 Forwarded by Hodayah Finman/ DC/ USEPA/ US on 09/ 09/ 02 03: 01 PM  Jan Sharp < JSharp@ calstrawberry. org> 09/ 09/ 02 01: 59 PM To: Bill Chism/ DC/ USEPA/ US@ EPA, Bromide Methyl@ EPA cc: Subject: California Strawberry Commission CUE Application for Production S trawberries Attached is the Excel CUE form for production Strawberries in California. It is a large document, so please be patient with the download. A second email will follow with pertinent Narratives and accompanying spreadsheets. Hardy copies are being sent by Courier today as well as a CD with electronic versions of nearly all the Appendices. Similarly, electronic and hard copy are also going directly to Roberta Firoved at CDPR. Any questions, please call or email. Thank you. Jan << CA Strawberry Commission CUE Application. xls>> Janice K. Sharp, Ph. D. Director of Regulatory and Environmental Affairs California Strawberry Commission P. O. Box 269 Watsonville, CA 95077 0269 831 724 1301 ext 149 phone 818 707 7680 fax 818 903 0762 mobile 1,3 Dichloropropene and Chloropicrin Technical Feasibility Efficacy. Telone   ( 1,3 dichloropropene) is used as a nematocide with minimal efficacy against disease and weeds when used alone. Because it is not effective against the entire pest complex in California strawberries, this alone prevents it from being a methyl bromide replacement ( Table 1, Pest Complex, in application). Early efficacy work with Telone alone demonstrated its poorer activity compared to methyl bromide/ chloropicrin standards ( Appendix CC, 91 15 Pink Sheet). And in fact in that study of repeated use over three years, already poor yields dropped with time. The MBTOC 1998 report ( page 51) also indicated it is effective only in combination with other components. The Federal Use Label also shows it is labeled only against nematodes.

Chloropicrin alone has some activity against much of the California Pest Complex. Chloropicrin has good efficacy against Pseudomonas solancearum, Cylindrocladium fungi, Phytophthora, Fusarium, Pyrenochaeta, Pythium, Rhizoctonia, Sclentina, Slcerotium, Verticillium, clubroot organism Plasmodiophora, soil pox Actinomyces ipomoea ( Table 1, Pest Complex, in application). Chloropicrin alone has some control of cut worms, grubs, wireworms, and suppression of weeds if used with tarps ( Appendix G, Metapicrin label.) It has no control over some key weeds, knotweed, clovers, and filaree and limited control over others that MBC does control ( Appendix DD, Fennimore 2002 handout). While used primarily as a fungicide, its control of anthracnose is unknown, and this disease has become an increasingly important problem in California strawberries and is controlled by MBC. Chloropicrin has no reported activity against nematodes. Nematodes may likely become an increasing problem with repeated use of Chloropicrin. MBC has controlled nematodes so well for decades and it is difficult to measure the future impact of this pest when faced with less than adequate control from Chloropicrin.

Combined Efficacy The main drawback of the 1,3 D chloropicrin alternative combination is the lack of control of weeds. Some increased control of weeds has been observed with InLine applications using VIF mulch. However, as in all drip applications, weed control is not observed along the sides of the beds where the drip application did not reach. Application of herbicides is not a simple solution because these side weeds are under the mulch. Removal requires extensive labor to lift the tarp sides, pull the weeds, and replace the tarp along the sides. Use of additional herbicides would simply add to the operational costs as would increased labor to hand weed. Yields When the yield data is analyzed for both shank and drip applications of Telone C35 or InLine, some interesting overall results are observed. When only data from trials where untreated controls had yields of 80% or less of the MBC standard are considered, the overall yields with 1,3 D/ chloropicrin averages 94% of the MBC standard ( Appendix T, 1,3 D Pic tab). When drip and shank applications are separated, drip was better at 97% versus 90% for shank. Analysis of 10 studies comparing MBC with 1,3 D/ chloropicrin applications by Shaw and Larson showed an overall loss of 14.7% compared to MBC. No studies or work is available on repeated use of 1,3 D/ chloropicrin on the same land. Since Shaw and Larson showed steady declines in yields over 3 years of chloropicrin use, and 1,3 D has limited efficacy on the pest complex, one would anticipate steady losses with use of this material. In particular, weed pressure may increase so significantly with repeated use to further contribute to yield loss.

Other problems have been experienced with drip applications of InLine. Phytoptoxicity is seen sometimes if appropriate plant back timings were not used during the study. Soil temperatures are critical to calculating accurate plant back times, the cooler the temperature, the longer the plant back. Damaged to irrigation piping and systems can occur if proper flushing of the system is not done after fumigation. And leaks in an irrigation system can result in pooling of chemical and therefore spotty delivery to the field resulting in variable efficacy throughout the field or phytotoxicity after planting strawberry transplants. And volume delivery of the drip material has been found to be inappropriate for very sandy soils ( no spread through the bed) or resulted in collapsed beds with too much volume, of poor efficacy and spread in heavier soil. In short, use of this drip material requires more specific soil type, moisture, and delivery conditions. All of these problems are still under investigation by researchers, particularly rates in different soils, to find optimal conditions from which growers can then safely trial the material in their own specific circumstances.

Economic Analysis For drip applications, the most economical and safest application technology, there are potential up front costs for ensuring irrigation systems are leak proof and proper valves and safeguards are in place to prevent backflow of materials into water sources. In addition, 1,3 Dichloropropene and chloropicrin are very corrosive substance and if proper care is not taken to clean out systems after application, valves and piping corrode and need replacement. Growers need to replace PVC pipe, which is corroded by 1,3 D and chloropicrin, with non PVC piping such as Oval Hose. The first growers using the technology state that they had minimal up front costs or donations of equipment to upgrade their systems. For the general grower upgrade costs could run thousands of dollars to replace PVC piping and add proper valve and flow equipment. We estimate yearly costs of $ 100 per acre to upgrade and maintain drip systems based on discussions with experienced growers.

The economics associated with soil preparation come into play for 1,3 D/ chloropicrin applications. Soil preparation and soil moisture are more critical than with MBC applications ( Appendix G, Telone C35 and InLine labels). Soil temperature is also more critical. According to label directions, if soil temperatures drop below 40 ° F, the material loses effectiveness on application and requires an even longer plant back period. The normal plant back period is roughly 1 week for every 10 gallons per acre applied ( Appendix G). At best this leaves a plant back period of 21 days compared to the 7 days for MBC. Even so, the Southern grower pulling crop at the beginning of July can fit in Telone C35 or InLine applications.

The Northern growers however will lose revenue from not harvesting the second half of September ($ 1,262 per acre) for rotational growers. There is some savings in not paying harvest costs for two weeks, a total of $ 459 per week ( fresh harvest costs for North divided by 35 weeks harvest), or $ 918 per acre. The nonrotational growers will have to obtain their land sooner, paying one quarter year's rent to prevent the vegetable grower from doing one last vegetable crop. Land rent in the northern region ranges from $ 1800 2400 per acre. One quarter of the average rent, $ 2,100, is $ 525.

Economic analysis was done with best case scenarios. For the Southern grower and the Northern non rotation grower, it was assumed drip application of InLine was the most efficacious and cost effective. In addition, for the Southern grower it is assumed he has just enough time for soil preparation, fumigation, and plant back time of 21 days. For the rotation grower in the North, flat fumigation of Telone C35 is the only option to ensure coverage of the entire field in anticipation of use the next year by vegetable growers. As such, when these costs are added in, the Southern grower still sees a loss of $ 520 per acre a total loss of $ 20,800 for the 40 acre representative user. In the North, the non rotation grower experiences a loss of $ 895 per acre for a total loss of $ 35,800. The rotational grower experiences the greater loss of $ 2,099 per acre to use of the more expensive flat fumigation with Telone C35, and greater yield loss with that treatment. The total loss for the 40 acre representative rotation grower is $ 83,960. On average for the Northern grower, losses would be $ 1,497 per acre, or $ 59,880 for the 40 acre Northern grower. This are minimum possible losses because if plant back time, particularly in the colder north, increases so does loss of revenue by having to take land back earlier.

Regulatory Pressures 1,3 Dichloropropene The Federal Label requires a 100 foot buffer zone for drip applied Telone ( Appendix G). For shank applied Telone, a 100 foot buffer zone is required the first year and a 300 foot buffer zone is required for the next two years on the same ground. In addition, in California, use is limited by township caps, as an additional protection with respect to the classification of 1,3 D as a B2 carcinogen ( Appendix O, P, and S). Recently township caps were doubled in townships where historical Telone use did not reach the maximum allowed under the caps, in general 90,000 lbs per township ( Appendix S). This is, however a temporary increase until the amount of Telone " banked" from previous years is used up, or the registrant convinces the California Department of Pesticide Regulation that permanent increases are justified by reassessing the oncogenic risk.

Township caps originally set by California were 90,250 " adjusted" pounds per township per year ( Appendix P). Adjusted pounds are actual pounds of 1,3 D applied times an application factor. This calculates out to approximately 345 acres in a township can be treated with InLine using VIF mulch. Since a township is approximately 25,000 acres, and many townships in the Northern and Southern strawberry growing regions have over a thousand acres in strawberries in many townships, obviously not all strawberries growers could use Telone products.

DPR recently doubled the township cap in many of the townships where previous use did not equal the maximum amount allowed under the old township cap. In essence, the unused amount was " banked" for future use. This, however, is only a temporary solution until the banked amounts are used up. Meanwhile the 1,3 D registrant is working with DPR to revise regional modeling schemes to determine whether permanent caps should be recalculated based on each regions weather conditions. Such analysis so far is predicted to result in caps close to the current increased caps or between the old and new.

Dr. Tom Trout of USDA has provided an analysis of the impacted acres of strawberries in each county based on the old and new township cap ( Appendix P). His analysis shows at best that Telone products will not be available to 47% of the total strawberry acreage in the state. For the strawberry growing regions, his study projects unavailable acres according to the following table ( based on 2001 acreage):

Region Total Acres Straw Acres Unavailable % of Acres Watsonville 10,759 4,344 40.4% Santa Maria 3,817 1,645 43% Ventura County 7,777 4,228 54% Orange County 2,446 243 10%

Roughly half of the Southern acreage would not be able to use Telone products. And roughly 40% of the Northern acreage would not. Considering it is not economical for the Northern rotation growers, to account for concentration of non rotation acres in the same affected townships, from 40 100% of the 2,500 acres of non rotational growers acres in the Watsonville area could use the material, although they could still suffer losses using it over MBC. Much of the land in the Watsonville area however is not amenable to drip applications because of soil type and hilliness, further reducing use of the material. The 1645 acres in Santa Maria would be available and only 4,228 acres in Ventura. At best then, 8,373 strawberries acres may be able to use the material. This roughly calculates to availability to approximately 30% of strawberry growers at best even under the expanded township caps.

!, 3 D is also classified as a toxic air contaminant in the state of California and will undergo additional scrutiny in future. This classification, in addition to the classification as a B 2 probable carcinogen contributes to an uncertain regulatory future in California.

Chloropicrin The California Department of Pesticide Regulation is re evaluating chloropicrin at this time with anticipated completion of the review in approximately 2 3 years. There are already sensitivities around the use of the material due to its physiological effects ( lacrimation and upper respiratory discomfort) at very low levels in the air. Chloropicrin is also currently listed as a toxic air contaminant in the state, and could be subject to additional regulatory restraints after thorough review by the Scientific Review Panel of the California Air Resources Board. Of greatest concern is what additional regulatory restraints could be in place in 2005 as a result of the DPR re evaluation, particularly increases in required buffer zones, which would limit the products use in the highly urbanized strawberry growing regions ( Appendix S).

Buffer zones for chloropicrin currently vary from county to county and depend upon local conditions such as proximity of a field to sensitive sites ( Appendix X). In most cases if a sensitive site ( occupied buildings, residences, businesses, schools, hospitals etc.) is within 300 feet of a field, a 100 foot or more buffer zone is required depending on the size of the acreage to be fumigated at a given time. These buffer zones are actually larger than buffer zone requirements for methyl bromide applications near most sensitive sites ( 60 feet minimum depending upon application method and acres to be fumigated at a given time.)

Conclusion The combined soil fumigation regime of 1,3 dichloropropene and chloropicrin is questionable as a methyl bromide alternative. It is on the edge economically for some growers and significantly limited by township caps in California, at best limiting it to 33% of the strawberry acreage. The most efficacious application is drip application of InLine, yet its use is limited by various geographical and soil factors. For instance drip applications are difficult on hilly land, of which approximately half of the Watsonville growing region has hills. In addition, if the soil is too sandy, the material does not spread out in the bed giving poor coverage. If the soil is too heavy, again poor coverage results because it cannot move effectively through the heavy soil. Or worse yet, if material is applied too quickly in high volumes, beds can collapse, as they have in some of the experimental trials. Finally, if not properly rinsed, irrigation systems can corrode increasing grower costs for replacements, or phytotoxicity can result if material left in the system reaches transplants.

This combination is also under continual regulatory scrutiny because of acute toxicity and the carcinogenic classification of 1,3 D. While research work continues on improving yield and use potential, 1,3 D/ chloropicrin is not currently an alternative for the majority of strawberry growers.

Growers need 3 4 years of practice with this regime in their own specific field and climate conditions to perfect any potential use of the regime. With the very low margins present in the current strawberry market, growers can only afford to do relatively small acreage at a time to minimize potential losses until they perfect conditions using the alternatives. 1.

2.

3.

4.

Light 80% Medium 20% Heavy County Soil Maps 0 to 2% 51% 2 to 3 % 49% over 3% Appendix E 5.

6. Specialty ( check one)

7. Jan ice K. Sharp, Ph. D. agronomic XX 8. economic XX 9. Daytime phone 10. FAX 11.

List an additional contact person if available. Specialty ( check one)

12. agronomic XX 13. economic 14. 15. FAX 16. Watsonville, CA 95077 jsharp@ calstrawberry. org Crop prefers coastal climate of cool nights, moderate daytime temperatures, little to no freezing, no rain during majority of production season. Grow best on deep, well drained, sandy loam soils. Crop is salt sensitive.

831 724 5973 Contact name Address 831 724 1301 E mail Worksheet 1. Contact and Methyl Bromide Request Information The following information will be used to determine the amount of methyl bromide requested and the contact person for this request. It is important that we know whom to contact in case we need additional information during the review of the application.

Other geographic factors that may affect crop/ commodity yield ( e. g., water table).

California Strawberry Commission California, counties of San Diego, Orange, Ventura, Santa Barbara, San Luis Obispo, Monterey, Santa Cruz, San Benito, and small acreage in the San Jaoquin Valley primarily Fresno County. See Appendices A and B.

Production strawberries. Some rotation to vegetables; broccoli, celery, lettuce, radish, leeks, artichokes, see Appendix C.

Soil Type:

Organic Matter: Soil type Check the box( es) for the soil types and percent organic matter that apply to your area. If a consortium is submitting this application, please indicate the estimated percentage of consortium users in each soil type.

Consortium name 910 K. Street, Suite 325 Location ( Enter the state, region, or county. Provide more detail about the location if relevant to the feasibility of alternatives to methyl bromide.)

Crop/ commodity ( Include all crops/ commodities that benefit from the application of methyl bromide in a fumigation cycle. A fumigation cycle is the period of time between methyl bromide fumigations.)

Climate ( Individual users should enter their climate zone designation by reviewing the U. S. climate zone map. If a consortium is submitting this application, please indicate the estimated percentage of consortium users in each climate zone. This map is located at the end of this workbook or it can be reviewed online at http:// www. usna. usda. gov/ Hardzone/ ushzmap. html). Hardiness zone 9b, minimum temperatures 25 30F, climate heavily influenced by close proximity to ocean. Strawberries do best in areas with daytime temperatures in the 70' s and nighttime temperatures in the 50' s ( Appendix D)

P. O. Box 269 916 443 2793 916 443 3071 For EPA Use Only ID#

Contact name Address Daytime phone E mail Sacramento. CA 95814 jwells@ exponent. com Jim Wells Worksheet 1. Contact and Methyl Bromide Request Information 17. lbs.

17a. acres units 18. Yes XX No 18a.

19.

20.

20a.

OMB Control # 4,500,000 Unit of Area Treated See attached narrative " Pest Complex Narrative", Appendix F, and Table 1, Pest Complex, in this form ( next tab) Year 2006 Quantity ai ( lb.) of Methyl Bromide 4,500,000 Area to be Treated 25,000 If yes, please list year and quantity active ingredient ( ai) of methyl bromide requested in the table below and explain why you need authorization for multiple years.

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

Explain why this user represents the typical user in the consortium. 25,000 For the reasons stated above and in this application, the consortium is requesting the full amount of methyl bromide anticipated to be used in the 2002 production cycle for the years 2006 and 2007. If the two year trend in adoption of alternatives ( 2000 2001) continues, or if economically viable alternatives gain registration, future applications for critical use exemptions will be adjusted accordingly. 25,000 For EPA Use Only ID#

4,500,000 17. Approximately 3% of the strawberry acreage in 2000 and 10% of the acreage in 2001 was treated with alternatives to methyl bromide. If this trend continues, we would expect that alternatives could be employed on approximately 30% of the acreage by 2005, resulting in a need for 3,500,000 pounds in that year. However, for reasons detailed in this application, the sustainability and the economic viability of the current alternative pest control regimes is questionable. Therefore, this application requests the amount of ai the consortium expects to be used for the 2002 production cycle.

See attached narrative " Representative UserDescription", Appendix I.

See attached narrative " Representative UserDescription", Appendix I. How much active ingredient ( ai) of methyl bromide are you requesting for 2005?

If applying as a consortium for many users of methyl bromide, please define a representative user . Define exactly, issues such as size of the operation ( acres treated with methyl bromide for growers, cubic feet for post harvest operations, and square feet for structural applications), whether the representative user owns or rents the land or operation, intensity of methyl bromide use ( treat regularly or only when pest reaches a threshold), pest pressure, etc. Target Pest( s) or Pest Problem( s): ( Be as specific as possible about the species or classes of pests relevant to the feasibility of alternatives.) If a consortium is submitting this application, the data for question 17 and 17a. should be the total for the consortium.

Are you requesting methyl bromide for additional years beyond 2005?

acres acres 2007 In the table below, area is defined as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. How much area will this be applied to? Please list units. Pest Complex Efficacy of Pest Complex Controlled by Methyl Bromide/ Chloropicrin Importance Pest Common Name Scientific Name Rating MBr/ Pic Chloropricrin Metam 1,3 D Nematocides Pic, Metam 1,3 D, Pic 1,3, D, Pic, metam Diseases None None Verticillium Wilt Verticillium dahlia 1 Some control Control Some control Control Control Control Phytophthora root,

crown, and leather rots Phytophthora cactorum,

Phytophthora citricola, Phytophthora parasitica,

Phytophthora megasperma 3 Control Control Some control Control Control Control Red Stele root rot y p fragariae 3 Control Control Some control Control Control Control Anthracnoseolletotrichum accutatum 3 Control Black root rot Pythium sp.,

Cylindrocarpon sp. 5 Control Control Some control Control Control Control Charcoal rot Macrophomina phaseolina 5 Control Control Some control Control Control Control Arthropods Root weevils Otiorhynchus cribicollis, Nemocestes incomptus,

Otiorhynchus sulcatus, Pantomorus cervinus 7 Control Cutworms Agrotis ipsilon,

Athetis mindara 4 Control Some control Some control Some control Some control strawberry rootworm Paria fragariae 7 Control white grubs Hoplia oregona 8 Control Some control Some control Some control Some control garden symphalan Scutigerlla immaculata 9 Control Control Control ground mealy bug Rhizoecus falcifer) 9 Control Nematodes Control Foliar helenchoides fragariae 1 Control Some control Control Some control Control Control Root knot Meloidogyne hapla 1 Control Some control Control Some control Control Control InLine / Shank Weeds Some, with tarp None None Some, with tarp Some, with tarp Common Chickweed Stellaria media 1 Control Some control Control Control Control Control Burning nettle Urtica urens 1 Control Filaree Erodium spp. 3 No Control No Control No control Bluegrass Poa annua 1 control Some control Control Califronia Burclover Medicago spp. 2 No Control No Control No control Common Purslane Portulaca oleracea 1 Control Some control Control Control Control Control Pigweed Amaranthus retoflexus 2 Control Control Control Control Sowthistle Sonchus spp, 2 Control Little mallow Malva parviflora 1 Some control Little control Little Control Knotweed Polygonum aviculare 2 Some control No Control Control Common Grounsel Senecio vulgaris 3 Control Control Control Common Lambsquarters Chenopodium album 3 Control Control Control Control Shepardspurseaspsella bursa pastoris 3 Control Yellow Nutsedge Cyperus esculentus 5 Control Yellow Sweetclover Melilotus indica 2 No Control No Control No control Worksheet Title Instructions specific to each worksheet are located at the top of each sheet.

2 A Methyl Bromide Use for 1997  2000 This worksheet provides data in actual usage for 1997 2000.

2 B Methyl Bromide  Crop/ Commodity Yield and Gross Revenue for 1997

2000 This worksheet provides crop/ commodity yield and gross revenue for 1997 through 2000.

2 C Methyl Bromide  Crop/ Commodity Yield and Gross Revenue for 2001 This data provides historical information on crop/ commodity yield and gross revenue for 2001.

2 D Methyl Bromide Use and Costs for 2001 This worksheet isolates use and cost data for 2001.

2 E Methyl Bromide  Other Operating Costs for 2001 This data is needed to estimate a baseline for operating costs in order to estimate the impact on operating profit and short run economic viability as a result of not using methyl bromide.

2 F Methyl Bromide  Fixed And Overhead Costs for 2001 This data is needed to estimate a baseline for total costs in order to estimate the impact on profitability and long run economic viability as a result of not using methyl bromide.

Purpose of Data: To establish a baseline estimate of crop/ commodity yields, gross revenues, and costs using methyl bromide. Worksheet 2. Methyl Bromide  Historical Use of Methyl Bromide Col A: Formulation of Methyl Bromide Col B, E, H, K: Actual Area Treated Col C, F, I, L: Actual Total lbs. ai of Methyl Bromide Applied Col D, G, J, M: Actual Average lbs. ai Applied per Area A B C D E F G H I J K L M Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area over 95% methyl bromide 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide 16,823 4041595 240 18338 4251831 232 21252 5213472 214 20382 4231204 207 Comments: Data obtained from the California Department of Pesticide Registration Pesticide Use Reporting database,

http:// www. cdpr. ca. gov/ docs/ pur/ purmain. htm Active ingredient reported for use on strawberries statewide NOTE: majority of methyl bromide applied in a given year is done in the fall for the next year's crop Formulation information not available. Major formulations used for strawberries are 67: 33 and 57: 43.

OMB Control # The average application rates in pounds ai of methyl bromide per area are automatically calculated from the previous 2 columns. 2000 Enter the total actual area treated. Note: This number should be the total actual area treated by the individual user or total actual area for the entire consortium, for the year indicated.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Formulation of Methyl Bromide Enter the actual total pounds active ingredient ( ai) of methyl bromide applied. Note: This number should be the total pounds ai applied by the individual user or the entire consortium, for the year indicated.

1997 1998 1999 For EPA Use Only ID#

Worksheet 2 A. Methyl Bromide  Use 1997 2000 Enter the appropriate data in Col B M for each formulation, if known, and/ or the totals and averages for all formulations. If you enter only the total and averages for all formulations in the last row of the table, please describe in the comments section the formulations typically used, or the approximate proportions of the formulations used.

If a consortium is submitting this application, all data should reflect the actual data for the consortium. For EPA Use Only ID#

A C D E F Year Methyl Bromide was Applied Unit of Crop/ Commodity ( pounds fruit) Crop/ Commodity Yield ( Lbs/ acre) Price ( dollar/ pound) Revenue ( per acre) $ 0 1996 ( 1997 crop) 865064400 39908 $ 0.520 $ 20,752 309671298 11256 $ 0.270 $ 3,039 1997 ( 1998 crop) 835527600 38212 $ 0.555 $ 21,208 361753506 14343 $ 0.204 $ 2,926 1998 ( 1999 crop) 924309600 43876 $ 0.614 $ 26,940 416962692 11946 $ 0.312 $ 3,727 1999 ( 2000 crop) 1036602000 41512 $ 0.486 $ 20,175 365125626 11983 $ 0.216 $ 2,588 $ 0 $ 0 $ 0 Total Revenue for 1997 $ 23,791 Total Revenue for 1998 $ 24,134 Total Revenue for 1999 $ 30,667 Total Revenue for 2000 $ 22,763 Average Revenue Per Year $ 25,339 Comments: Data source USDA Agricultural Marketing Service, Federal State Market News, www. ams. usda/ gov/ marketnews. htm Numbers used in Section 18 applications, See also Appendix K, tab " 1997 2000 Revenues"

Total pounds fresh fruit are for season starting January 1 through mid October for each given year ( prices not available after mid October)

Price is a weighted average calculated from daily averages throughout the season from Jan 1 through mid October OMB Control # Worksheet 2 B. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 1997 2000 If a consortium is submitting this application, the data for this table should reflect the actual averages for the consortium.

Enter the average prices received by the users for the year and crop/ commodity indicated ( 1997 2000).

This number is calculated automatically using the values you entered in Cols. D and E. You may override the formula to enter a different revenue. Please explain why the revenue amount is different in the comment section below.

Enter the unit of measurement for each crop/ commodity.

Be sure to enter the year. Use as many rows as needed for each year for all the crops/ commodities in the fumigation cycles from 1997 to 2000. If a fumigation cycle overlaps more than one calendar year, then the year of the fumigation cycle is the year methyl bromide was applied.

Enter all crops/ commodities that benefit from methyl bromide in each fumigation cycle. ( For example, if normally methyl bromide is applied and tomatoes are grown and harvested followed by peppers without an additional treatment of methyl bromide, then both tomatoes and peppers would be part of the same fumigation cycle.) See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.

Enter the number of units of crop/ commodities produced per area.

If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

The purpose of this worksheet is to estimate the gross revenue for 1997  2000 when using methyl bromide. Post harvest and structural users may work with EPA to modify this form to accommodate differences in operations when providing gross revenue data.

Col. A: Year Col. B: Crop/ Commodity Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Revenue Crop/ Commodity Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Average Revenue per Year: The average revenue per year is calculated automatically using the summary data you enter for each year.

Total Revenue for 1997 2000 Enter the total revenue per year by adding the revenue for all crops for that year.

Strawberry fresh Strawberry processed B Strawberry fresh Strawberry processed Strawberry fresh Strawberry processed Strawberry fresh Strawberry processed For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Revenue A B C D E F Crop/ Commodity Price Factors ( time) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( pounds/ acre) Price ( dollar/ pound) Revenue ($/ acre)

Strawberry, Fresh January 13512500 1322 $ 1.290 $ 1,705 Strawberry, Fresh February 25415000 2486 $ 1.109 $ 2,757 Strawberry, Fresh March 53072500 5191 $ 0.912 $ 4,735 Strawberry, Fresh April 129872950 12704 $ 0.666 $ 8,461 Strawberry, Fresh May 83725750 8190 $ 0.363 $ 2,973 Strawberry, Fresh June 4169900 408 $ 0.494 $ 201 Subtotal, lbs/ acre 30301 Subtotal $ 20,832 Strawberry, Processed April 2960262 290 $ 0.306 $ 89 Strawberry, Processed May 76302774 7464 $ 0.306 $ 2,284 Strawberry, Processed June 92174400 9016 $ 0.306 $ 2,759 Strawberry, Processed July 11687598 1143 $ 0.306 $ 350 Strawberry, Processed August 351558 34 $ 0.306 $ 11 Subtotal, lbs/ acre 17947 Subtotal $ 5,492 Total Yield, lbs/ acre 48249 Total Revenue $ 26,324 Comments: Because of market changes, prices are weighted monthly averages, See Appendix K, " Monthly Prices" tab Data source USDA Agricultural Marketing Service, Federal State Market News, www. ams. usda/ gov/ marketnews. htm Total pounds fresh fruit are for season starting January 1 through mid October for each given year ( prices not available after mid October Total acres for Southern region 10,223 Market for 2001 broken into South ( San Diego, Orange, and Ventura Counties) region because of harvest schedule Note ratio of Fresh to Processed is 63% to 37%

OMB Control #

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Enter average 2001 prices received by the users for that crop/ commodity and price factor.

Revenue is automatically calculated using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this revenue amount is different in t Enter factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality,

grade, market ( e. g. fresh or processing), timing of harvest, etc., you may itemize by using more than one ro Enter the unit of measurement for each crop/ commodity.

Enter the number of units of crop/ commodity produced per area for that price factor.

The purpose of this worksheet is to estimate the gross revenue for 2001when using methyl bromide. Post harvest users may modify this form to accommodate differences when providing gross revenue data. If 2001 was not a typical year for the individual or f Enter all crops/ commodities that benefit from methyl bromide in the fumigation cycle ( interval between fumigations) beginning with the treatment of methyl bromide in 2001. If multiple crops are grown during the interval between fumigations ( e. g. tomatoes If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Col. A: Crop/ Commodity Worksheet 2 C South. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 2001 For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Revenue A B C D E F Crop/ Commodity Price Factors ( time) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( pounds/ acre) Price ( dollar/ pound) Revenue ($/ acre)

Strawberry, Fresh February 135700 9 $ 1.109 $ 10 Strawberry, Fresh March 2010200 138 $ 0.778 $ 107 Strawberry, Fresh April 31156950 2138 $ 0.551 $ 1,178 Strawberry, Fresh May 164310850 11273 $ 0.413 $ 4,656 Strawberry, Fresh June 156811700 10758 $ 0.525 $ 5,648 Strawberry, Fresh July 110612750 7589 $ 0.596 $ 4,523 Strawberry, Fresh August 81290050 5577 $ 0.790 $ 4,406 Strawberry, Fresh September 49579260 3401 $ 0.683 $ 2,323 Strawberry, Fresh October 34718500 2382 $ 0.737 $ 1,755 Strawberry, Fresh November 4052600 278 $ 0.648 $ 180 Subtotal, lbs/ acre non rotation 40883 Subtotal $ 22,851 Subtotal, lbs/ acre rotation 43533 Subtotal $ 24,787 Strawberry, Processed April 2470104 169 $ 0.306 $ 52 Strawberry, Processed May 18981198 1302 $ 0.306 $ 398 Strawberry, Processed June 53232084 3652 $ 0.306 $ 1,118 Strawberry, Processed July 21421638 1470 $ 0.306 $ 450 Strawberry, Processed August 14161176 972 $ 0.306 $ 297 Strawberry, Processed September 9603846 659 $ 0.306 $ 202 Strawberry, Processed October 3563802 244 $ 0.306 $ 75 Strawberry, Processed November 1726146 118 $ 0.306 $ 36 Subtotal, lbs/ acre non rotation 8224 Subtotal $ 2,516 Subtotal, lbs/ acre rotation 8587 Subtotal $ 2,628 Total Yield, lbs/ acre non rotation 49107 Total Revenue non rotation $ 25,367 Total Yield, lbs/ acre rotation 52120 Total Revenue rotation $ 27,414 Comments: Because of market changes, prices are weighted monthly averages, See Appendix K, " Monthly Prices" tab October/ November revenues removed for ground prep and fume for coming year for Non Rotation grower Data source USDA Agricultural Marketing Service, Federal State Market News, www. ams. usda/ gov/ marketnews. htm Total pounds fresh fruit are for season starting January 1 through mid October for each given year ( prices not available after mid October)

Total acres for Northern Region are 14576 Market for 2001 broken into South ( Santa Barbara, San Luis Obisbo, Santa Cruz, and Montery Counties) region because of harvest schedule Note ratio of Fresh to Processed is 84% to 16%

OMB Control #

The purpose of this worksheet is to estimate the gross revenue for 2001when using methyl bromide. Post harvest users may modify this form to accommodate differences when providing gross revenue data. If 2001 was not a typical year for the individual or f Enter all crops/ commodities that benefit from methyl bromide in the fumigation cycle ( interval between fumigations) beginning with the treatment of methyl bromide in 2001. If multiple crops are grown during the interval between fumigations ( e. g. tomatoes If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Col. A: Crop/ Commodity Worksheet 2 C North. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Enter average 2001 prices received by the users for that crop/ commodity and price factor.

Revenue is automatically calculated using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this revenue amount is different in t Enter factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality,

grade, market ( e. g. fresh or processing), timing of harvest, etc., you may itemize by using more than one ro Enter the unit of measurement for each crop/ commodity.

Enter the number of units of crop/ commodity produced per area for that price factor. Col. A: Formulation of Methyl Bromide Col B: Average lbs. active ingredient ( ai) of Methyl Bromide Applied per Area Cols. C, D, E, G: Prices and Costs Col. F: Actual Area Treated A B C D E F G Formulation of Methyl Bromide Lb. ai of Methyl Bromide Applied per Area ( 2001 Average) Price per lb. ai of Methyl Bromide ( 2001 Average) Cost of Applying Pesticide per Area ( 2001 Average) Other MBr Costs ( e. g. tarps,

etc.) per Area ( 2001 Average) Total Actual Area Treated in the Consortium Cost per Area over 95% methyl bromide $ 0.00 75% methyl bromide, 25% chloropicrin $ 0.00 67% methyl bromide, 33% chloropicrin $ 0.00 50% methyl bromide, 50% chloropicrin $ 0.00 __% methyl bromide, __% chloropicrin $ 0.00 __% methyl bromide, __% chloropicrin $ 0.00 $ 0.00 Total South Region, custom application $ 1,778.00 10223 $ 1,778.00 Comments: Data from University of California Cooperative Extension, " 2001 Sample Costs to Produce Strawberries,

South Coast Region  Ventura County", http:// coststudies. ucdavis. edu See Appendix L OMB Control # For EPA Use Only ID#

If 2001 was not a typical year for the individual or for the representative user of a consortium, the applicant may provide additional data for a different year. However, all applicants must complete this worksheet for the year 2001 regardless. If you pr If the methyl bromide is custom applied then put the cost per area in Column G and fill in the average lb ai of methyl bromide applied per area ( Col B) and the Total Actual Area Treated ( Col F).

Worksheet 2 D South. Methyl Bromide  Use and Costs for 2001 If a consortium is submitting this application, the data in Cols. B, C, D, and E should reflect the representative user in the consortium. The data in Col. F should reflect the actual area treated by all users in the consortium.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Enter the appropriate data in Col B G for each formulation, if known, and/ or the totals and averages for all formulations of methyl bromide. If you just enter data in the bottom row in the table ( All formulations of methyl bromide), please describe in th Enter the average pounds active ingredient ( ai) of methyl bromide applied per area.

Enter the average price per pound active ingredient ( ai) of methyl bromide in Col. C and the average cost of applying methyl bromide per area treated in Col. D. In Col. E, enter the average other costs per area associated with applying methyl bromide ( e. g Enter the actual area treated. Note: This number should be the total area treated by all users in the consortium. Col. A: Formulation of Methyl Bromide Col B: Average lbs. active ingredient ( ai) of Methyl Bromide Applied per Area Cols. C, D, E, G: Prices and Costs Col. F: Actual Area Treated A B C D E F G Formulation of Methyl Bromide Lb. ai of Methyl Bromide Applied per Area ( 2001 Average) Price per lb. ai of Methyl Bromide ( 2001 Average) Cost of Applying Pesticide per Area ( 2001 Average) Other MBr Costs ( e. g. tarps,

etc.) per Area ( 2001 Average) Total Actual Area Treated in the Consortium Cost per Area over 95% methyl bromide $ 0.00 75% methyl bromide, 25% chloropicrin $ 0.00 67% methyl bromide, 33% chloropicrin $ 0.00 50% methyl bromide, 50% chloropicrin $ 0.00 __% methyl bromide, __% chloropicrin $ 0.00 __% methyl bromide, __% chloropicrin $ 0.00 $ 0.00 Total North Region, custom application $ 1,728.00 14920 $ 1,728.00 Comments: Data from University of California Cooperative Extension, " 2001 Sample Costs to Produce Strawberries,

Central Coast , http:// coststudies. ucdavis. edu Fumigation costs ( flat fume) in Monterey/ Santa Cruz, $ 1,728/ acre from Cost of Production, Central Coast Region See Appendix L OMB Control #

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Enter the appropriate data in Col B G for each formulation, if known, and/ or the totals and averages for all formulations of methyl bromide. If you just enter data in the bottom row in the table ( All formulations of methyl bromide), please describe in th Enter the average pounds active ingredient ( ai) of methyl bromide applied per area.

Enter the average price per pound active ingredient ( ai) of methyl bromide in Col. C and the average cost of applying methyl bromide per area treated in Col. D. In Col. E, enter the average other costs per area associated with applying methyl bromide ( e. g Enter the actual area treated. Note: This number should be the total area treated by all users in the consortium.

For EPA Use Only ID#

If 2001 was not a typical year for the individual or for the representative user of a consortium, the applicant may provide additional data for a different year. However, all applicants must complete this worksheet for the year 2001 regardless. If you pr If the methyl bromide is custom applied then put the cost per area in Column G and fill in the average lb ai of methyl bromide applied per area ( Col B) and the Total Actual Area Treated ( Col F).

Worksheet 2 D North. Methyl Bromide  Use and Costs for 2001 If a consortium is submitting this application, the data in Cols. B, C, D, and E should reflect the representative user in the consortium. The data in Col. F should reflect the actual area treated by all users in the consortium. For EPA Use Only ID#

Col A: Operation Col B: Custom Operation Cost Col C: Material Cost per Area Col D: Labor Cost per Area Col E: Total Cost per Area Col F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area Typical Equipment Used Ground Preparation $ 627.00 $ 0.00 Post Fumigation Preparation $ 1,454.00 $ 0.00 Planting $ 2,356.00 $ 0.00 Pesticides $ 1,253.00 $ 0.00 Fresh Harvest $ 12,850.00 $ 0.00 Processed Harvest $ 3,537.00 $ 0.00 Weeding $ 713.00 $ 0.00 Field clearing $ 298.00 $ 0.00 Assessment $ 131.00 $ 0.00 Interest on Capital $ 1,204.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Custom per Area $ 24,423.00 User Total per area $ 0.00 Data from University of California Cooperative Extension, " 2001 Sample Costs to Produce Strawberries,

South Coast Region  Ventura County", http:// coststudies. ucdavis. edu See next page and Appendix L OMB Control # Operation Done by User Worksheet 2 E South. Methyl Bromide  Other Operating Costs for 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Custom Operation Cost per Area Operation If a consortium is submitting this application, the data for this table should reflect a representative user.

Do not include methyl bromide costs.

Identify the typical equipment used for operations done by user. Please be specific, such as tractor horsepower. No cost data is required in this column.

If you do not incur custom operation costs, enter the material cost per area.

The total cost per area is calculated automatically from the values you enter in Cols. C and D.

If you do not incur custom operation costs, enter the labor cost per area.

Enter all operating costs except methyl bromide costs incurred during the fumigation cycle ( interval between fumigations) beginning in 2001. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. Enter these costs in Col B for custom operations, or in Col C and D for operations done by user.

Identify in Col A the operations ( except methyl bromide) to which the costs apply. For growers, these operations should include but are not limited to ( 1) prepare soil, ( 2) fertilize, ( 3) irrigate, ( 4) plant, ( 5) harvest, ( 6) other pest controls, etc. You must include all other operating costs.

If you incur custom operation costs, enter those costs in Col. B.

Submit crop budgets for each crop, if available. You may submit crop budgets electronically or in hard copy. If your costs are significantly different than the crop budgets,

please explain in the comments. Cost of Production Operations Breakdown Ventura County 2001 Operation Detail Elements Individual Costs ($/ acre) Total for Operation Ground Preparation 400 627 227 Post Fumigation Preparation List Bed 4 1454 Shape Beds 2X 6 Fertilize 18 6 8 364 Install Drip Tape 2 line/ bed 274 369 44 Lay Laterals/ Connect Drip 110 Irrigate Drip 270 Punch Holes 13 Planting Plant 2352 2356 Roll Plants 4 Pesticides Disease Mildew 49 1253 Disease Botrytis/ Mildew 90 Insect Predatory Mite 2X 323 285 Disease Botrytis/ Mildew 98 Disease Botrytis/ Mildew 73 Disease Botrytis/ Mildew 1X 93 Disease Botrytis/ Mildew 2X 124 Inssects Cutworms 31 87 Fresh Harvest Harvest/ Record Fresh 12573 12850 Haul/ Load Fresh 277 Processed Harvest Harvest Freezer/ Haul/ Record 3537 3537 Weed Hand Weed Hand 713 713 Field Clearing Cut Mulch Prior to Harvest 146 298 152 Assessment 131 131 Interest on Operating Capital Interest @ 10.51% 1204 1204 Cash Overhead ( Not Included) 3050 NonCash Overhead ( Not Included) 455 Disease/ Insect Botrytis/ Mildew/ Worms Remove/ Haul/ Dump Plastic/ Tape Land prep: Disc, Plow, Subsoil, Level Irrigate Sprinkler/ Layout, Pickup Pipe Lay Mulch Cut/ Grade Roads/ Maintain Roads Disease/ Insect Botrytis/ Mildew/ Mite For EPA Use Only ID#

Col A: Operation Col B: Custom Operation Cost Col C: Material Cost per Area Col D: Labor Cost per Area Col E: Total Cost per Area Col F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area Typical Equipment Used $ 0.00 Ground Preparation $ 263.00 $ 0.00 Post Fumigation Preparation $ 1,348.00 $ 0.00 Planting $ 1,707.00 $ 0.00 Pesticides $ 1,153.00 $ 0.00 Fresh Harvest $ 16,077.00 $ 0.00 Processed Harvest $ 1,044.00 $ 0.00 Weeding $ 893.00 $ 0.00 Field clearing $ 105.00 $ 0.00 Assessment $ 133.00 $ 0.00 Interest on Capital $ 1,250.00 $ 0.00 $ 0.00 Total Custom per Area $ 23,973.00 User Total per area $ 0.00 Weighted average of Santa Maria and Watsonville areas representative of Northern region Data from University of California Cooperative Extension, " 2001 Sample Costs to Produce Strawberries,

Central Coast , http:// coststudies. ucdavis. edu See next page and Appendix L OMB Control # Operation Done by User Worksheet 2 E North. Methyl Bromide  Other Operating Costs for 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Custom Operation Cost per Area Operation If a consortium is submitting this application, the data for this table should reflect a representative user.

Do not include methyl bromide costs.

Identify the typical equipment used for operations done by user. Please be specific, such as tractor horsepower. No cost data is required in this column.

If you do not incur custom operation costs, enter the material cost per area.

The total cost per area is calculated automatically from the values you enter in Cols. C and D.

If you do not incur custom operation costs, enter the labor cost per area.

Enter all operating costs except methyl bromide costs incurred during the fumigation cycle ( interval between fumigations) beginning in 2001. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. Enter these costs in Co Identify in Col A the operations ( except methyl bromide) to which the costs apply. For growers, these operations should include but are not limited to ( 1) prepare soil, ( 2) fertilize, ( 3) irrigate, ( 4) plant, ( 5) harvest, ( 6) other pest controls, etc. Y If you incur custom operation costs, enter those costs in Col. B.

Submit crop budgets for each crop, if available. You may submit crop budgets electronically or in hard copy. If your costs are significantly different than the crop budgets,

please explain in the comments. For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Cost Item Description Allocation Method Cost per Area Cash and Non cash Overhead $ 5,070.00 Total $ 5,070.00 Comments: Data from University of California Cooperative Extension, " 2001 Sample Costs to Produce Strawberries,

Central Coast , http:// coststudies. ucdavis. edu See next page and Appendix L OMB Control # Worksheet 2 F North. Methyl Bromide Fixed and Overhead Costs in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated.

Enter all fixed and overhead costs incurred during the fumigation cycle ( interval between fumigations) beginning in 2001. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Cost Item Description Allocation Method Cost per Area Cash Overhead $ 3,050.00 Non cash overhead $ 455.00 Total $ 3,505.00 Comments: Data from University of California Cooperative Extension, " 2001 Sample Costs to Produce Strawberries,

South Coast Region  Ventura County", http:// coststudies. ucdavis. edu See next page and Appendix L OMB Control # Worksheet 2 F South. Methyl Bromide Fixed and Overhead Costs in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated.

Enter all fixed and overhead costs incurred during the fumigation cycle ( interval between fumigations) beginning in 2001. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. Cost of Production Operations Breakdown Central Coast 2001 ( Northern Growers) Santa Maria Monterey/ Santa Cruz ( 26.2% SM + 73.8% M/ SC)

Operation Detail Elements Costs ($/ acre) Costs ($/ ac Total for Operation Ground Preparation $ 263 152 Fertilize 469 Land Prep: Disc, Subsoil, Chisel, Level 136 Post Fumigation Preparation Install Drip Tape 2 line/ bed $ 1,348 List/ Shape 52" beds 9 Shape Beds 2X Fertilize preplant 230 Install Drip Tape 2 line/ bed 275 277 412 55 Lay Laterals/ Connect Drip 110 7 Irrigate Drip 421 338 Irrigate Sprinkle/ Layout/ Pickup Pipe 279 131 Punch Holes 13 13 Planting Plant 1994 1601 $ 1,707 Roll Plants 4 Pesticides Worms 25 $ 1,154 Botrytis 55 Insect Predatory Mite 2X 367 Botrytis/ Mildew 45 84 Botrytis/ Mildew 67 Mildew/ Mite 143 100 Mildew/ Mite 125 Botrytis/ Mildew/ Mite 138 59 Botrytis/ Mildew/ Lygus 46 97 35 37 Botrytis/ Mildew/ Worm 363 Botrytis/ Lygus 71 Botrytis/ Mite 136 Botrytis/ Mite/ Worm 195 Botrytis/ Mite/ Worm/ Lygus 49 Fresh Harvest Harvest/ Record Fresh 9398 17903 $ 16,077 Haul/ Load Fresh 215 469 Processed Harvest Harvest/ Record Freezer 3799 $ 1,044 Haul/ Load Freezer 186 Weed Hand Weed Hand 713 957 $ 893 Field Clearing Yearend Plastic Retrieval/ Landfill 108 102 $ 104 Assessment 118 138 $ 133 Interest on Operating Capital Interest @ 10.51% 911 1370 $ 1,250 Cash Overhead ( Not Included) 2,014 1937 $ 1,957 NonCash Overhead ( Not Included) 429 4065 $ 3,112 OMB Control # Land prep: Disc/ Roll, Subsoil, Plow, Level/

Smooth Field, List/ Shape Beds, Fertilize Lay Mulch Cut/ Grade Roads/ Maintain Roads Mildew/ Mite/ Lygus For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Reprentative Use Total Operating Costs Total Revenues Net Revenues Southern Region ( w/ o overhead) $ 26,201 $ 26,324 $ 122.98 Northern Region ( w/ o overhead)

Non rotation $ 25,701 $ 25,367 $ 333.57 Rotation $ 25,701 $ 27,414 $ 1,713.10 Total Revenues for South $ 122.98 Total Revenues for North $ 689.77 Comments: Overhead cost for both North and South put both representative users in the red unless they bed fume Overhead costs not included at this time as best case scenario OMB Control # Worksheet 2 G. Methyl Bromide Total Costs and Revenues in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated. Worksheet Title 3 A Alternatives  Technical Feasibility This form is used to obtain information on the chemical alternatives identified by the Methyl Bromide Technical Options Committee ( MBTOC) that are registered for use in the United States, as well as the non chemical alternatives identified by the MBTOC. Applicants must address the technical feasibility of all the chemical and non chemical alternatives identified on the list.

3 B Alternatives  Pest Control Regimen Costs This form is used to estimate the cost of using alternative pest control regimens.

3 C Alternatives  Crop/

Commodity Yield and Gross Revenue This form is used to estimate the crop/ commodity yields and gross revenues when using alternative pest control regimens.

3 D Alternatives  Changes in Other Costs This form is used to estimate change in any other costs as a result of using the alternatives.

Complete each of the worksheets below ( 3 A, 3 B, 3 C, and 3 D) for each alternative pest control regimen listed in the " U. S. Matrix" for chemical controls ( www. epa. gov/ ozone/ mbr/ cueqa. html) and the " International Matrix" for non chemical pest controls ( www. epa. gov/ ozone/ mbr/ cue). Each worksheet contains a place holder in the title for you to insert the name of the specific alternative pest control regimen addressed. You should add additional worksheets as required. Please add a number designation to each worksheet title to indicate a different alternative. For example, for the first alternative pest control regimen label the worksheets as 3 A( 1), 3 B( 1), 3 C( 1), and 3 D( 1). For the second alternative pest control regimen label the worksheets 3 A( 2), 3 B( 2), 3 C( 2), and 3( D)( 2).

Purpose of Data on Alternative Pest Control Regimens: To estimate the loss as a result of not having methyl bromide available. EPA needs to compare data ( yields, crop/ commodity prices, gross revenues and costs) on the use of methyl bromide and alternative pest control regimens.

Worksheet 3. Alternatives  Feasibility of Alternative Pest Control Regimens 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 fumigation cycle worksheet for a comprehensive definition. Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) XXX For EPA Use Only ID#

Worksheet 3 A. Nematocide Technical Feasibility wrt Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

Nematocides In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet Enzone and fozthiazate, the nematocides mentioned in 2001 TEAP report are not registered in US.

Avermectin, also from the 2001 TEAP report, is not registered in California for use on nematodes ( http:// www. cdpr. ca. gov/ docs/ label/ labelque. htm# regprods)

See Nematocide Narrative, Appendix M Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # For EPA Use Only ID#

See Nematocide Narrative, Appendix M Fosthiazate is only active against nematodes and does not impact soil borne disease or weeds Nematocides do not encompass the entire pest complex of strawberries in California Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. See Nematocide Narrative, Appendix M Worksheet 3 A. Nematocide Technical Feasibility wrt Methyl Bromide Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Nematocide Narrative, Appendix M OMB Control #

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after Worksheet 3 A 2. Alternatives  Nematocide Technical Feasibility with Respect to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

Nematocides [ Insert Study Title] Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps XXX Caps impact from 11,000  18,000 acres 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) XXX See Appendix N, " 1,3 Dichloropropene Narrative"

Local restrictions near sensitive sites and buffer zone requirements See Telone II use Label, Appendix G, http:// www. cdpr. ca. gov/ docs/ dprdocs/ methbrom/ telone/ mgmtplan. pdf,

Appendix O, http:// www. cdpr. ca. gov/ docs/ enfcmpli/ penfltrs/ penf2001/ 2001040. pdf Appendix P, Impact of Township Caps on California Strawberry Production For EPA Use Only ID#

Worksheet 3 A. 1,3 Dichloropropene Technical Feasibility wrt Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

1,3 Dichloropropene In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # For EPA Use Only ID#

See Appendix N, " 1,3 Dichloropropene Narrative" Work being done is in combination with other materials imited activity and others have seen rapid loss of activity in some instances.

Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Primarily effective against nematodes. MBTOC report states used alone has Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. See Appendix N, " 1,3 Dichloropropene Narrative" Worksheet 3 A. 1,3 Dichloropropene Technical Feasibility wrt Methyl Bromide Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Appendix N, " 1,3 Dichloropropene Narrative"

OMB Control #

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after Worksheet 3 A 1. Alternatives  1,3 D Technical Feasibility with Respect to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

1,3 Dichloropropene [ Insert Study Title] Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) XXX See Appendix Q, " Metam Sodium Narrative" Metam Sodium is classified as a toxic air contaminant by the California Department of Pesticide Regulation and is currently undergoing re evaluation. Current buffer zone permit requirements Appendix R, http:// www. cdpr. ca. gov/ docs/ empm/ pubs/ mitc/ augfinl02/ augdirdeter. pdf For EPA Use Only ID#

Worksheet 3 A. Metam Sodium Technical Feasibility wrt Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

Metam Sodium In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet are in danger of becoming impractical ( 500 feet possibly) which would severely limit its usability Appendix S, http:// www. cdpr. ca. gov/ docs/ dprdocs/ methbrom/ mb_ main. htm Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No XXX 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # For EPA Use Only ID#

See Appendix Q, " Metam Sodium Narrative" Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Metam sodium CUE Narrative Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. See Appendix Q, " Metam Sodium Narrative" Worksheet 3 A. Metam Sodium Technical Feasibility wrt Methyl Bromide Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments:

OMB Control # For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after Metam Sodium [ Insert Study Title]

Provide one summary table for each study being described.

Research Summary Table See Appendix Q, " Metam Sodium Narrative"

See Appendix T, " Alt Sum Yield Data. xls", tab Metam Worksheet 3 A. Alternatives  Metam Sodium Technical Feasibility with Respect to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area) Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J, M: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Gallons of product per Acre per Application Product Unit ( e. g., lbs.,

gals) $ 0.00 $ 0.00 Metam Sodium Drip Application 50 gals $ 698.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total Comments:

If you do not have the quantitative data for additional crops grown on the same land, please indicate so in the comment section.

See Appendix U, " mebr_ alts_ prices. xls"

See Appendix V, " Vegetable Rotation Narrative"

OMB Control # For EPA Use Only ID#

Use one row for each active ingredient ( ai). For example, if a product contains 2 ai's use 2 rows for that product. Once a row is completed for a given product, then only Col.

B ( if applicable), C, and E need to be completed for additional rows regardin Enter the number of applications in a fumigation cycle comparable to methyl bromide for this alternative pest control regimen. Since this number is an average, it does not need to be a whole number.

Enter the formulation or the % of active ingredient. Cost per Area ( 2001$)

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Name of Product Price per Unit of the Product Cost of Applying Pesticide per Area Other Costs per Application Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: Metam Sodium Enter the area receiving at least one application of the pesticide.

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

Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. If multiple crops are grown Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product.

Col. A: Name of Product and Non chemical Control If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

As a cross check, EPA is requesting both the amount of active ingredient in Col. E and product applied per area in Col. F. Indicate the unit of the product in Col. G.

Use 2001 prices and costs. If the product is custom applied you may enter the total cost in the last column ( Col. M) and override the formula. If a pesticide is applied by the user, enter the price of the product in Col. H and the cost of applying it in Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Gross Revenue A B C D E F Crop/ Commodity Price Factors ( grade, time, market) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( lbs per acre) Price ( per unit of crop/ commodity) Revenue ( per area) $ 0.00 $ 0.00 South $ 0.00 Strawberries Fresh and Processed Total yield per acre 39,081 $ 0.00 Fresh 63% 24,621 $ 0.695 $ 17,111.77 Processed 37% 14,460 $ 0.306 $ 4,424.79 $ 0.00 North $ 0.00 Strawberries Fresh and Processed $ 0.00 Rotation 42,217 Fresh 84% 35,463 $ 0.576 $ 20,426.42 Processed 16% 6,755 $ 0.306 $ 2,066.96 Non Rotation 39,776 Fresh 84% 33,412 $ 0.576 $ 19,245.38 Processed 16% 6,364 $ 0.306 $ 1,947.45 $ 0.00 $ 0.00 Total Revenue South $ 21,536.56 Total Rev Rot North $ 22,493.38 Total Rev Non Rot Nor $ 21,192.83 Comments: Weighted average yearly price for fresh berries is $ 0.695 South and $ 0.576 based on calculations used for Section 18 applications, Appendix K Percentage of fresh vs processed based on 2001 baseline, Worksheets 2 CS and 2 CN, 63: 37 and 84: 16 respectively Crop/ Commodity Yield calculated from the average percent yield from California strawberry trials of 81% of MBC Standard, Appendix T, Metam tab Note ratio in South of Fresh to Processed is 63% to 37%

Note ratio in North of Fresh to Processed is 84% to 16%

OMB Control # Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternati Metam Sodium If a consortium is submitting this application, the data for this table should reflect a representative user.

In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this Enter the unit of measurement for your crop/ commodity.

Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please discuss changes in crop cycles resulting from alternative use in the comments. See the Fumigation Cycle Worksheet f Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality, grade, market ( e. g., fresh or processing), timing of harvest, etc., you may itemize by using m Enter the number of units of crop/ commodity produced per area for that price factor identified.

Enter the average 2001 prices received by the users for that crop/ commodity and price factor.

The purpose of this worksheet is to identify the gross revenue for units ( crop, commodity, structure) when using an alternative compared to gross revenue when using methyl bromide.

Postharvest and structural users may modify this form to accommodate diff Col. A: Crop/ Commodity If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. For EPA Use Only ID#

Col. A: Operation or Cost Item Col. B: Custom Operation Cost Col. C, D, E: Costs per Area Col. F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area $ 0.00 $ 0.00 Custom Fumigation $ 698 $ 0.00 $ 0.00 Lost revenue for early crop pull S $ 11 $ 0.00 $ 0.00 Lost revenue for early crop pull N $ 1,262 $ 0.00 $ 0.00 Additional rent for rotation North 525 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 South Total Rotation per Area $ 708.52 User Total per area $ 0.00 North Total Non Rotation per Area $ 1,960.40 North Total Rotation per Area $ 1,223.00 Comments: Custom fumigation cost, Apprendix U Lost crop revenue for the North based on loss of two weeks of September income See Appendix Q, " Metam Sodium Narrative"

OMB Control #

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Enter in Col. C and D, material and labor costs per area that change for operations done by user. The total cost per area is calculated automatically from the values you enter in Cols. C and D. Typical Equipment Used Operation Done by User Metam Sodium Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative:

Custom Operation Cost per Area Operation or Cost Item Enter data only for costs ( other than the cost of alternative pest control) that change as a result of using the alternatives instead of methyl bromide. Enter the whole cost, not just the incremental changes. Enter the cost in Col. B for custom operatio Identify changes in the typical equipment used by the user as a result of not using methyl bromide. Please be specific such as tractor horsepower. No cost data are required in this column.

Identify the operations or cost items that change as a result of not using methyl bromide.

Enter custom operation costs that change in Col. B. For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Reprentative Use Total Operating Costs Total Revenues Net Revenues Southern Region ( w/ o overhead) $ 25,132 $ 21,537 $ 3,594.97 Northern Region ( w/ o overhead) Rotation $ 25,196 $ 22,493 $ 2,702.62 Non Rotation $ 25,933 $ 21,193 $ 4,740.57 Total Revenues for South $ 3,594.97 Total Revenues for North Rotation $ 2,702.62 Comments: Total Revenues for North Non Rotation $ 4,740.57 Overhead costs not included at this time as best case scenario See Appendix Q, " Metam Sodium Narrative"

OMB Control # Worksheet 3 E. Metam Sodium Total Costs and Revenues in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated. Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) xxxx Efficacious amount of 200 lbs/ acre or more not allowed or discouraged by County Ag Commissioners ( Personal Communication, Ag Commissioners in Orange, Ventura, Santa Barbara, Santa Cruz, and Monterey Counties)

See Appendix W, " Chloropicrin Narrative" For EPA Use Only ID#

Worksheet 3 A. Chloropicrin Technical Feasibility to Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

Chloropicrin In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # For EPA Use Only ID#

See Appendix W, " Chloropicrin Narrative" Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. See Appendix W, " Chloropicrin Narrative" Worksheet 3 A. Chloropicrin Technical Feasibility to Methyl Bromide Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Appendix W, " Chloropicrin Narrative"

See Appendix T, " Alt Sum Yield Data. xls"

OMB Control # Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

Chloropicrin [ Insert Study Title]

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode for pest 1 in the Col F header below and stunt nematode for pest 2 in the Col. L header below. In the comments section describe the rating system used ( 0 to 100 scale where 0 is no control, number of nematodes per gram of soil, number of colony forming units per gram of soil,

etc.).

Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study should directly compare methyl bromide and the alternative regimen.

List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after treatment, and 6 weeks after treatment. In this example, type over the words " Rating Interval 1" with " pre treatment", type over " Rating Interval 2" with " 3 weeks", and type over " Rating Interval 3" with " 6 weeks." If you are completing the printed version, please define Rating Interval in the comments below. Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J, M: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Units of product per Area per Application Product Unit ( e. g., lbs.,

gals) $ 0.00 $ 0.00 $ 0.00 Chloropicrin EC, drip application 24 gallons $ 1,455.00 Chloropicrin, shank flat application 200 lbs $ 1,208.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total $ 2,663.00 Comments:

If you do not have the quantitative data for additional crops grown on the same land, please indicate so in the comment section.

See Appendix U, " mebr_ alts_ prices. xls"

See Appendix V, " Vegetable Rotation Narrative"

OMB Control # Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied. Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: Chlorpicrin Enter the area receiving at least one application of the pesticide.

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

Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. If multiple crops are grown during the interval between fumigations ( e. g. tomatoes followed by peppers in a single growing season, or strawberries followed by lettuce over 2 or 3 years) include all of the pesticides that replace methyl bromide for the entire interval. Do not include pesticides that are used along with methyl bromide enter only the additional pest control if methyl bromide were not available.

Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product.

Col. A: Name of Product and Non chemical Control If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

As a cross check, EPA is requesting both the amount of active ingredient in Col. E and product applied per area in Col. F. Indicate the unit of the product in Col. G.

Use 2001 prices and costs. If the product is custom applied you may enter the total cost in the last column ( Col. M) and override the formula. If a pesticide is applied by the user, enter the price of the product in Col. H and the cost of applying it in Col. I. Enter any other costs associated with applying this product in Col. J, specifying what they are in the comments section at the bottom of this sheet. Col. M will be calculated automatically using the data you have entered.

Name of Product Price per Unit of the Product Cost of Applying Pesticide per Area Other Costs per Application For EPA Use Only ID#

See attached narrative Use one row for each active ingredient ( ai). For example, if a product contains 2 ai's use 2 rows for that product. Once a row is completed for a given product, then only Col.

B ( if applicable), C, and E need to be completed for additional rows regarding the same product.

Enter the number of applications in a fumigation cycle comparable to methyl bromide for this alternative pest control regimen. Since this number is an average, it does not need to be a whole number.

Enter the formulation or the % of active ingredient. Cost per Area ( 2001$)

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Gross Revenue A B C D E F Crop/ Commodity Price Factors ( grade, time, market) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( lbs per acre) Price ( per unit of crop/ commodity) Revenue ( per area) $ 0.00 $ 0.00 South $ 0.00 Strawberries Fresh and Processed Total yield per acre 45,836 $ 0.00 Fresh 63% 28,877 $ 0.695 $ 20,069.36 Processed 37% 16,959 $ 0.306 $ 5,189.57 $ 0.00 North $ 0.00 Strawberries Fresh and Processed $ 0.00 Rotation 50,035 Fresh 84% 42,030 $ 0.576 $ 24,209.09 Processed 16% 8,006 $ 0.306 $ 2,449.73 Non Rotation 46,651 Fresh 84% 39,187 $ 0.576 $ 22,571.74 Processed 16% 7,464 $ 0.306 $ 2,284.05 Rotation 3 year Repeated use 44,980 Fresh 84% 37,783 $ 0.576 $ 21,762.96 Processed 16% 7,197 $ 0.306 $ 2,202.20 Total Revenue South $ 25,258.93 Total Rev Rot North $ 26,658.82 Total Rev Non Rot Nort $ 24,855.79 Repeated use Total Rev Rot North $ 23,965.16 Comments: Weighted averageyearly price for fresh berries is $ 0.695 South and $ 0.576 based on calculations used for Section 18 applications, Appendix K Percentage of fresh vs processed based on 2001 baseline, Worksheets 2 CS and 2 CN, .63: 37 and .84: 16 respectively Crop/ Commodity Yield calculated from the average percent yield from California strawberry trials, Appendix T, Pic Tab Note ratio in South of Fresh to Processed is 63% to 37%

Note ratio in North of Fresh to Processed is 84% to 16%

OMB Control #

Col. A: Crop/ Commodity If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternativ Chloropicrin If a consortium is submitting this application, the data for this table should reflect a representative user.

In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this Enter the unit of measurement for your crop/ commodity.

Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please discuss changes in crop cycles resulting from alternative use in the comments. See the Fumigation Cycle Worksheet f Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality, grade, market ( e. g., fresh or processing), timing of harvest, etc., you may itemize by using m Enter the number of units of crop/ commodity produced per area for that price factor identified.

Enter the average 2001 prices received by the users for that crop/ commodity and price factor.

The purpose of this worksheet is to identify the gross revenue for units ( crop, commodity, structure) when using an alternative compared to gross revenue when using methyl bromide.

Postharvest and structural users may modify this form to accommodate diff For EPA Use Only ID#

Col. A: Operation or Cost Item Col. B: Custom Operation Cost Col. C, D, E: Costs per Area Col. F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area $ 0.00 $ 0.00 Custom Drip Fumigation $ 1,455 $ 0.00 Flat Fumigation $ 1,208 $ 0.00 Lost revenue for early crop pull S $ 11 $ 0.00 $ 0.00 Lost revenue for early crop pull N $ 1,262 $ 0.00 Additional rent for rotation 525 $ 0.00 Weeding costs addition South 319 $ 0.00 $ 0.00 Weeding costs addition North 428 $ 0.00 $ 0.00 $ 0.00 South Total Custom per Area $ 1,784.52 User Total per area $ 0.00 North Total Rotation per Area $ 2,161.00 North Total Non Rotation per Area $ 3,145.40 Comments: North rotation growers must flat fume to rotate to vegetable growers.

Weeding costs for PIC shank calculated as $ 1,032 versus $ 713 for South, $ 1,385 versus $ 957 for North, Appendix K, Weeding Costs Weeding costs for PIC drip calculated as $ 1,282 versus $ 713 for the South, $ 1,721 versus $ 957 for the North, Appendix K, Weeding Cos See Appendix W, " Chloropicrin Narrative"

OMB Control # Chloropicrin Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative:

Custom Operation Cost per Area Operation or Cost Item Enter data only for costs ( other than the cost of alternative pest control) that change as a result of using the alternatives instead of methyl bromide. Enter the whole cost, not just the incremental changes. Enter the cost in Col. B for custom operatio Identify changes in the typical equipment used by the user as a result of not using methyl bromide. Please be specific such as tractor horsepower. No cost data are required in this column.

Identify the operations or cost items that change as a result of not using methyl bromide.

Enter custom operation costs that change in Col. B.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Enter in Col. C and D, material and labor costs per area that change for operations done by user. The total cost per area is calculated automatically from the values you enter in Cols. C and D. Typical Equipment Used Operation Done by User For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Reprentative Use Total Operating Costs Total Revenues Net Revenues Southern Region ( w/ o overhead) $ 26,208 $ 25,259 $ 948.60 Northern Region ( w/ o overhead) Rotation $ 26,134 $ 26,659 $ 524.82 Non Rotation $ 27,118 $ 24,856 $ 2,262.61 3 Year Repeated use Rotation $ 26,134 $ 23,965 $ 2,168.84 Total Revenues for South $ 948.60 Total Revenues for North $ 868.90 Comments: Overhead costs not included at this time as best case scenario See Appendix W, " Chloropicrin Narrative"

OMB Control # Worksheet 3 E. Chloropicrin Total Costs and Revenues in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated. Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) XXXX Efficacious amount of 200 lbs/ acre or more not allowed or discouraged by County Ag Commissioners ( Personal Communication, Ag Commissioners in Orange, Ventura, Santa Barbara, Santa Cruz, and Monterey Counties)

See Appendix Y, " Chloropicrin/ Metam Narrative" For EPA Use Only ID#

Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide [ Insert Study Title] In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives pro For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative,

BACKGROUND If use of this alternative is precluded by regulatory restriction for all users covered by this application, the applicant should not complete Section II. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions 1, 5, and 8.

Chloropicrin/ Metam Sodium In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each resear Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as applicati The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and othe There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

3. Publication and Date of Publication 4. Location of research study 5.

6. Was crop yield measured in the study? Yes No 7.

8.

OMB Control # For EPA Use Only ID#

See Appendix Y, " Chloropicrin/ Metam Narrative" Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. See Appendix Y, " Chloropicrin/ Metam Narrative" Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Study:

Col. A: Treatment Number Col. B: Treatment Col. C: Rate Col. D, F, H, J, L, N:

Interval Cols. E, G, I, K, M, O: Rating for Interval:

Control of Pests 1 and 2 ( Cols. D  I and Cols. J  O):

Col. J: Yield A B C D E F G H I J K L M N O P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments: See Appendix Y, " Chloropicrin/ Metam Narrative"

OMB Control # Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide For EPA Use Only ID#

Treatment Treatment Number Rate ( lbs. or gals. ai per area)

Enter the marketable yield of the crop or commodity and specify the units ( lbs./ acre, tons) in the column header or comments section.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. Yield ( units/ area)

Chloropicrin/ Metam Sodium [ Insert Study Title]

Provide one summary table for each study being described.

Research Summary Table For the target pest( s) in the study list the pest or pest species being rated in the column header or the comments section. For example, a study for nematode control in tomatoes may have looked at sting nematode and stunt nematode. Enter sting nematode Provide a summary table of research information that will allow us compare the impact of methyl bromide and the alternative regimen on such things as pest control, yield or quality of the commodity being treated, or protected.

Ideally, a research study s List the treatment number from the research study you are citing.

List what type of pest control method was used.

Enter the pounds or gallons of a chemical used, days of solarization, etc.

Enter the interval after treatment that the rating was taken. Enter the interval ( days, weeks or months) in the column heading or in the comments section. In the comments describe the rating scale ( e. g. 0 to 100 where 100 is complete control).

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J, M: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Units of product per Area per Application Product Unit ( e. g., lbs.,

gals) $ 0.00 $ 0.00 $ 0.00 Chloropicrin EC 24 galloms $ 0.00 + Metam Sodium drip 37 50 galloms $ 1,571.00 Chloropicrin bed shank 200 pounds $ 0.00 + Metam Sodium drip 37 50 galloms $ 1,161.00 $ 0.00 Average $ 1,366.00 $ 0.00 Chloropicrin flat shank + Metam drip $ 1,366.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total Non Rotation $ 1,366.00 Comments: Total Rotation $ 1,366.00 If you do not have the quantitative data for additional crops grown on the same land, please indicate so in the comment section.

See Appendix U, " mebr_ alts_ prices. xls"

See Appendix V, " Vegetable Rotation Narrative"

OMB Control # Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: Chlorpicrin Enter the area receiving at least one application of the pesticide.

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

Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. If multiple crops are grown Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product.

Col. A: Name of Product and Non chemical Control If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

As a cross check, EPA is requesting both the amount of active ingredient in Col. E and product applied per area in Col. F. Indicate the unit of the product in Col. G.

Use 2001 prices and costs. If the product is custom applied you may enter the total cost in the last column ( Col. M) and override the formula. If a pesticide is applied by the user, enter the price of the product in Col. H and the cost of applying it in Name of Product Price per Unit of the Product Cost of Applying Pesticide per Area Other Costs per Application For EPA Use Only ID#

Use one row for each active ingredient ( ai). For example, if a product contains 2 ai's use 2 rows for that product. Once a row is completed for a given product, then only Col.

B ( if applicable), C, and E need to be completed for additional rows regardin Enter the number of applications in a fumigation cycle comparable to methyl bromide for this alternative pest control regimen. Since this number is an average, it does not need to be a whole number.

Enter the formulation or the % of active ingredient. Cost per Area ( 2001$)

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications. For EPA Use Only ID#

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Gross Revenue A B C D E F Crop/ Commodity Price Factors ( grade, time, market) Unit of Crop/ Commodity ( pounds) Crop/ Commodity Yield ( lbs per acre) Price ( per unit of crop/ commodity) Revenue ( per area) $ 0.00 $ 0.00 South $ 0.00 Strawberries Fresh and Processed Total yield per acre 47,284 $ 0.00 Fresh 63% 29,789 $ 0.695 $ 20,703.13 Processed 37% 17,495 $ 0.306 $ 5,353.45 $ 0.00 North $ 0.00 Strawberries Fresh and Processed $ 0.00 Rotation 51,078 Fresh 84% 42,905 $ 0.576 $ 24,713.44 Processed 16% 8,172 $ 0.306 $ 2,500.77 Non Rotation 48,124 Fresh 84% 40,425 $ 0.576 $ 23,284.53 Processed 16% 7,700 $ 0.306 $ 2,356.17 Total Revenue South $ 26,056.58 Total Rev Rot North $ 27,214.21 Total Rev Non Rot Nor $ 25,640.71 Comments: Weighted averageyearly price for fresh berries is $ 0.695 South and $ 0.576 based on calculations used for Section 18 applications, Appendix K Percentage of fresh vs processed based on 2001 baseline, Worksheets 2 CS and 2 CN, .63: 37 and .84: 16 respectively Crop/ Commodity Yield calculated from the average percent yield from California strawberry trials, Appendix T, " Alt Sum Yield Data. xls"

Note ratio in South of Fresh to Processed is 63% to 37%

Note ratio in North of Fresh to Processed is 84% to 16%

OMB Control #

Col. A: Crop/ Commodity If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternati Chloropicrin/ Metam Sodium If a consortium is submitting this application, the data for this table should reflect a representative user.

In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this Enter the unit of measurement for your crop/ commodity.

Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please discuss changes in crop cycles resulting from alternative use in the comments. See the Fumigation Cycle Worksheet f Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality, grade, market ( e. g., fresh or processing), timing of harvest, etc., you may itemize by using m Enter the number of units of crop/ commodity produced per area for that price factor identified.

Enter the average 2001 prices received by the users for that crop/ commodity and price factor.

The purpose of this worksheet is to identify the gross revenue for units ( crop, commodity, structure) when using an alternative compared to gross revenue when using methyl bromide.

Postharvest and structural users may modify this form to accommodate diff For EPA Use Only ID#

Col. A: Operation or Cost Item Col. B: Custom Operation Cost Col. C, D, E: Costs per Area Col. F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area $ 0.00 $ 0.00 Drip Fumigation PIC + Metam $ 1,366 $ 0.00 Flat Fumigation + Drip $ 1,366 $ 0.00 Additional yearly maintenance of drip $ 100 $ 0.00 Lost revenue for early crop pull S $ 1,841 $ 0.00 Savings from not picking 1 month S $ 832 Lost revenue for early crop pull N $ 2,525 $ 0.00 Savings from not picking 1 month N $ 1,836 Additional rent for rotation 525 $ 0.00 Additional Weeding Costs S 175 $ 0.00 Additional Weeding Costs N 235.5 $ 0.00 ( average of two weed costs) $ 0.00 $ 0.00 $ 0.00 South Total Custom per Area $ 2,649.62 User Total per area $ 0.00 North Total Rotation per Area $ 2,126.50 North Total Non Rotation per Area $ 2,390.29 Comments: Weeding costs for shank application calculated as $ 773 versus $ 713 for the South, $ 1,038 versus $ 957 for the North Weeding costs for drip application calculated as $ 1,003 versus $ 713 for the South, $ 1,347 versus $ 957 for the North See Appendix Y, " Chloropicrin/ Metam Sodium Narrative"

OMB Control # Chloropicrin/ Metam Sodium Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative:

Custom Operation Cost per Area Operation or Cost Item Enter data only for costs ( other than the cost of alternative pest control) that change as a result of using the alternatives instead of methyl bromide. Enter the whole cost, not just the incremental changes. Enter the cost in Col. B for custom operatio Identify changes in the typical equipment used by the user as a result of not using methyl bromide. Please be specific such as tractor horsepower. No cost data are required in this column.

Identify the operations or cost items that change as a result of not using methyl bromide.

Enter custom operation costs that change in Col. B.

Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Enter in Col. C and D, material and labor costs per area that change for operations done by user. The total cost per area is calculated automatically from the values you enter in Cols. C and D. Typical Equipment Used Operation Done by User For EPA Use Only ID#

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Reprentative Use Total Operating Costs Total Revenues Net Revenues Southern Region ( w/ o overhead) $ 27,073 $ 26,057 $ 1,016.04 Northern Region ( w/ o overhead) Rotation $ 26,100 $ 27,214 $ 1,114.71 Non Rotation $ 26,363 $ 25,641 $ 722.59 Total Revenues for South $ 1,016.04 Total Revenues for North $ 196.06 Comments: Overhead costs not included at this time as best case scenario OMB Control # Worksheet 3 E. Chloropicrin/ Metam Sodium Total Costs and Revenues in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation,

( 4) management, and ( 5) overhead such as office and administration.)

Please describe the cost in more detail.

Please describe how you estimated the portion of total fixed cost of the farm or entity that applies to this crop/ commodity.

Enter the cost per area of methyl bromide treated. Use additional pages as needed.

Alternative: Study:

Section I. Initial Screening on Technical Feasibility of Alternatives 1. Are there any location specific restrictions that inhibit the use of this alternative on your site?

1a. Full use permitted 1b. Township caps XXXX 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe) XXXX See Appendix Z, " 1,3 D Chloropicrin Narrative" See Appendix P, Impact of Township Caps Local restrictions near sensitive sites and buffer zone requirements, See Appendix O For EPA Use Only ID#