:OMB Control # 2060

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## WORKSHEET 2

- B : METH YL BROM IDE

– HISTORICAL USE 2006

- 2010

Row A: T otal Actual Pounds a

. i

. of Methyl Bromide Applied

Enter the total actual pounds active ingredient (a

. i

. ) of methyl bromide applied. Note: This

number should be the total pounds a

. i

. applied by the individual user or the entire consortium,

for the yea r indicated. Include only the pounds active ingredient of methyl bromide.

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

Enter the total actual volume (1,000 cu ft) treated. Note: This number should be the total

actual volume (1,000 cu ft) treat ed by the individual user or total actual volume (1,000 cu ft)

treated for the entire consortium, for the year indicated.

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

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

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

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

For the years shown specify: 200 6 2007 200 8 200 9 20 10

A

. Total Actual Pounds a.i. of Methyl

Bromide Applied

B

. Total Actual V olume (1,000 cu ft)

Treated

C

. Formulation (Ratio of MB/Pic

Mixture) to be Used for the CUE

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

What is the frequency of methyl bromide a pplied per volume (1,000 cu ft): (1x / year, 2x / year, 1x / 3

years , etc.)

_______ times per

_______

If there is a variation (greater than 10%) in the quantity a.i., the acres treated or average

application rate from year to year, please explain the reasons for the variation:

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## WORKSHEET 2

- C : BASELINE

– MET HYL BROMIDE

– COMMODITY

TREATED & GROSS PROFIT 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 commodities in t he

fumigation cycles from 200 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: Commodity

Enter all commodities that benefit from methyl bromide in the fumigation cycle (interval between

fumigations). See the Definiti ons page for a comprehensive definition of the fumigation cycle.

If someone other than the applicant benefits from the application of methyl bromide in the fumigation

cycle and you do not have the quantitative data for the commodity treated in the same f acility/structure,

please indicate so in the comments section below.

Column C: Market Categories

Enter marketing categories that determine prices received, for example, grade (quality, taste, color) or

timeliness (holiday market season, early season, late season). Itemize or aggregate these factors to the

extent appropriate i f lack of methyl bromide would a ffect the price in each category.

Column D: Unit of Commodity

Enter the unit of measurement for each commodity (lbs, tons, cwt). If not by weight, specify in the

comments section the average weight of the measure. For the international review board, all measures

will be converted to metric.

Column E: Total Commodity Treated

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

.

Column F: Price

Enter average prices received by the users for that commodity and category. For the total line, you do not

have to enter a price. Average price over all categories can be calculated separately, if need ed. If a

commodity treated is never owned by the facility, indicate the fees charged for all services.

Column G: Cost of Goods Sold

Enter the total cost of goods sold (raw materials purchased) during the period. If this expense is not

relevant to yo ur post

- harvesting operation, please skip this column.

Column H: Gross Profit

Gross profit may be calculated using the data you entered as the Total Commodity Treated times Price

minus the Cost of Goods Sold. If gross profit is not equal to total co mmodity sold times price subtracted

by cost of goods sold ((Column E * Column F)

- Column G), you may override the formula and enter a

different revenue amount. Please explain why this gross profit amount is different in the comment section

below.

A B C D E F G H

Year Commodity Market

Category

(grade,

time, end

use) Unit of

Commodity

(e.g., lbs,

tons) Total

Commodity

Treated

(per unit of

commodity) Price

(per unit of

commodity) Cost of

Goods Sold

(per unit of

commodity) Gross

Profit

(per unit of

commodity)

Comments:OMB Control # 2060

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## WORKSHEET 2

- D : METHYL B ROMIDE

– OPERATING COSTS FOR 2010

The purpose of this section is to determine operating expenses when methyl bromide is used. This f orms

the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data

requested are designed to help you identify how your operation would change if methyl bromide were

unavailable, which will be shown in Worksheet 3

- B. Please fill in the unshaded areas. The shaded

areas can be used if the information is known.

Column A: Operating Expense Items

Identify the operations to which the costs apply. You may add or delete lines as necessary. The

operating expense ite ms listed here are not meant to be exhaustive or be representative of your

specific operating system. Other operating expenses include, but are not limited to, wage/salary,

advertising and selling, utilities, rent and lease, insurance, and supplies. Be as precise as necessary

to explain how lack of methyl bromide would affect your operation, otherwise you may aggregate

operating expenses. These are meant to provide suggestions and to help you identify how your

operation would change if methyl bromide were unavailable.

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

This field is required only for methyl bromide. However you may include specific amounts of other

inputs or operations if you believe it helps to document the addi tional costs you would incur by using

an alternative fumigant.

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

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

Column D: Unit Cost ($)

For all inputs and operations d etailed in Column B, please specify the unit cost. Also, indicate all

costs of applying methyl bromide, including any material costs (e.g. tarps). If custom applied and

separate costs are unavailable, write 'custom' and enter total cost in Column E.

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

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

add or delete lines as necessary.

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

A B C D E

Operating Expense Items Quantity Used per

V olume (1,000 cu.

ft.) or Weight (t ons

(short)) Units

(lbs

. , hours,

etc.) Unit

Cost

($) Cost ($) per Volume

(1,000 cu

. ft

. ) or Cost

($) per Weight (tons

(short))

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

a) Sanitation

b) Pest Control

c) Methyl Bromide Fumigation (c1+c2)

c1) Product

c2) Application

d) Other Pest Manageme nt Costs

2. Repairs / Maintenance / Replacement

3. Interest

4. Depreciation for Plant Assets

5. Other Operating Expenses

TOTAL OPERATING COSTOMB Control # 2060

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## WORKSHEET 3 : ALTERNATIVES

– FEASIBILITY OF ALTERNATIVE

PEST CONTR OL REGIMENS

Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to

compare data (commodity prices, gross profit, operating expenses, etc.) on the use of methyl bromide

and alternative pest control regimens.

Complete Worksheet 3

- A for each alternative pest control regimen

. Please indicate the name of the

specific alternative pest control regimen addressed and add additional pages as required.

Enter all alternative pesticides and pest control methods (and associated cost and yield data) that would

replace one treatment of methyl bromide throughout the fumigation cycle. See the Definition s page for a

comprehensive definition on fumigation cycles.

Worksheet Title

3

- A Alternatives

- Technical Feasibility of Alternatives to Methyl Bromide

You must complete one worksheet for each alternative. Please insert the name of the

alternative in the area on top of the page. If you prefer, you may provide the information

requested in this worksheet in a narrative r eview. However, you must fill in the information

in Question #1 or we will assume no production or quality loss.

3

- B Alternatives

- Changes in Operating Costs

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

r epresentative user for the consortium.

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

in costs and the impact on operating profit and short

- run economic viability as a result of

not using methyl bromide and to provide required information to the international review

board.

Please fill out this worksheet for each alternative for which the economic evaluation

would bolster the case that methyl bromide is needed.

The purpose of this worksheet is to determi ne operating expenses when alternatives are

used for evaluating the cost impacts of using an alternative to replace methyl bromide. The

data requested are designed to help you identify how your operation would change if methyl

bromide were unavailable.

3

- C Alternatives

- Economic Feasibility of Alternatives to Methyl Bromide

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

representative user for the consortium.

Please include in this worksheet data for e ach alternative included in worksheets 3

- A

and 3

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## WORKSHEET 3

- A : ALTERNATIVES

– FEASIBILITY OF ALTERNATIVE PEST CONTROL

REGIMENS

Name of Alternative:

1. Pest Control When Comparing This Alter native to Methyl Bromide : Provide nume rical estimates whe re possible.

Study # Pest Being Tested Relative % Pest

Control Scale of Study (e.g.

pilot, plot) Resulting Damages (please

specify)

1

2

3

4

5

2 . Study Information: For the cited studies above, please list: s tudy name, authors, publication, date, and indicate with a checkmark if a copy is

attached and if it is on the EPA website.

Study # Copy? EPA? Month/Year project st arted and

finished (e.g. Nov '06

- Oct '09 ) Details

1

2

3

4

5

3. Ar e there any production delays (downtime) associated with this alternative? Yes

___ No

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

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

_________ days/year

3b. What is the c ost of production delays or downtime per year? $

_________ per year

3c. Please explain the details of going into downtime and why it is necessary with this alternative:OMB Control # 2060

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with and without methyl br omide or alternative treatments: Please explain.

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

of methyl bromide needed.

% of

Structure/Facility/Volume Deta ils

Regulatory Restriction

- Label Restriction

Climate Restriction

Pest Resistant To Alternative

Structural Limitations

Facility Limitations

Other Restrictions/Limitations (Describe)

6. Why is this alternative not suitable to replace 100% of methyl bromide u se in processing this

commodity:

7

. Use Rate of Chemical Alternative :

Active Ingredient

(a.i.) Name of Product and

Formulation Quantity per

Volume

(1,000 cu ft) Units

(gals, lbs

,

e tc.) Volume

(1,000 cu ft)

Treated # of

Applications

per Year

8

. Non

- Chemical Pest Control : Please describe.OMB Control # 2060

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. Fumigation Timeline : Indicate when fumigation, major comm odity and pest management practices

typically occur. If the fumigation cycle is longer than one year

, change the months to an appropriate

interval.

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

1 2 3 4 5 6 7 8 9 10 11 12

Facility Preparation

Sealing

Cleaning

Fumigation Timeline

Reception of Raw Materials

Processing

Storage

Raw Materials

Finished Product

Packing

Shipping

Retail Market Window

Other Pest Treatments

Other

Comments:OMB Control # 2060

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## WORKSHEET 3

- B : ALTERNATIVE

– CHANGES IN OPERATING

EXPENSES

Name of Alternative:

Column A: Operating Expense Items

Identify the operations to which the costs apply. You may add or delete lines as necessary. The

operati ng expense items listed here are not meant to be exhaustive or be representative of your

specific operating system. These are meant to provide suggestions and to help you identify how your

operation would change if methyl bromide were unavailable.

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

This field is required only for alternatives. However you may include specific amounts of other inputs or

operations if you believe it helps to document the additional costs you would incur by using an

alternative fumigant.

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

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

Column D: Unit Cost ($)

For all inputs and operations detailed in Column B, p lease specify the unit cost. Also, indicate all costs

of applying alternatives, including any material costs (e.g. tarps). If custom applied and separate costs

are unavailable, write 'custom' and enter total cost in Column E.

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

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

or delete lines as necessary.

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

A B C D E

Operating Expense Items Quantity Used per

Volume (1,000 cu

ft) or Weight

(Tons (short)) Units (lbs.,

hours, etc.) Unit Cost

($) Cost ($) per

Volume (1,000 cu.

ft.) or Cost ($) per

Weight (tons

(short))

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

a) Sanitation

b) Pest Control

c) Fumigation (c1+c2)

c1) Product

c2) Application

d) Other Pest Management Costs

2. Repairs / Maintenance / Replacement

3. Interest

4. Depreciation for Plant Assets

5. Other Operating Expenses

TOTAL OPERATING COSTOMB Control # 2060

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chambers, etc.) needed to utilize this alternative : Establish necessary capital expenditures required

for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include

installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting

other components to make them amenable to heat treatment.

Type of Investment Total

Investment ($) Life of Investment

(# of years) Salvage

Value ($) I nterest

Rate (%)

Comments:OMB Control # 2060

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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 adoptio n rate and/or describe changes.

What use/emission reduction methods are

presently adopted?

Please state the emission reduction amounts

for each listed year What further use/emission reduction steps

will be taken for the methyl bromide used

for critical uses? Please project the

reduction amounts for each listed year.

Methyl Bromide

Dosage

Reduction 200 6

___ ________ __ lbs/acre 20 1 1

___ _______ _ __ lbs/acre

20 10

___ ________ __ lbs/acre 20 1 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

Reclamation 2006 2011

2010 2015

Sealing

Buildings 2006 2011

2010 2015

Integrated Pest

Management

(IPM) 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: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 practices 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 bromide:

6. Are there technologies being used to produce the crop which avoid the need for methyl

bromide? Please explain whether such technologies could replace a proportion of proposed

methyl bromide use:

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

8. Will you include incidenc e reports w h ere a commodity fails :OMB Control # 2060

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- harvest 9. Please describe the management strategies that are in place or proposed to eliminate the use of

methyl bromide for the nominated critical use, e.g., measures to avoid any increase in methyl

bromide consumption, me asure to encourage the use of alternatives, information on the market

penetration of newly deployed alternatives and alternatives that may be used in the near future:

10. What is the cumulative amount spent and the types of contributions this consort ium has made

to fund research to develop alternativ es to methyl bromide since 1992, e.g. consortium dues

, direct research funding, etc. : Please add additional rows if necessary.

Years Name of Organization / Research Institution Amount ($)

11

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

________ Describe each inves tment 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 : SUMMARY

This section may be posted on the web to notify the public of requests for critical use e xemp tions

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

1. Consortium Name:

2. Location:

3. Crop:

4. Poun ds of M e thyl Bromide Requested: 2013

______ lbs. 2014 ________ lbs.

5. Volume Treated with Methyl Bromide : 2013

______ (1,000 cu

. ft

. ) 2014

________ (1,000 cu

. ft

. )

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

2013

____

___ ____ lbs. Volume Treated ______

___ __ ( 1,000 cu

. ft

. )

2014

___

___ _____ lbs. Vo lume Treated _____

___ ___ ( 1,000 cu

. ft

. )

2015

_____ ___ ___ lbs. Volume Treated ____

___ ____ ( 1,000 cu

. ft

. )

7. Summary of Alternatives Not Feasible: Place an "X" in the column(s) labeled "Not Technically

Feasible" and/or "Not Economically Feasible" where appropriate. Use the "Reasons" column to describe

why the potential alternative is not feasible. Please add additional rows if necessary.

Potential

Alternative Not

Technically

Feasible Not

Economically

Feasible ReasonsOMB Control # 2060

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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 t he 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 cyc le. 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 would end in 2005 . The data should

cover the methyl bromide costs a nd 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 t he 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, tomato es 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 ca n group sim il ar crops together if:

(i) Crops would experience similar yield and qual ity 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 cro ps including various flower or tree species can

be aggregated, with average yields per acre and prices. However, if

crops are distinctly different in revenues and operating costs, or the

cycles, the applicant may want to present yield, price and operating

costs for each crop separately and also indicate the proportion of land

area allocated to each crop.OMB Control # 2060

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