OMB Control # 2060-0482 Expires 10/31/2011 

## SECTOR _________________________ For EPA Use Only ID # ______________



# 2012 A **pplication for Critical Use Exemption of Methy l Bromide**  **for Post Harvest Use in the United States in 2014 and 2015**

**WHY IS THIS INFORMA** 

**TION NEEDED?**  

# UNITED STA

**TES ENVIRONMENTA L PROTECTION A** **GENCY WA** **SHINGTON, D.C. 20460**

Under the Clean Air Act and the international treaty to protect the ozone layer (the Montreal Protocol on Substances that Deplete the Ozone Layer), the production and import of methyl bromide was phased out in the United States on January 1, 2005. This application seeks information to support a U.S. request to produce and import methyl bromide for certain critical uses and circumstances beyond this 2005 phaseout date. 'The information in this application will be used to review whether your use of methyl bromide is "critical" because no technically and economically feasible alternatives are available. In order to estimate the loss as a result of not having

EPA Form # 4900-137 Post Harvest 

### Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 39 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. 

## Click on the Instructions tab located at the bottom of the screen for additional information. 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.

methyl bromide available, EPA needs to compare data (commodity prices, revenues, and costs) for your use of methyl bromide with uses of alternative pest control regimens.**WHAT INFORMA** 

**TION IS REQUIRED?** 
**HOW DO I A**  **PPLY?**

**WHEN IS THE INFORMA** 

**TION NEEDED?**  **Mailing A ddress for applications being submitted**  **by mail**  **directly**

**to the EPA :**  **Ad dress for applications being sent by**  **courier or**  **non-U.S. Postal ov** **ernight express deliv** **ery to the EPA**  **:** US Environmental Protection Agency US Environmental Protection Agency Methyl Bromide Critical Use Exemption Methyl Bromide Critical Use Exemption Office of Air and Radiation Office of Air and Radiation Stratospheric Protection Division (6205 J) Stratospheric Protection Division 1200 Pennsylvania Ave, NW 1310 L Street, NW , Suite 1047E Wa shington, DC 20460 Wa shington DC 20005 OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest

Applicants submitting their application via e-mail assume responsibility for the confidentiality of the electronic message transmission. This application must be postmarked to the EPA address below no later than **Au gust 15.**  **Electronic A ddress for applications: arling.jeremy** **@epa.gov When submitting an application electronically**  **, y ou should also sign Worksheet 1 and email or fax it to:**  **202-343-2338** Critical use exemptions are valid for only one year and do not renew automatically. Users desiring to obtain an exemption for 2015 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 W orksheets are not submitted, EPA will not include the application in the U.S. nomination submitted for international consideration. You may either complete an electronic (Microsoft W ord 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.

**WHERE DO I SUBMIT THE**  **AP PLICA** 

**TION?**

If you have general questions about this application call the Stratospheric Ozone Hotline at: 1-800-296-1996 More information is also at http://www.epa.gov/ozone/mbr The applicant may assert a business confidentiality claim covering part or all of the information in the application by placing on (or attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of notice employing language such as trade secret, proprietary, or company confidential. Allegedly confidential portions of otherwise non-confidential documents should be clearly identified by the applicant, and may be submitted separately to facilitate identification and handling by EPA. If the applicant desires confidential treatment only until a certain date or until the occurrence of a certain event, the notice should so state. Information covered by a claim of confidentiality will be disclosed by EPA only to the extent, and by means of the procedures set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no claim of confidentiality accompanies the information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant. **IS MY INFORMA** 

**TION CONFIDENTIA**  **L?**

**HOW CA N I**  **RECEIVE ADDITIONA**  **L INFORMA** 

**TION?** 

# INSTRUCTIONS The information provided by you in this application will be used to evaluate the requested methyl bromide use. The U.S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer decided that: "a use of methyl bromide should qualify as "critical" only if the nominating Party determines that: (i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a significant market disruption; and (ii) There are no technically and economically feasible alternatives available to the user that are acceptable from the standpoint of environment and health and are suitable to the crops and circumstances of the nomination ..."

If you anticipate that you will need methyl bromide in 2015 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. W e encourage users with similar circumstances of use to submit a single application (for example, any number of post harvest users with similar commodity, pest, and structural conditions can submit a single application.) If a consortium is applying for multiple methyl bromide users, the economic data should be for a representative or typical user within the consortium unless otherwise noted. If economic or technical factors (such as types of commodities) affecting the ability of this "representative user" to use alternatives are significantly different than other users in the consortium, more than one application should be submitted to reflect these differences. Please contact your local, state, regional or national commodity association and/or state representative agency to find out if they plan on submitting an application on behalf of your commodity group. **WHO AP**  **PLIES? SECTIONS OF** 

**WORKBOOK** OMB Control # 2060-0482, Expires 10/31/2011

**4.** Go to the blank worksheet where you want the copied information to be pasted. **5.** Again, select the top left corner of the worksheet (left of column A and above row 1) to select the entire worksheet.

The two arrows on the bottom right of the screen allow you to move the worksheet that you are viewing to the right or to the left. This is useful if the viewable area of on the screen is smaller than the entire page that is in the worksheet. **Printing worksheets 6.**  Go to the menu line at the top of the worksheet and select “Edit” then “Paste” **7.** Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet tab. Note: This is the only way you can copy a worksheet and not lose portions of the text instructions. **Viewing worksheets**

If you would like to print all worksheets that are contained in this workbook, go to the menu bar at the top of the screen and select "File" and then "Print." Then in the section of the menu that appears called "Print what," select "Entire W orkbook." EPA Form # 4900-137 Post Harvest

Wo rksheets are best viewed in "Page Break Preview." To select the view of the worksheet, go to the menu bar and select "View" and then "Page Break Preview." Page break preview shows only the printable area of the worksheet, with the blue lines that surround the screen indicating the edges of each page. To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select “View” and then “Zoom”. **Navigating between worksheets** The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to access the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the left or right will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows allow you move the worksheet tabs to the right or to the left incrementally. **EXCEL USER TIPS**  **Inserting a blank worksheet:**

**1.** To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select “Insert” then “worksheet” **2.** A tab with the name “Sheet 1” will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor and double click the “new tab” **3.** By double clicking in the tab you can now rename the worksheet to the appropriate number letter designation (e.g., 3-A(1), 3- A(1)(a), etc.) **4.** To move a newly inserted worksheet, simply drag the worksheet with your mouse to the desired location. **5.** Once you add a new worksheet, Excel will automatically name each subsequently added worksheet as Sheet 2, Sheet 3, etc... Follow the instructions above to rename the new blank worksheets as appropriate.

**2.** Select the top left corner of the worksheet (this is the space to the left of column A and above row 1. You will know that the entire worksheet has been selected because the row and column marks as well as the worksheet itself will change to a different **3.** Go to the menu line at the top of the worksheet and select “Edit” then “Copy”. **Worksheet 3.** Alternatives **Worksheet 3-A .**  Alternatives - Technical Feasibility of Alternatives to Methyl Bromide **Worksheet 3-B.** Alternatives - Changes in Operating Costs

**Copy ing and pasting an entire worksheet’s contents into a blank worksheet:**  **1.** Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in color when it has been selected. **Worksheet 4.** Emission Control **Worksheet 5.** Future Research Plans **Definitions Climate Zone Map**  **Worksheet 6.** Application Summary



# INSTRUCTIONS **Each w orksheet number corresponds to the tab number in the electronic v** **ersion of the application. Instructions specific to each w**  **orksheet are prov ided at the top of each sheet. A**  **header row is included on**  **each w orksheet to include an application ID number that EPA**  **will assign. Instructions**  **Worksheet 1.** Contact and Methy l Bromide Request Information **Worksheet 2.** Methy l Bromide **Worksheet 2-A .**  Methy l Bromide - Pest and Processing Information **Worksheet 2-B.** Methyl Bromide - Historical Use for 2007 - 2011 **Worksheet 2-C.** Methy l Bromide - Commodity Treated & Gross Profit for 2007 - 2011 **Worksheet 2-D.** Methyl Bromide - Operating Costs for 2011**Is this information Confidential Business Information (CBI)? Yes**  **No**

**Ap plicant Name**  **Primary Contact**  **Contact Name Specialty**  **Ad dress**  **Ag ronomic**  **Economic Day**  **time Phone Cell Phone**  **E-mail A ddress**  **Fax Al**  **ternate Contact Contact Name**  **Specialty Ad**  **dress Ag**  **ronomic Economic**  **Day time Phone**  **Cell Phone E-mail A**  **ddress Fax**  OMB Control # 2060-0482, Expires 10/31/2011

(Check One) 

# Worksheet 1. Contact & Methy **l Bromide Request Information for 2015** 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.

(Check One) If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.

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

**Signature Date**  **Title**

**Print Name** Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. **Title**

**Signature Date**  Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered "critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. **By**

**signing below** , you agree now to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application.

**Print Name**

EPA Form # 4900-137 Post Harvest Public reporting burden for this collection of information is estimated to average 39 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number.**1.**

**2. 3.** 

**4. Climate**  **(Average Minimum Temperature)** 

Zones: (check all that apply) **5. Yes**  **Am ount**  **No 6.**  **Yes CUE #**  **No 7.** 

**A. Total Pounds A** 

**ctive Ingredient (a.i.) of**  **Methy l Bromide**  **B. Total A** 

**ctual Volume (1000 cu. ft.) Treated**  **C. Formulation (Ratio of**  **MB/Pic Mixture) to be Used for the CUE**  **D. Use Rate (lbs**  **a.i./1000 cu. ft.) 8.** 

**9.**

**10. Yes**  **Lbs No** 

**11. Have y**  **ou adjusted the request for the follow ing issues?:**  **Regulatory**

**Issues: Yes___ No___ Pest Pressure: Yes___ No___**  **Ad option of A**  **lternatives: Yes___ No___ Other (Please Explain): Yes___ No___**  **2015 2014** 

EPA Form # 4900-137 Post Harvest OMB Control # 2060-0482, Expires 10/31/2011

**Have y ou previously** 

**applied for Critical Use Exemption of Methy l Bromide?**  (Individual users should enter their climate zone designation by reviewing the U.S. climate zone map located at the end of this workbook or it can be reviewed online at http://planthardiness.ars.usda.gov/PHZMW eb. If a consortium is submitting this application, please indicate the estimated percentage of consortium users in each climate zone.) **1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____ 7b____ 8a____ 8b____ 9a____ 9b____ 10a____ 10b____ 11____**  **10,000 to 50,000 (1,000 cu ft)**

If a consortium is submitting this application, the data should be the total for the consortium. **5,000 to 10,000 (1,000 cu ft)**

**What is the amount of methy l bromide being requested by**  **this application? (Do NOT include QPS amounts) Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methy**  **l bromide?** 

**Please explain w hy** 

**there may**

**be variations in the pounds or volume (1,000 cu ft) treated from y ear to y** **ear, especially if**  **the request is higher this y ear than in previous y** **ears:**
**Please explain w hy** 

**methy l bromide is being requested.** 

**Do y ou anticipate that y**  **ou w ill have any**  **methy l bromide in**  **storage after January 1, 2013?**  (Enter the name and physical address of the facility(ies) where the proposed critical use of methyl bromide will

take place. Provide more details about the location if relevant to the feasibility of alternatives to methyl bromide.) **Location of Facility (ies)** 

If yes, please specify amount (in pounds). **Range of structure/facility size by**  **processors included in this application?** 

# Worksheet 1. Contact & Methy **l Bromide Request Information for 2015**

(Include all commodities that benefit from the application of methyl bromide in a fumigation cycle. See the Wo rksheet entitled "Fumigation Cycle" for definitions.) **Commodity**
(Insert number or percentage of users in each category)

**0 to 1,000 (1,000 cu ft) 1,000 to 5,000 (1,000 cu ft)**  **ov er 100,000 (1,000 cu ft)**  **50,000 to 100,000 (1,000 cu ft)**

### Worksheet **Title**

**2-A Me**  **thyl Bromide - Pest and Commodity Information**

If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. The purpose of this worksheet is to determine pest infestation and commodity information where methy l bromide is used. This forms the baseline for evaluating the impacts of using an alternative to replace methy l bromide. **2-B Me**  **thyl Bromide - Historical Use 2007 - 2011**

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 2007 - 2011. **2-C Me**  **thyl Bromide - Commodity Treated and Gross Profits for 2007 - 2011**

If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. This worksheet provides commodity treated and gross profits for 2007 through 2011. The purpose of this worksheet is to determine past gross profits when methy l bromide is used. This forms the baseline for evaluating the revenue impacts of using an alternative to replace methy l bromide. **2-D Baseline - Operating Costs for 2011** 

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 methy l bromide. The purpose of this worksheet is to determine operating expenses when methy l bromide is used. This forms the baseline for evaluating the cost impacts of using an alternative to replace methy l bromide. The data requested are designed to help you identify how your operation would change if methy l bromide were unavailable, which will be shown in W orksheet 3-B.

EPA Form # 4900-137 Post Harvest OMB Control # 2060-0482, Expires 10/31/2011 

# Worksheet 2. Methyl Bromide **Purpose of Data:** To establish a baseline estimate of commodity treated, gross profits, and costs using methy l bromide. Instructions specific to each worksheet are located at the top of each sheet.

### 1.

**2. Jan**  **Feb Mar**  **Ap r**  **May Jun**  **Jul Au**  **g Sept**  **Oct Nov**  **Dec**

**3. Fumigation Timeline:**  **Beginning Fumigation Cy cle**  (please define time periods) Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw

Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market W indow Other Pest Treatments Other
**4.**

**4a.** OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest 

### Provide a narrative of market channel for each commodity **, where it is fumigated, and how the fumigation effects**  **market availability**

**and commodity**

**sale.** Time Interval ______________________ (e.g. W EEKS/MONTH/YEAR/SEASON)

**Please provide a simplified schematic diagram w hich illustrates the basic steps of the commodity**  **moving through the process from raw**  **material to finished product.** 

# Worksheet 2-A **. Methyl Bromide - Pest & Processing Information**

(Indicate w hen fumigation, major commodity and pest management practices ty pically occur. If the fumigation cy cle is longer than one y ear change the months to an appropriate interval.) **What month does y our fumigation cy** **cle start?** (check only one) **Commodity**

**or Consortium:**

### 5. **Target Pest(s) or Pest**

**Problem(s):**

**Pest 1 Pest 2**  **Pest 3 6.**  **Pest Economic Threshold:**

**Pest 1 Pest 2**  **Pest 3 7.**  **Target Pest Infestation:**

**Pest 1 %**  **Pest 2 %**  **Pest 3 %**  **8.**

**9. Structure / Facility** 

**Commodity Storage**  **Al l**  **Other 10.** 

**11.** 

# Worksheet 2-A **. Methyl Bromide - Pest & Processing Information** OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest 

### Other **Please provide a brief description of any equipment fumigated in this operation.**  (Please identify the top 3 target pests or pest problems. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment.) 

### Common Name **Genus Indicate if**  **common or**  **minor pest** 

(If available, please provide the economic threshold information for each pest, units, and source of information.) 

### Economic **Threshold Units**  (e.g.

pests/cu ft) **Source**

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

### Percentage of Total **Structure/Facility Source** 

**Al ternative**  Phosphine in Combination Heat Treatment **Phase of Process Representative User :**  (Please provide descriptive factors appropriate for your operation.)



### % Replaced **What percentage of the operation have alternative(s) replaced methy l bromide in processing this commodity**  **and if so, during w**  **hat phase of the process? Details**  Phosphine (Alone) **Fumigation Chamber Prior to Storage**  **In w hat part and phase of the operation does the methy**  **l bromide fumigation take place?** (check all that apply and indicate exposure time)



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

### b. Gastightness Estimate:* **a. Number of Facilities:**

### 2007 **2008 2009**  **2010 2011** 

**A. B.**  **C. D.**  **What is the frequency of methyl bromide applied per volume (1,000 cu ft)?** (1x / y ear, 2x / y ear, 1x / 3 years, etc.) **Row A :** 

**Row B:**

**Row C:**

EPA Form # 4900-137 Post Harvest



### Enter the formulation of methy l bromide used (e.g. MB 98:2; MB/Pic 70:30). **Use Rate (lbs a.i./1000 cu. ft.)** Enter the use rate in pounds a.i. of methy l bromide per area.

**Use Rate (lbs a.i./1000 cu. ft.)**
_________ tim es per ____________ OMB Control # 2060-0482, Expires 10/31/2011 

# Worksheet 2-B. Methyl Bromide - Historical Use 2007 - 2011

**Total A ctual Pounds a.i. of Methyl Bromide A**  **pplied**

**Total A ctual**  **Volume (1,000 cu ft) Treated** 

**Total Pounds A ctive**  **Ingredient (a.i.) of Methyl Bromide**  **Row D:**

**If there is a variation (greater than 10%) in the quantity a.i., the volume (1,000 cu ft) treated or average application rate from year to year, please explain the reasons for the variation.** 

Enter the total actual pounds active ingredient (ai) of methy l bromide applied. Note: This number should be the total pounds ai applied by the individual user or the entire consortium, for the y ear indicated. Include only

the pounds active ingredient of methy l bromide.

**For the years shown specify:**

**Formulation (Ratio of MB/Pic Mixture) to be Used for the**  **CUE Total A** **ctual Volume (1000 cu. ft.) Treated**  **Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE** Enter the total actual volume (1,000 cu ft) treated. Note: This number should be the total actual volume (1,000 cu ft) treated by

the individual user or total actual volume (1,000 cu ft) treated for the entire consortium, for the y ear indicated.

**Comments:**

### A **C D**  **E F**  **G H**  **Year Ma**  **rket Category** (grade, time, end use) **Unit of Commodity**  (e.g., pounds, 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 ) $ 0.00 OMB Control # 2060-0482, Expires 10/31/2011



### Comments:

EPA Form # 4900-137 Post Harvest



### B **Commodity** Enter average prices received by the users for that commodity and category . For the total line, y ou do not have to enter a price. Average price over all categories can be calculated separately, if needed. If a commodity treated is never owned by the facility, indicate the fees charged for all services. Enter the total cost of goods sold (raw materials purchased) during the period. If this expense is not relevant to y our postharvesting operation, please skip this column. 

### Column G: **Cost of Goods Sold**

Gross profit may

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

### Gross Profit **Column H:** If someone other than the applicant benefits from the application of methy l bromide in the fumigation cy cle and you do not

have the quantitative data for the commodity treated in the same facility /structure, please indicate so in the comments section below.



### Column F: **Price**

Enter the total units of commodity treated with methy l bromide and processed/sold per area. 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 D: **Unit of Commodity**

**Total Commodity Treated Column E:**  Enter marketing categories that determine prices received, for example, grade (quality , taste, color) or timeliness (holiday

market season, early

season, late season). Itemize or aggregate these factors to the extent appropriate if lack of methy l bromide would effect the price in each category
. 

### Ma **rket Categories Column C:**  **Column B: Commodity**  

# Worksheet 2-C. Baseline - Methyl Bromide - Commodity Treated &

**Gross Profit for 2007 - 2011 Column A**  **:** Be sure to enter the y ear. Use as many rows as needed for each y ear for all the commodities in the fumigation cy cles from 2007 to 2011. If a fumigation cy cle overlaps more than one calendar y ear, then the y ear of the fumigation cy cle is the y ear methy l bromide was applied. 

### Year

Enter all commodities that benefit from methy l bromide in the fumigation cy cle (interval between fumigations). See the Fumigation Cycle W orksheet for a comprehensive definition of the fumigation cy cle.

### Column A **:**

**Column B:**
**Column C: Column D:** 

**Column E:**

**B C**  **D E**  **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))** 

5. Other Operating Expenses **Operating Expense Items**

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest 

### TOTA **L OPERA**

**TING COSTS** 3. Interest **Please fill in the unshaded areas. The shaded areas can be used if the information is known.**

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. 

### Quantity Used per Volume (1,000 cu ft) or Weight (tons (short))

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units. For all inputs and operations detailed in Column B, please specify the units of measurement.



### 4. Depreciation for Plant Assets 1. Pest Management Costs (a+b+c+d) a) Sanitation b) Pest Control c) Methy l Bromide Fumigation (c1+c2)

**Units (lbs. hours, etc.) Unit Cost ($)**  For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying methyl bromide, including any material costs (e.g. tarps). If custom applied and separate costs are unavailable, write 'custom' and enter total cost in Column E. 

# Worksheet 2-D. Methyl Bromide - Operating Costs for 2011 The purpose of this worksheet is to determine operating expenses when methy l bromide is used. This forms the baseline for evaluating the cost impacts of using an alternative to replace methy l bromide. The data requested are designed to help you identify how your operation would change if methy l bromide were unavailable, which will be shown in W orksheet 3-B.

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

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

### Cost ($) per Volume (1,000 cu ft) or Cost ($) per Weight (tons (short))

### Worksheet

**3-A**

**3-B**

**3-C** Enter all alternative pesticides and pest control methods (and associated profit and production practices) that would replace one treatment of methy l bromide throughout the fumigation cy cle. See the Definition worksheet for a comprehensive definition on fumigation cy cles.

**Title A**  **lternatives - Technical Feasibility of A lternatives to Methyl Bromide**  You m ust complete one worksheet for each alternative. Please insert the name of the alternative in the area on top of the page. If you prefer, you may provide the information requested in this worksheet in a narrative review. However, you must fill in the information in Question #1 or we will assume no production or quality loss. OMB Control # 2060-0482, Expires 10/31/2011 

# Worksheet 3. A **lternativ es - Feasibility of A**  **lternativ e Pest Control**  **Regimens Purpose of Data:**  To estimate the loss as a result of not having methy l bromide available. EPA needs to compare data (commodity

prices, gross profit, operating expenses, etc.) on the use of methy l bromide and alternative pest control regimens. Complete W orksheet 3-A for each alternative pest control regimen. Each worksheet contains a place holder in the title for yo u to insert the name of the specific alternative pest control regimen addressed. You should add additional worksheets as required.

The purpose of this worksheet is to determine operating expenses when alternatives are used for evaluating

the cost impacts of using an alternative to replace methy l bromide. The data requested are designed to help yo u identify

how your operation would change if methy l bromide were unavailable. **Al ternatives - Economic Feasibility of A**  **lternatives to Methyl Bromide**

EPA Form # 4900-137 Post Harvest



### Al **ternatives - Changes in Operating Costs** If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. This data is needed to estimate a baseline for operating costs in order to estimate **changes in costs** and the im pact on operating profit and short-run economic viability as a result of not using methy l 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.** 

If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. **Please include in this worksheet data for each alternative included in Worksheets 3-A and 3-B.** **1. Study** 

**# Relative %**  **Pest Control**  **1 2**  **3 4**  **5 2.**  **Study**

**# Copy**  **? EPA?**  **1 2**  **3 4**  **5 3.**  **Yes No** 

(If yes, please continue with 3a, 3b, and 3c) **3a. 3b.**  **3c.**

**4.**

**5.**

**6. Pest Control When Comparing This A**  **lternative to Methy l Bromide**  (Provide numerical estimates where possible.) 

## Al **ternative: [ Insert A**  **lternative ]**

- Label Restriction **% of Structure/Facility /Volume**  **Details Restrictions/Limitations on A**  **lternative Use** OMB Control # 2060-0482, Expires 10/31/2011 

# Worksheet 3-A **. A lternativ**  **es - Technical Feasibility of A lternativ**  **es to Methyl Bromide** 

For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website. **Scale of Study (e.g. pilot, plot)** 

**Study Information** 

**Pest Being Tested**

Climate Restriction Regulatory Restriction This information will be used to determine the amount of methyl bromide needed.

**Please explain the details of going into dow ntime and w**  **hy it is necessary** 

**w ith this alternative.**  **What is the cost of production delay s or dow**  **ntime per y ear?**  **$ per y** **ear**

**What is the estimated probability of the commodity** 

**not meeting consumer quality standards w**  **ith and w ithout methy**  **l bromide or alternative treatments?**  (please explain)

Pest Resistant To Alternative Structural Limitations

EPA Form # 4900-137 Post Harvest Other Restrictions/Limitations (Describe) **Resulting Damages (please specify )** 

Facility Limitations **Why is this alternative not suitable to replace 100% of methy**  **l bromide use in processing this commodity ?**  **Month/Year project started and finished (e.g. Nov '06 - Oct '09)**  **Details**

**day s/y** **ear Please specify** 

**the number of day s per y** **ear of dow ntime:**  **Ar e there any** 

**production delay s (dow**  **ntime) associated w ith this alternative?** **7.**

**8.**

**9.**

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

## Al **ternative: [ Insert A**  **lternative ]** OMB Control # 2060-0482, Expires 10/31/2011 

# Worksheet 3-A **. A lternativ**  **es - Technical Feasibility of A lternativ**  **es to Methyl Bromide** 
**Use Rate of Chemical A lternative:**  **Volume (1,000 cu ft) Treated**  **# of A pplications per Year**  **Active Ingredient (a.i.)**  **Name of Product and Formulation Quantity**  **per Volume**  **(1,000 cu ft) Units** 

**(gals, lbs., etc.)**

Sealing

EPA Form # 4900-137 Post Harvest Other Pest Treatments Other **Fumigation Cy cle** 

Finished Product Packing Raw Materials Shipping Cleaning Fumigation Timeline Reception of Raw Materials Processing

Retail Market W indow **Non-Chemical Pest Control:** (please describe)

(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.) Time Interval (e.g. W EEKS/MONTH/YEAR) **Fumigation Timeline:** 

Storage Facility Preparation

**Comments:**

### Column A **:**

**Column B:**
**Column C: Column D:** 

**Column E:**

B C D E **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** 

**Total Inv estment**  **($) Life of Inv**  **estment**

**(# of y ears)**  **Salv age Value ($)**  **Interest Rate (%)** OMB Control # 2060-0482, Expires 10/31/2011



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

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

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. 5. Other Operating Expenses 2. Repairs / Maintenance / Replacement 3. Interest **Please fill in the unshaded areas. The shaded areas can be used if the information is known.**

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

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

# Worksheet 3-B. A **lternativ e - Changes in Operating Expenses**  **Al ternative:**  **[ Insert A lternative ]** 

**Comments: TOTA**  **L OPERA TING COST**  **What are the additional new inv estments (structures, facilities, equipment, fumigation chambers, etc.) needed to utilize**  **this alternativ e?**  b) Pest Control c1) Product

EPA Form # 4900-137 Post Harvest 

### a) Sanitation

4. Depreciation for Plant Assets

**Unit Cost ($)**

c2) Application c) Fumigation (c1+c2)

**Ty pe of Inv**  **estment** d) Other Pest Management Costs

**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. A**1.**

**2007** _____ lbs/cubic ft **2012** _____ lbs/cubic ft **2011** _____ lbs/cubic ft **2016** _____ lbs/cubic ft **2007** ____ times per____ **2012** ____ times per____ **2011** ____ times per____ **2016** ____ times per____ **2007** _____% methyl bromide, _____% chloropicrin **2012** _____% methyl bromide, _____% chloropicrin **2011** _____% methyl bromide, _____% chloropicrin **2016** _____% methyl bromide, _____% chloropicrin **2007 2012**  **2011 2016**  **2007 2012**  **2011 2016**  **2007 2012**  **2011 2016**  **2007 2012**  **2011 2016**  **2007 2012**  **2011 2016**  **2007 2012**  **2011 2016**  **2007 2012**  **2011 2016**  **2.**

EPA Form # 4900-137 Post-Harvest **Formulation Changes (please specify)**  OMB Control # 2060-0482, Expires 10/31/2011 **How do y ou currently**  **minimize use and/or emissions of methy l bromide, and how do y** **ou plan to further reduce use and/or emissions in the future?**  (For all use/emissions reduction technique that you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.)

**Other Measures (please specify)**  **Methy l Bromide**  **Dosage Reduction** 

## Worksheet 4. Emission Control

**What use/emission reduction methods are presently adopted? Please state the emission reduction amounts** 

**between each listed y ear.**  **What further use/emission reduction steps will be taken for the methy**  **l bromide used for critical uses? Please project the**

**reduction amounts for each y ear.** 

**Cultural Practices (please specify)** 
**Other Pesticides (please specify)** 

**If methy l bromide emission reduction techniques are not being used, or are not planned for the future, state reasons:**  **Non-Chemical Methods (please**  **specify) Less Frequent**  **Application**

**Reclamation**
**Sealing Buildings**
**Integrated Pest Mangement (IPM)** **1. 1**  **4 2**  **5 3**  **2. 1**  **4**

**2 5**  **3 3.**  **1 4** 

**2 5**  **3 4.** 
**5.**

**6.**

**7.**

**8.**
**9.**

**10. Year**  **Am ount ($)** 

**11.** $ **Cost**
**12. Provide a list of alternative chemicals or cultural practices that have been tested.**  OMB Control # 2060-0482, Expires 10/31/2011 

# Worksheet 5. Future Research Plans Please describe future plans to test alternatives to methyl bromide. You may use this worksheet to describe all future plans. **Identify the top 3 to 5 target pests for y**  **our research.**

**Prioritize the alternative chemicals or cultural practices to be tested.**

**What w ould be the best currently**  **available alternative if methy l bromide w**  **ere not available?**

**Grant requests made to USDA , EPA** **, state, or other funding group.** (Describe each investment and its associated costs. e.g. specialized machinery, new facilities, etc.) **Investment What is the cumulative amount spent and the ty**  **pes of contributions this consortium has made to fund research to develop alternatives to methy**  **l bromide since 1992?** (e.g. consortium dues, direct research funding, etc.)

EPA Form # 4900-137 Post Harvest **Other total investments, if any , made to reduce y**  **our reliance on methy l bromide?**  **Ar e there any** 

**other potential alternatives under development w hich are being considered to replace methy**  **l bromide?** 

**Ar e there technologies being used to produce the crop w**  **hich avoid the need for methy l bromide? Please**  **explain w hether such technologies could replace a proportion of proposed methy**  **l bromide use.**

**Name of Organization / Research Institution Please describe the management strategies that are in place or proposed to eliminate the use of methy**  **l bromide for the nominated critical use, e.g., measures to avoid any**  **increase in methy l bromide consumption,**  **measure to encourage the use of alternatives, information on the market penetration of new ly**  **deploy ed**  **alternatives and alternatives that may be used in the near future.**  **Will y ou include incidence reports w**  **here a commodity fails?**  **Please provide an overview /timeline of the plan to transition aw**  **ay from using methy**  **l bromide.**

### 1. **2. 3.**  **4. 2014**  **lbs. 2015**  **lbs. 5.**  **2014 (1,000 cu ft)**  **2015 (1,000 cu ft)** 

**Not Technically**  **Feasible Not** 

**Economically Feasible**  **For EPA Use Only ID # _______________**  **SECTOR ___________________________ This worksheet will be posted on the web to notify**  **the public of requests for critical use exemptions bey ond the 2005 phaseout**  **for methy l bromide. Therefore, this worksheet cannot be claimed as CBI.** 

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.
**Potential Alternative Pounds of Methy**  **l Bromide Requested**  **Volume Treated with Methy**  **l Bromide Crop:**  OMB Control # 2060-0482, Expires 10/31/2011



# Worksheet 6. A **pplication Summary**

**Consortium Name: Location:** 

**Reasons**

EPA Form # 4900-137 Post Harvest

### Fumigation cycle: The period of time between methyl bromide fumigations.

**Year:** If a fumigation cycle overlaps more than one calendar year, "year" refers to the calendar year when methyl bromide is applied (or the beginning of the cycle). **Comparable data:** In order to compare revenues and costs with and without methyl bromide, data on alternatives for pest control, yields, revenues, and costs must be for the same time interval as the methyl bromide fumigation cycle. If, however, quantitative data, is not available for the entire fumigation cycle, then to be comparable, the quantitative data for the alternatives should cover the same portion of the fumigation cycle as the quantitative data for methyl bromide, and the rest of the cycle should be discussed in the comments sections.
**2-year example:** If a methyl bromide fumigation is made every 2 years, then the 2003 fumigation cycle began in 2003 and would end in 2005. The data should cover the methyl bromide costs and usage for the methyl bromide fumigation made in 2003, and all yields and revenues received and other costs incurred during the 2 year period. To be comparable, the data on alternatives should cover a similar 2 year period beginning at the same time of year when a methyl bromide fumigation would be made. The data should cover all methyl bromide alternatives used, and all yields and revenues received during that 2-year interval. Other pest control and other costs would only need to be provided for that interval if they would change from what they were with methyl bromide. **Other beneficiary example**  If someone other than the applicant benefits from a methyl bromide fumigation, you should comment on these benefits if you do not have quantitative data for the entire fumigation cycle. For example, if a rotational crop in the second year benefits from a methyl bromide fumigation a year earlier, but there is quantitative data only on the first crop, then the data on the alternatives should cover only the first crop, and the benefits of methyl bromide and the additional pesticides that would have to be used on the rotational crop should be discussed in the comments sections. **Crop cycle change example:**  If in a one year interval, methyl bromide is applied, tomatoes are grown and harvested followed by peppers, then the fumigation cycle would be one year including the tomatoes and peppers. If, however, without methyl bromide, it is not possible to follow tomatoes with peppers in the same one year interval, then the alternative data on pesticides, costs, yields, and revenues should just cover tomatoes. The loss of profit from not being able to grow peppers with the alternatives would be part of the loss from not having methyl bromide. **Crop Grouping** The applicant can group simliar crops together if: (i) Crops would experience similar yield and quality losses in the absence of methyl bromide; and (ii) Crops are grown on the same fumigation and cultivation cycle with similar operating costs. For example, nursery crops including various flower or tree species can be aggregated, with average yields per acre and prices. However, if crops are distinctly different in revenues and operating costs, or the cycles, the applicant may want to present yield, price and operating costs for each crop separately and also indicate the proportion of land area allocated to each crop.



# Definitions OMB Control # 2060-0482, Expires 10/31/2011

EPA Form # 4900-137 Post Harvest