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The applicant, International Paper, grows bareroot pine SuperTree seedlings at nine ( 9) nurseries in the Arkansas ( 1 nursery) Alabama ( 2) Georgia ( 2) South Carolina ( 2) Texas ( 2)

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Light X Medium Heavy 0 to 2% X 2 to 5 % over 5%

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6. Specialty ( check one)

7. agronomic 8. economic X 9. Daytime phone 10. FAX 11. 912 238 6131 Savannah, Georgia 31402 richard. barham@ ipaper. com 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).

International Paper Soil Type: Organic Matter: Soil type Check the boxes) 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. International Paper is the world's largest seedling grower producing over 350MM bareroot pine SuperTree seedlings in the southeast. To date we have produced nearly 8 billion forest tree seedlings in the U. S. alone, and last year we planted our 6 millionth acre of forestland in the U. S. SuperTree seedling customers consist of private non industrial land owners, forest industry, and various government agencies. Our customers use SuperTree seedlings for reforestation, wildlife enhancement, and aesthetic and ecosystem regeneration. Greater than 95% of our southeastern nursery production consists of bareroot loblolly ( Pinus taeda ), slash ( Pinus elliotti i), sand ( Pinus clausa ), and virginia ( Pinus virginiana ) pines.

None regions 7, and 8. 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). International Paper's SuperTree seedlings represent a diverse array of genetic adaptability and can be planted throughout Consortium name E mail Address 912 238 7595 P. O. Box 1391 For EPA Use Only ID#

Location ( Enter the state, region, or county. Provide more detail about the location if relevant to the feasibility of alternatives to methyl bromide.)

following southeastern states:

regions 6, 7, and 8 as defined by the U. S. climate zone map. Bareroot SuperTree seedling nurseries are located in Contact name Mr. Richard Barham Worksheet 1. Contact and Methyl Bromide Request Information List an additional contact person if available. Specialty ( check one)

12. agronomic X 13. economic 14. 15. FAX 16. 17. 92,000 lbs.

17a. Acres units 18. Yes X No 18a. Are you requesting methyl bromide for additional years beyond 2005? 912 739 4721 912 739 9409 For EPA Use Only ID#

P. O. Box 56 Dr. George Lowerts Acres If a consortium is submitting this application, the data for question 17 and 17a. should be the total for the consortium. In the question below, area is defined as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

2006 Quantity ai ( lb.) of Methyl Bromide 92,000 Area to be Treated 270 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.

A portion of all International Paper SuperTree seedling nurseries are fumigated each year. The request for a Critical Use Exemption is based on this annual application requirement.

2006 92,000 lbs If a consortium is submitting this application, the data below should be the total for the consortium.

270 Requests beyond 2005 How much active ingredient ( ai) of methyl bromide are you requesting for 2005? Contact name Address Daytime phone E mail 2007 Unit of Area Treated 92,000 Year Acres 2007 92,000 lbs Bellville, Georgia 30414 george. lowerts@ ipaper. com How much area will this be applied to? Please list units. 270 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. 19.

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20a.

OMB Control # 2060 0482 destruction of pine seedling crops. Seedling quality is also reduced by nematodes which attack pine seedlings. Fumigation with methyl bromide has been demonstrated to effectively control the following genera: Criconemoides, and Helicotylenchus. There is no other product or control method available that will economically and practically control all of the above pathogens and pests as does a single methyl bromide fumigation. After many years of investigating integrated pest management alternatives including solarization, organic amendments, and cultural controls, Weyerhaeuser has concluded no single alternative has the broad spectrum biocidal efficacy of methyl bromide ( EPA, 2002). A description of the economic and environmental impact associated with a withdrawal of methyl bromide on International Paper and on southeastern forestry can be found in appendix 4. 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.)

Explain why this user represents the typical user in the consortium. At all International Paper SuperTree nurseries, methyl bromide fumigation is a cost effective and essential treatment for the production of bareroot pine seedlings. Methyl bromide fumigation is critical for the control of weed ( broadleaf and grasses) seed, particularly yellow and purple ( Cyperus spp. ) nutgrass since there is no other control product or economically feasible control method available. Both yellow and purple nutsedge are included in the United Nations list of the world's top ten worst weeds. Without methyl bromide fumigation, nutgrass will rapidly dominate seedling production areas reducing seedling quality to such an extent that the crop may not be suitable for reforestation and ecosystem regeneration. As a quarantine measure, the USDA requires all shipments of seedlings to be free of fire ants ( Solenopsis invicta ). Methyl bromide fumigation is the only practical method for controlling fire ants over large areas. In addition, many soil fungal pathogens ( ex. Macraphomia spp., Cylindrocaldium spp., Fusarium spp., Pythium spp., Rhizoctonia spp. ) are effectively controlled. These root rot pathogens have the ability to literally result in the Representative User For EPA Use Only ID#

Worksheet 1. Contact and Methyl Bromide Request Information International Paper has nine ( 9) SuperTree seedling nurseries in the southeast that range in size from 100 to 200 plantable acres. A typical International Paper nursery has about 140 acres available for growing bareroot seedlings in any given year. Of these 140 acres, only 70 acres are used each year for growing seedlings. Our nurseries operate with a 2: 2 crop rotation consisting of two years in seedlings and two years in cover crop with methyl bromide fumigation applied to the soil just before sowing the seedling crop. Of the total amount of land used to grow seedlings every year approximately one half is fumigated each year, thus, our typical International Paper nursery would fumigate 35 of the 70 acres available for growing seedlings each year. Across all nine SuperTree nurseries, we expect to fumigate approximately 270 acres each year. 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. 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 334 126,144 378 193 70,170 364 413 151,775 367 143 52,336 366 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 10 2,350 235 24 5,640 235 39 9,165 235 17 4,053 238 50% methyl bromide, 50% chloropicrin 90% methyl bromide, 10% chloropicrin 4 1,253 313 136 40,785 313 57% methyl bromide, 43% chloropicrin 2 456 228 All formulations of methyl bromide 344 128,494 374 217 75,810 349 456 162,193 356 298 97,630 328 Comments:

OMB Control # 2060 0482 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 ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) acres Price ( per unit of crop/ commodity)

thousand seedling Revenue ( per area) acres 1997 per thousand trees 658 $ 34 $ 22,372 1998 per thousand trees 658 $ 36 $ 23,688 1999 per thousand trees 658 $ 37 $ 24,017 2000 per thousand trees 658 $ 39 $ 25,662 Total Revenue for 1997 $ 22,372 Total Revenue for 1998 $ 23,688 Total Revenue for 1999 $ 24,017 Total Revenue for 2000 $ 25,662 Average Revenue Per Year $ 23,935 Comments: The last two years of the four year cycle are in cover crop which does not generate revenue.

OMB Control # 2060 0482 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 2000 Col. B: Crop/ Commodity Forest Tree Seedlings Pine & Hardwoods Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield B 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.

1st year after fumigation seedlings 1st year after fumigation seedlings 1st year after fumigation seedlings 1st year after fumigation seedlings Revenue is only generated in years that seedlings are grown. In a 2: 2 rotation, the first two years are in seedlings and generate revenue.

Crop/ Commodity Yield and Gross Revenue 1997 2000 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 ( grade, time, market) Unit of Crop/ Commodity ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) acre Price ( per unit of crop/ commodity)

thousand seedlings Revenue ( per area) acres Bareroot Seedlings Pine seedling quality, genetic gain, market per thousand trees 675 $ 40.00 $ 27,000.00 fluctuations Total Revenue 27,000.00 $

Comments:

OMB Control # 2060 0482 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 the comment section below.

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 row. Itemize or aggregate these factors to the extent appropriate in making the case that the use of methyl bromide affects these price factors.

Enter the unit of measurement for each crop/ commodity.

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

Note: revenue is only generated during the first two years following fumigation when the land is growing bareroot seedlings.

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 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. Please explain in the comment section at the bottom of the worksheet why 2001 is not considered a typical year, if that is the case. 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 followed by peppers in a single growing season, or strawberries followed by lettuce over 2 or 3 years) include all of the crops during the entire interval. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.

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

Col. A: Crop/ Commodity Worksheet 2 C. 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. 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 ( acres) Cost per Area over 95% methyl bromide 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin 90% methyl bromide, 10% chloropicrin _ 80_% methyl bromide, 20__% chloropicrin 280 $ 2.70 $ 300 270 $ 1,795.00 All formulations of methyl bromide 280 $ 2.70 $ 300 270 $ 1,795.00 Comments:

OMB Control # 2060 0482 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 the comments, the relative usage of the various formulations, to the extent known.

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., tarps). Column G will be calculated automatically using the values you entered in columns B E. If methyl bromide is custom applied, enter the cost per area in Col. G and fill in Cols. B and F.

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 provide an additional year's data, please explain in the comment section at the bottom of the worksheet why 2001 is not considered a typical year.

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. 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 Soil Preparation for Sowing Seeds $ 592.42 $ 573.48 $ 1,165.90 Sowing Pine Seeds $ 4,457.98 $ 549.68 $ 5,007.66 Crop Cultural Activities $ 1,061.36 $ 1,412.02 $ 2,473.38 Lifting, packing, shipping crop to $ 3,682.85 $ 897.27 $ 4,580.12 customers Total Custom per Area User Total per area $ 13,227.06 Soil Preparation: Typical farm tractor and implements Sowing: Highly specialized machine sowers are used to sow genetically improved seed. Power supplied by farm tractor.

Maintenance Standard tractor drawn boom sprayers. Implements for fertilization, top and root pruning are specially designed for forest tree nurseries.

Harvest OMB Control # 2060 0482 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. Operation Done by User Worksheet 2 E. 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.

Note: The operations listed are typical for each International Paper SuperTree seedling nursery Operations Details: Highly mechanized harvesting operation using specially designed seedling lifters. Seedlings placed in cold storage until shipped 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 Labor and Labor Related Managerial and Administrative salaries and benefits $ 2,442.99 Travel Travel Expenses, Business Meals, Conferences $ 199.49 Advertising $ 92.56 Postage FedEx, UPS, and regular mail charges $ 65.10 Communications Telephones, Cellular Phones $ 201.30 Data Processing $ 44.12 Computer Hardware Computers, printers, etc. $ 31.16 Rentals Tangible Properties Machine Rentals $ 49.06 Rentals Real Property Office Rental $ 177.94 Vehicle Lease Expenses Auto Lease and Heavy Equipment $ 870.48 Dues and Assessments Trade Association Dues and Contributions $ 14.08 Publications Trade Magazine Subscriptions $ 1.97 Meetings $ 22.93 Taxes Sales and Property Taxes $ 398.37 Depreciation Capitalized Interest and Plant Depreciation $ 1,759.79 Gain/ Loss on Sale of Assets Usually a one time loss or gain $ 435.21 Legal Settlements Company Legal Bill $ 207.96 Rental Income From home on nursery site $ 62.69 Supplies and Equipment Managerial and Administrative Supplies $ 517.87 Other Income/ Expenses $ 148.05 Utilities Water and Electricity $ 553.89 Allocations and Transfers Corporate and Division Overhead $ 282.35 Total $ 7,583.56 Comments: Data represent costs from a typical International Paper SuperTree seedling nursery growing bareroot pines.

OMB Control # 2060 0482 Worksheet 2 F. 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. 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 Yes 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe)

Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No X 1a. If not on the EPA website, please attach a copy. See Appendix 3 for list. All articles are part of the public domain and can be used freely. 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 stu Yes x No ( seedling size, bed density) 7. EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions Summarize each of the research studies you cite in the Research Summary Worksheet. If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more BACKGROUND There are three major ways you can provide the Agency with proof of your investigative work. Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide In this worksheet, you should address why an alternative pest management strategy on the list ( see previous For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed.

In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and Basamid Various see Appendix 3 If use of this alternative is precluded by regulatory restriction for all users covered by this For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide See Appendix 3 for list. Primary investigating agency is the staff of the Auburn University Nursery Cooperative, Drs. Ken McNabb and Bill Carey See Appendix 3 Various forest tree seedling nurseries in the southeastern US Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss.

Basamid Describe the effectiveness of the alternative in controlling pests in the study.

Nutsedge ( Cyperus spp. ) populations are not controlled to any great extent by Basamid as indicated in many research studies ( Carey, 1994b, 1996; Conn, 2002; Dwinell and Fraedrich, 1997). Also, a 1997 survey of southern forest nursery managers indicated that Basamid was less effective in weed control than methyl bromide ( Cram, 1996). The population of nutsedge plants on a nursery bed can quickly expand to epidemic proportions literally covering the developing pine and seedlings ( Figure 1, 8. Basamid studies have been conducted at nurseries similar to those of International Paper and on similar nursery soils. We do not expect results different from those observed in the various research studies. At best, Basamid effects are inconsistent. The lack of nutsedge control is a serious threat to the efficient and economical production of quality pine seedlings.

OMB Control # 2060 0482 nurseries will have to resort to handweeding which increases cost ( approximately $ 662/ acre; see section 3 D Basamid).

Paper, a reduction in bed density by just 2 plantable seedlings/ sq ft would result in a per acre nursery bed loss of $ 2.2M. Appendix 2). As can be expected, the size of the pine seedlings will be dramatically reduced from grade one seedlings to grade 2 or cull seedlings ( i. e. unusable) when in competition with nutsedge. South, et al. ( 2001) demonstrated that a reduction in seedling size by 2mm can result in a net present value loss of $ 0.10 per seedling. With an annual crop exceeding 350MM seedlings, International Paper can expect to incur an annual loss $ 35MM just from increased weed competition primarily from nutsedge. Unfortunately, no herbicides are available that will control nutsedge without damaging the i dli Th I t ti l P S T Discuss how the results of the study apply to your situation. Would you expect similar results? Seedling size is an important indicator of seedling quality since size at time of field planting is directly related to survival and future tree growth ( South, et al, 2001). Basamid has not demonstrated consistent seedling size effects at many study locations and in operational use ( Auburn Nursery Cooperative, 2002). Some studies indicate soil treated with Basamid can produce seedlings that have the same average root collar diameter as those seedlings grown in soil treated with methyl bromide fumigation ( Carey, 1996). However, several studies clearly demonstrate that Basamid treated soil produces smaller seedlings than soil treated with methyl bromide ( Carey, 1994b, 1995, Cary and McNabb, 1996; Dwinell and Fraedrich, 1997). Weed pressure was not a factor in these studies and did not contribute to the reduction in seedling size ( Auburn Nursery Cooperative, 2002). Further, Basamid has consistently produced 2.2 fewer seedlings per sq. ft. of nursery bed compared to methyl bromide ( A b N C ti 2002) At I t ti l Many different soil fungi are beneficial to pine seedling growth. Low populations of these fungi will result in erratic seedling growth patterns in the nursery bed and a reduction in seedling size. Basamid treatment has been demonstrated to prolong the recovery of Trichoderma ( one of the most beneficial fungi) compared to methyl bromide fumigation ( South, et. al. 1997; Lyer and White, 1969). The long term effect of repeated use of Basamid on the soil population of Trichoderma is unknown. However, Auburn Nursery Cooperative ( 2002) is very concerned that the populations of beneficial soil fungi may be comprised with Basamid use Outgassing is a potentially serious problem with Basamid. At least one case of outgassing from Basamid treated fields has been reported ( Auburn Nursery Cooperative, 2002). Methylisothiciocyanate ( MITC) gas is the active ingredient in Basamid. This gas is released upon the exposure of Basamid to water. Seedling damage from outgassing of fumigation alternatives has also been documented by the J. Herbert Stone Nursery ( Scholtes, 1989) Outgassing poses a risk to the health of adjacent seedlings ( see Figure 2; Appendix 3) as well as those individuals in residences adjacent to International Paper SuperTree nurseries Col. B: Target Pests Col. C: Active Ingredi Col. D: Formul ation Col. E, F, G: Applica Col. H, I, J: Prices and Costs Col. K: Area Treated Col. L: # of Applica Col. M: Cost per Nonchemic al Control A B C D E F G H I J K L M lbs. ai per Area per Applicati on Units of product per Area per Applicati on Product Unit ( e. g., lbs., gals)

Basamid Weeds MITC 98% 343 acre 350 lbs/ a lbs ######### $ 2,000.00 Soil Fungi $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 emical Pest Target Pest Description Cost/ area Total $ 2,000.00 Comments: If you do not have the quantitative data for additional crops grown on the same land, please indicate so in the comment section.

OMB Control # 2060 0482 For EPA Use Only Worksheet 3 B. Alternatives  Pest Control Reg Basamid If a consortium is submitting this application, the data for this table should reflect a representative user. Col. A: Name Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product.

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 formulation or the % of active ingredient.

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.

Enter the area receiving at least one application of the pesticide.

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 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.

Cost per Area ( 2001$) 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.

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 Target Pests Active Ingredien ts ( ai) in Product Formulati on of Product Application Rate Price per Unit of the Product Area Treated at Least Once # of Applicati ons per Year Cost of Applying Pesticide per Area Other Costs per Applicati on 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 ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) thousand/ acre Price ( per unit of crop/ commodity) per thousand Revenue ( per area) acre Pine seedlings seedling quality, genetic gain, market 1000 trees 621 $ 40 $ 24,840 fluctuations $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Total Revenue $ 24,840.00 Comments:

OMB Control # 2060 0482 Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternati Basamid 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 revenue amount is different in the comment i b l 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 for a comprehensive definition of the fumigation cycle.

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 more than one row. Itemize or aggregate these factors to the extent appropriate in making the case that the use of alternatives affects these price factors.

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.

Note: revenue is only generated during the first two years following fumigation when the land is growing bareroot seedlings.

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 differences in operations when providing gross revenue data.

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.

Gross Revenue of Alternatives 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 ( acre) Total Cost per Area ( acre)

Hand Weeding 0 $ 60/ acre/ application $ 360.00 Hand labor Increased Herbicide Use cover crop / fallow $ 24.50 $ 59.40 $ 83.90 Tractor / Spray Rig seedling crop $ 98.50 $ 120.00 $ 218.50 Tractor / Spray Rig Total Custom per Area User Total per area $ 662.40 Comments:

Assumes increase in weed populations ( ex. Nutsedge) will require one hand weedings per acre per month from May through October. Cost per acre is estimated to be $ 60 which represents a hand weeding crew of 5 plus one supervisor.

Additional herbicide use will be needed when growing seedlings the first two years of the fumigation cycle and also during the second two years when the soil is fallow or in cover crop.

Additional indirect costs per acre at listed in 3 A Typical Equipment Used Operation Done by 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. Basamid 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 operation costs, or in Col. C and D for operations done by user.

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 . 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 See Comment Comments:

See appendix 3 for list of research publications.

OMB Control # 2060 0482 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)

Basamid See " comments" below 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. 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 Yes 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe)

Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No X 1a. If not on the EPA website, please attach a copy. See Appendix 3 for list. All articles are part of the public domain and can be used freely. 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 stu Yes x No ( seedling size, bed density) 7. For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide In this worksheet, you should address why an alternative pest management strategy on the list ( see previous For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions Summarize each of the research studies you cite in the Research Summary Worksheet. If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more BACKGROUND EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could There are three major ways you can provide the Agency with proof of your investigative work. Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and Metham sodium Various see Appendix 3 If use of this alternative is precluded by regulatory restriction for all users covered by this For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide See Appendix 3 for list. Primary investigating agency is the staff of the Auburn University Nursery Cooperative, Drs. Ken McNabb and Bill Carey See Appendix 3 Various forest tree seedling nurseries in the southeastern United States Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss.

Metham sodium Describe the effectiveness of the alternative in controlling pests in the study.

Metham sodium cannot be safely used at International Paper SuperTree seedling nurseries. In 2000, International Paper's Texas nursery at Bullard installed an operational pilot study to evaluate metham sodium effectiveness on a large scale. The Metham sodium was applied to the soil during the day. That evening the chemical outgassed from the soil and drifted on the wind. As can be seen in Figure 2 ( Appendix 2), the outgassed Metham sodium killed over 20 million pine seedlings. An even more distressing event occurred with Some early studies ( Carey, 1994a, 1996, 1999, 2000a, b, c, Cram, 1996) with Metham sodium showed promising results when Metham sodium was combined with chloropicrin or the herbicide EPTC. Weed control and seedling size were similar to the results obtained with methyl bromide fumigation ( Carey, 2000d). Metham sodium/ chloropicrin fumigated soil tends to produce seedlings with less biomass than methyl bromide fumigation ( Carey, et al., 2001). Like Basamid, a reduction in the number of seedlings in the nursery bed sometimes occurs. Fewer seedlings available in the nursery translates to less potential revenue.

Metham sodium application to the soil requires additional soil cultural treatments compared to methyl bromide. A tractor mounted rototiller is needed to incorporate the Metham sodium into the soil. Each time any vehicle travels over the soil a serious soil compaction risk occurs. A " plow pan" or compaction layer will form in the soil just below the level of the rototiller. This compacted layer retards water infiltration through the soil, reduces aeration, and forms a barrier to root growth. As a consequence, seedling quality can be reduced due to excessive soil moisture and poor pine seedling growth. The Auburn University Nursery Cooperative ( 2002) has documented nursery soil damage from Metham sodium application. Application time for Metham sodium fumigation is two to three times as long as methyl bromide ( Parker, 2002). International Paper SuperTree nurseries have a short period when environmental conditions are favorable for fumigation. It is doubtful, that Metham sodium applications can be completed before adverse soil temperature conditions occur.

8. Metham sodium has been applied directly to some of our nurseries. The outgassing associated with Metham sodium cannot be practically avoided. Due to this experience and the outgassing seen at other forest tree nurseries, International Paper cannot safely use Metham sodium as an alternative to methyl bromide fumigation.

OMB Control # 2060 0482 Discuss how the results of the study apply to your situation. Would you expect similar results? this outgassing. The Metham sodium drifted to the property of several people living adjacent to the nursery. Since this event, these individuals have alleged to have health problems related to the outgassing and they are now in litigation with the contract applicator. Outgassing of Metham sodium from forest tree nurseries has been reported in Louisiana, Mississippi, Arkansas, Oregon, and Montana ( Carey, 00). Because of the risk of outgassing and the threat to health of those living downwind, Metham sodium is not a suitable alternative to methyl bromide fumigation.

Nutsedge ( Cyperus spp. ) populations are not controlled to any great extent by Metham sodium ( when used as a stand alone treatment) as indicated in several research studies ( Carey 1996, Fraedrich and Dwinell, 1997). The population of nutsedge plants on a nursery bed can quickly expand to epidemic proportions literally covering the developing pine seedlings ( Figure 1, Appendix 2). As can be expected, the size of the pine seedlings will be dramatically reduced from grade one seedlings to grade 2 seedlings when in competition with nutsedge. South, et al, ( 2001) demonstrated that a reduction in seedling size by 2mm can result in a net present value loss of $ 0.10 per seedling. With an annual crop exceeding 350MM seedlings, International Paper can expect to incur an annual loss of $ 35MM just from increased weed competition primarily from nutsedge. Unfortunately, no herbicides are available that will control nutsedge without damaging the pine seedlings. Thus, International Paper SuperTree nurseries will have to resort to handweeding which increases seedling cost. Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J: 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)

Tarped Metham sodium weeds/ fungi MITC 42% 210 lbs 60 gallons 1 $ 2,000.00 Non Chemical Pest Control Target Pests Description Cost/ area Total $ 2,000.00 Comments:

OMB Control # 2060 0482 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 regarding 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 per area Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: Metham 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 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.

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 ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) thousand/ acre Price ( per unit of crop/ commodity) per thousand Revenue ( per area) acre Pine seedlings seedling quality, genetic g 1000 trees 621 40 $ 24,848 fluctuations $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Total Revenue $ 24,848.00 Comments:

The reduction in the number of seedlings per bed is comparable for both Basamid and Metham sodium; therefore, the revenue numbers OMB Control # 2060 0482 Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Metham sodium If a consortium is submitting this application, the data for this table should reflect a representative user. 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 Col. A: Crop/ Commodity Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity Enter the unit of measurement for your crop/ commodity.

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. 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 revenue expressed here are the same as for Basamid. Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Gross Revenue of Alternatives Note: revenue is only generated during the first two years following fumigation when the land is growing bareroot seedlings. 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 ( acre) Total Cost per Area ( acre)

Hand Weeding 0 $ 60/ acre/ application $ 360.00 Hand labor Increased Herbicide Use seedling crop $ 98.50 $ 120.00 $ 218.50 Tractor/ Spray Rig cover crop/ fallow $ 24.50 $ 59.40 $ 83.90 Tractor/ Spray Rig Total Custom per Area User Total per area $ 662.40 Comments: Assumes increase in weed populations ( ex. Nutsedge) will require one hand weedings per acre per month from May through October. Cost per acre is estimated to be $ 60 which represents a hand weeding crew of 5 plus one supervisor.

Additional herbicide use will be needed when growing seedlings the first two years of the fumigation cycle and also during the second two years when the soil is fallow or in cover crop.

Additional indirect costs per acre at listed in 3 A Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative: Metham sodium If a consortium is submitting this application, the data for this table should reflect a representative user . 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, 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.

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

Operation or Cost Item Custom Operation Cost per Area Operation Done by User Typical Equipment Used 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 See Comment Comments: See appendix 3 for list of research publications.

OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide For EPA Use Only Research Summary Table Metham sodium See " comments" below Provide one summary table for each study being described. 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 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 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.). 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.

Treatment Number Treatment Rate ( lbs. or gals. ai per area) Yield ( units/ are a) 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 Yes 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe)

Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No X 1a. If not on the EPA website, please attach a copy. See Appendix 3 for list. All articles are part of the public domain and can be used freely. 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 stu Yes x No ( seedling size, bed density) 7. Describe the effectiveness of the alternative in controlling pests in the study.

Organic amendments have been tested as an alternative to methyl bromide fumigation. Known advantages of organic amendments include increased soil organic matter levels resulting in improved soil structure and cation exchange capacity ( Davey and Krause, 1980). In fact, International Paper SuperTree nurseries include the addition of organic amendments ( ex. sawdust, cotton gin waste, etc.) as a routine measure to maintain the productivity of nursery soils. The effect of organic amendments Various with several different organic amendments See Appendix 3 Various forest tree seedling nurseries in the United States Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide See Appendix 3 for list. In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and Organic Amendments Various see Appendix 3 If use of this alternative is precluded by regulatory restriction for all users covered by this EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could There are three major ways you can provide the Agency with proof of your investigative work. Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions Summarize each of the research studies you cite in the Research Summary Worksheet. If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more BACKGROUND For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide In this worksheet, you should address why an alternative pest management strategy on the list ( see previous For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. loss in the number of seedlings per square foot will result in less revenue since fewer seedlings will be available for sale.

8. At present, we expect similar results since both the Florida and South Carolina nurseries have soil types typical for all International Paper SuperTree nurseries. In fact, the South Carolina nursery is a member of International Paper's SuperTree nursery family. Additional research may show a role for organic amendments, most likely when used as part of an integrated pest management program.

OMB Control # 2060 0482 Discuss how the results of the study apply to your situation. Would you expect similar results? Seedlings were generally larger when grown in fumigated soil than in soil treated with organic amendments in both Florida and South Carolina after several consecutive seedling crops ( Kannwischer Mitchell, et al, 1995, 1997; Barnard, et al., 1996). However, some pine bark or compost treatments did have greater average root collar diameter than fumigated soil. Similarly, average root collar diameter in fumigated soil in the pacific northwest was equal, greater, or smaller than the root collar diameter seen in soil treated with organic amendments or crop rotations ( Stone, et al, 1997). Evidently the effect of soil organic amendments on seedling size has been inconsistent. A small reduction in root collar diameter of only 2mm can seriously affect the revenue from seedling sales ( see discussion in 3 A B id) Organic amendments may affect the populations of plant pathogenic fungi; however, weeds are not controlled. In fact, careful consideration must be given to the source of organic amendments in order to prevent the introduction of additional weeds into the nursery ( Lantz, 1997). Nutsedge ( Cyperus spp. ) populations could prosper with the use of organic amendments. As explained in section 3 A Basamid and 3 A Metham sodium, nutsedge control is very difficult without methyl bromide fumigation. Decreased seedling quality and increased nursery costs associated with more hand weeding and herbicide use are inevitable without methyl bromide fumigation. Seedling health has not been affected after several consecutive crops in soil treated with organic amendments at forest tree nurseries in the southeast ( Kannwischer Mitchell, et al, 1995, 1997; Barnard, et al., 1996) and the pacific northwest ( James, et al, 1997; Stone, et al, 1997). In fact, there was no significant difference in disease incidence between soil treated with various fumigants ( e. g. Basamid, methyl bromide) and soil organic amendments even after four consecutive seedling crops. However, seedling survival and seedling size were typically greater on fumigated soil than on soil treated with organic amendments. Nursery bed densities at the end of the growing season indicated soil treated with methyl bromide generally had 1 to 3 more seedlings per sq. ft. than did soil treated with pine bark or compost ( Kannwischer Mitchell, et al, 1995; Barnard, et al, 1996). In the pacific northwest, the two year old seed bed densities of douglas fir ( Pseudotsuga menziesii) and ponderosa pine ( Pinus ponderosa ) were variable (+/) depending on the organic amendment, cropping technique, and soil fumigant ( Stone, on the population of soil pathogens and parasites, and the effect on seedling quality have been evaluated in several recent studies. Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J: 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 Applicati on Units of product per Area per Applicati on Product Unit ( e. g., lbs., gals)

Organic Soil Fungi none 100% 540 cu. Yrds lbs $ 7.50 $ 4,050.00 Matter $ 0.00 $ 0.00 $ 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 Pest Description Cost/ area Total $ 4,050.00 Comments: Organic amendments when used as an alternative to methyl bromide fumigation should be applied from 1 to 4 inches thick ( Carey and McNabb, 1996). For EPA Use Only Worksheet 3 B. Alternatives  Pest Control Regimen Costs for A Organic Amendments If a consortium is submitting this application, the data for this table should reflect a representative user. Col. A: Name of Product and Non chemical Control Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product. 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 Enter the formulation or the % of active ingredient. 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 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 Enter the area receiving at least one application of the pesticide. 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 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.

Cost per Area ( 2001$) 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 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 Target Pests Active Ingredien ts ( ai) in Product Formulati on of Product Application Rate Price per Unit of the Product Area Treated at Least Once # of Applicati ons per Year Cost of Applying Pesticide per Area Other Costs per Applicati on 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 ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) thousand/ acre Price ( per unit of crop/ commodity) per thousand Revenue ( per area) acre Pine seedlings seedling quality, genetic gain1000 trees 621 40 $ 24,848 fluctuations $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Total Revenue $ 24,848.00 Comments:

Assumes loss of 2.2 seedlings per sq. ft. of nursery bed.

OMB Control # 2060 0482 Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenu Organic Amendments If a consortium is submitting this application, the data for this table should reflect a representative user. 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 Col. A: Crop/ Commodity Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the 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 Enter the unit of measurement for your crop/ commodity.

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. In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Gross Revenue of Alternatives Note: revenue is only generated during the first two years following fumigation when the land is growing bareroot seedlings. 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 ( acre) Total Cost per Area ( acre)

Hand Weeding 0 $ 60/ acre/ application $ 360.00 Hand labor Increased Herbicide Use seedling crop $ 98.50 $ 120.00 $ 218.50 Tractor/ Spray Rig cover crop/ fallow $ 24.50 $ 59.40 $ 83.90 Tractor/ Spray Rig Total Custom per Area User Total per area $ 662.40 Comments: Assumes increase in weed populations ( ex. Nutsedge) will require one hand weedings per acre per month from May through October. Cost per acre is estimated to be $ 60 which represents a hand weeding crew of 5 plus one supervisor.

Weed control is not available with organic amendments. More herbicides will be needed during the growing season and in the fallow period.

Additional indirect costs per acre at listed in 3 A Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative Organic Amendments If a consortium is submitting this application, the data for this table should reflect a representative user. 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 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.

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

Operation or Cost Item Custom Operation Cost per Area Operation Done by User Typical Equipment Used Alternative: Study:

Col. A: Treatm ent Number Col. B: Treatm ent 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 ee Comment Comments: See appendix 3 for list of research publications.

OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl For EPA Use Only Research Summary Organic Amendments See " comments" below Provide one summary table for each study being described. 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 quali 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.

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.).

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.

Treatmen t Number Treatment Rate ( lbs. or gals. ai per area) Yield ( units/ are a) 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 Yes 1b. Township caps 1c. Alternative not acceptable in consuming country 1d. Other ( Please describe)

Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No X 1a. If not on the EPA website, please attach a copy. See Appendix 3 for list. All articles are part of the public domain and can be used freely. 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 stu Yes No X 7.

Flooding is not feasible at International Paper SuperTree nurseries. Our nursery soils are well drained and would require an excessive volume of water to keep the fields flooded. The fields are also designed to promote water drainage. A slope at least one percent is built into all fields to prevent water from standing. Flooding can only be used in flat, low lying areas with high seasonal water tables ( EPA, 2002). For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide In this worksheet, you should address why an alternative pest management strategy on the list ( see previous For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. When completing Section II, if you cite a study that is on the EPA website, you only need to complete questions Summarize each of the research studies you cite in the Research Summary Worksheet. If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more BACKGROUND EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could There are three major ways you can provide the Agency with proof of your investigative work. Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and Flooding/ Solarization Various see Appendix 3 If use of this alternative is precluded by regulatory restriction for all users covered by this For EPA Use Only Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide See Appendix 3 for list See Appendix 3 Various forest tree seedling nurseries in the United States Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss.

Flooding Solarization Describe the effectiveness of the alternative in controlling pests in the study. Flooding is not feasible due to soil drainage and slope. We would expect similar solarization results if we could successfully employ solarization during the summer months and economically control weeds. More research is needed to confirm affect of solarization on soil pathogens and parasites deep ( about 10" 12") in nursery soils.

8.

OMB Control # 2060 0482 Discuss how the results of the study apply to your situation. Would you expect similar results? Solarization is a method in which clear plastic is placed on top of the soil in order to trap solar radiation which raises soil temperature ( Carey and McNabb, 1996; EPA, 2002). Soil temperatures above 98F are required to kill or disable soil pathogens and parasites. With increasing soil temperature, the time needed to kill soil pathogens and parasites decreases. At 98F, up to 4 weeks exposure is needed to adversely affect soil pathogens and parasites. In contrast, only 1 to 6 hrs are needed if soil temperature is 117F ( Katan and DeVay, 1991). As expected soil temperature decreases with soil depth. A solarization study in Florida found soil temperatures of 121, 116, and 107F at soil depths of 2, 6, and 10 inches, respectively ( Chellemi, et al, 1994). Weyerhaeuser ( EPA, 2002) has found similar soil temperatures of 122 140F at a depth of 3 inches in Arkansas. The efficiency of solarization is dependent on air temperature, day length, and other factors. The time for optimum solarization is during the summer months.

Normally, nursery fields are fumigated in the late fall or early spring. Both periods are not suitable for solarization. A summer solarization would require clear plastic mulch to be laid on the soil for many months to achieve adequate soil temperatures deep in the soil profile and prevent erosion and re contamination from soil outside the treated area ( Carey and McNabb, 1996). Although forest tree nursery soils are usually uniform, most fields contain areas that have soil textural and drainage differences. These areas would not be treated to the same degree with soil solarization as the majority of the field. The quality of the seedlings produced in these areas would be different than the rest of the field. Unfortunately, many weed seeds are resistant to high temperatures and would not be affected. Nutsedge ( Cyperus spp) is not affected by the soil temperatures produced by solarization.

Although not currently feasible, solarization may play an important role in an integrated pest management system. Additional research is needed to combine several alternatives ( including organic matter, solarization, etc.) into one crop rotation package. Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J: 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 Applicati on Units of product per Area per Application Product Unit ( e. g., lbs., gals)

Solarization Soil Fungi none none none tarp/ acre sq. ft. $ 500.00 $ 500.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest ControTarget Pest Description Cost/ area Total $ 500.00 Comments: Flooding not possible. Estimated labor, tarp installation and removal costs For EPA Use Only Worksheet 3 B. Alternatives  Pest Control Regimen Costs f Flooding; Solarization If a consortium is submitting this application, the data for this table should reflect a representative user. Col. A: Name of Product and Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See If someone other than the applicant previously benefited from the application of methyl bromide in the fumigation cycle and you do not have Be as specific as possible regarding the species or classes of pests controlled by the active ingredient or pesticide product. 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 formulation or the % of active ingredient. 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 Enter the area receiving at least one application of the pesticide. 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 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.

Cost per Area ( 2001$) 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 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 Target Pests Active Ingredien ts ( ai) in Product Formulati on of Product Application Rate Price per Unit of the Product Area Treated at Least Once # of Applicati ons per Year Cost of Applying Pesticide per Area Other Costs per Applicati on 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 ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) thousand/ acre Price ( per unit of crop/ commodity) per Revenue ( per area) acre Pine seedlings seedling quality, genetic gain1000 trees 621 40 $ 24,848 fluctuations $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Total Revenue $ 24,848.00 Comments:

The number of seedlings per acre will decrease due to greater weed competition.

OMB Control # 2060 0482 Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Reven Flooding; Solarization If a consortium is submitting this application, the data for this table should reflect a representative user. 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 Col. A: Crop/ Commodity Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the 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 Enter the unit of measurement for your crop/ commodity.

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. In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Gross Revenue of Alternatives Note: revenue is only generated during the first two years following fumigation when the land is growing bareroot seedlings. 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 ( acre) Total Cost per Area ( acre)

Hand Weeding 0 $ 60/ acre/ application $ 360.00 Hand labor Increased Herbicide Use seedling crop $ 98.50 $ 120.00 $ 218.50 Tractor/ Spray Rig cover crop/ fallow $ 24.50 $ 59.40 $ 83.90 Tractor/ Spray Rig Apply soil organic matter $ 4,050 $ 40 $ 4,090 Tractor/ spreader ( e. g. sawdust)

Total Custom per Area User Total per area $ 4,752.40 Comments: Assumes increase in weed populations ( ex. Nutsedge) will require one hand weedings per acre per month from May through October. Cost per acre is estimated to be $ 60 which represents a hand weeding crew of 5 plus one supervisor.

Weed control is limited with solarization. More herbicides and hand weeding required. Since cover crop is not grown the summer before sowing a large volume of organic matter is needed.

Flooding not possible. Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative: Flooding; Solarization If a consortium is submitting this application, the data for this table should reflect a representative user . 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, 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.

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

Operation or Cost Item Custom Operation Cost per Area Operation Done by User Typical Equipment Used Alternative: Study:

Col. A: Treatm ent Number Col. B: Treatm ent 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 ee Comment Comments: See appendix 3 for list of research publications.

OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl For EPA Use Only Research Summary Flooding; Solarization See " comments" below Provide one summary table for each study being described. 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 quali 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.

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.).

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.

Treatmen t Number Treatment Rate ( lbs. or gals. ai per area) Yield ( units/ are a) 1. Name of study: alternatives to methyl bromide fumigation.

2. Researcher( s):

alternatives.

3. Your test is planned for:

4. Location:

5. Name of alternative to be tested:

6. Yes X No Includes seedling quality, size, survival 7.

OMB Control # 2060 0482 For EPA Use Only ID#

International Paper is very concerned about health, safety, and environmental quality. We will implement any methyl bromide alternative that is safe to use and promotes production of high quality SuperTree seedlings in a cost effective manner. Worksheet 4. Alternatives  Future Research Plans Will crop yield be measured in the study? Also, integrated pest management techniques including crop rotations, fallow field soil management, selected use of herbicides, solarization, and allopathic interactions of crops and weeds such as the reduction in number and size of nutsedge tubers associated with allopathic substances produced by sweet potatoes ( Ipomea spp ).

International Paper will be exploring all suitable alternatives similar to that done by Weyerhaeuser ( EPA, 2002) Several studies that will evaluate potential chemical and integrated pest management International Paper is a strong contributing member of the Auburn University Nursery Please describe future plans to test alternatives to methyl bromide. ( All available methyl bromide alternatives from the alternatives list should have been tested or have future tests planned.) There is no need to complete a separate worksheet for future research plans for each alternative  you may use this worksheet to describe all future research plans.

If additional testing is not planned, please explain why. ( For example, the available alternatives have been tested and found unsuitable, an alternative has been identified but is not yet registered for this crop, available alternatives are too expensive for this crop, etc.) installing at our nurseries appropriate methyl bromide alternative research studies.

Nine International Paper nurseries are available for research studies. 2002 and as needed Cooperative. As a consequence, we eagerly support Cooperative research activities by Various potential fumigants such as: methyl iodide, chloropicrin, eptc, azides. In addition, we will be installing in house research for further evaluation of methyl bromide 1.

1a. Check all methods you will use Nothing X Tarpaulin ( high density polyethylene)

Virtually impermeable film ( VIF)

Cultural practices ( please specify)

1b. Will you use other pesticides to reduce use of methyl bromide? Yes X No If yes please specify.

1c. Other non chemical methods: ( please specify):

2. Yes No X If yes, how many pounds? lbs.

3. Yes No X If yes, how many pounds? lbs.

4.

$

5.

6.

When do you expect these to occur?

7.

0 10 acres 10 25 acres trial at Texas is included. In house research costs not borne by the Cooperative are also included.

numbers so that total revenues are not affected. The cost associated with the alternative must not reduce our ability to earn an acceptable ROI. Further, any alternative must meet International Paper's requirements for health, safety, and environmental stewardship. 1,005,000.00 Range of acres farmed by growers included in this application? ( insert number of users in each category) Other investments, if any, made to reduce your reliance on methyl bromide. Describe each investment and its associated cost.

This money helps to support herbicide and nursery cultural research that may help reduce the need for methyl bromide.

An effective methyl bromide fumigation alternative must be able to produce seedlings of sufficient quality, size, and How will you minimize your use and/ or emissions of methyl bromide?

Allopathic effects of cover crops on weed seeds is a promising area.

Do you have access to recycled methyl bromide? Increased use of herbicides in cover crops and during seedling crop production Do you anticipate that you will have any methyl bromide in storage on January 1, 2005?

As soon as possible but in reality we do not know. Annual dues for International Paper's membership in the Auburn University Nursery Cooperative are $ 8,300 per year.

Identify what factors would allow you to stop or reduce your use of methyl bromide ( e. g. registration of particular pesticide; completion of research plan; capital outlay). What is the cumulative amount spent to date by the user or consortium on research to develop alternatives to methyl bromide ( beginning in 1992)?

The figure above includes International Paper's annual dues which helps support all Auburn University Nursery Cooperative research. Also, the revenue loss from seedlings damaged by Metham sodium operational scale research Worksheet 5. Additional Information For EPA Use Only ID# 25 50 acres 50 100 acres 100 200 acres note: acres suitable for growing pine and seedlings 200 400 acres nine International Paper SuperTree nurseries over 400 acres Worksheet 5. Additional Information ( continued)

8.

0  5,000 sq. ft. 5,001  10,000 sq. ft. 10,001  20,000 sq. ft. 20,001  40,000 sq. ft. 40,001  80,000 sq. ft. 80,001  160,000 sq. ft. X over 160,000 sq. ft. At each of nine International Paper SuperTree nurseries was obtained from the Auburn University Nursery Management Cooperative methyl bromide CUE application. For EPA Use Only ID# X The contribution of Hendrix and Dail to our research effort is calculated as $ 39, 061. This figure would not purchase the materials and labor on the open market. No commercial company would haul materials to Texas, 2,000 mile round trip, to treat half an acre for $ 3,000. Range of square feet of the area to which applicants included in this application will apply methyl bromide? ( insert number of users in each category)

The following is a description of the research effort conducted by the Auburn University Nursery Cooperative and The Coop. estimates that efforts to find alternatives to MBr have occupied a third of our research effort since 1993. With an annual operating budget of $ 200,000 this would be $ 666,000. This includes about 50% of the time for one Research Fellow and 10% and 25% respectively of two Technicians that are full time employees of the Coop but does not include the time of Auburn faculty associated with the Coop. The Contribution of Auburn University through faculty salaries of those three members closely associated with the Nursery Coop. during this period should add approximately $ 150,000.

A substantial contribution to research but not funded by the Auburn Coop has been the efforts by Dr. Scott Enebak into potential biological methods ( primarily PGPR research) to offset the loss of MBr. Since 1996, Dr. Enebak has generated $ 300,792 in grants for his PGPR research. To those grants, Auburn has contributed $ 108,000 for a full time technician and student workers who have been employed in this research for a total of $ 411,612 for PGPR and fumigation research. I certify that all information contained in this document is factual to the best of my knowledge.

Signature Date Print Name Title International Paper Corporation Signature Date Print Name Title and Orchards International Paper Corporation OMB Control # 2060 0482 Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered " critical" and authorized for an exemption beyond the 2005 phase out. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree not to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application.

Manager, Nurseries 6 Sep 02 Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 324 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. Richard O. Barham Manager; Nurseries Richard O. Barham 9 Sep 02 Worksheet 5. Additional Information The research within the Coop is highly cooperative. Nothing can be done without the cooperation of the nursery that agrees to allow the study to be placed on its production beds. It is very difficult to estimate the dollar contributions of these cooperating nurseries. For several studies the host nursery has just set the study area aside and not included it in its inventory of sold seedlings from treatment plots. In several studies seedlings from treatment plots have not been salable. The fate of seedlings within a study area often depends on market demands. In all instances we have received labor help from the host nursery. It is certain that the dollar value for this contribution is not zero, but very difficult to estimate.

We estimate cost of MBr replacement research associated with the Auburn Nursery Coop figures to have been $ 1,266,673 between 1993 and 2002. B67 For EPA Use Only and Orchards 1. 2. 3. 4. Pounds of Methyl Bromide Requested 2005 92,000 5. Area Treated with Methyl Bromide 2005 270 acre units 6. If methyl bromide is requested for additional years, reason for request:

2006 92,000 lbs. Area Treated 270 acres units 2007 92,000 lbs. Area Treated 270 acres units Not Technically Feasible Not Economically Feasible X X X X X X X X X X X Metham Sodium The population of soil pathogens and parasites can be affected by organic amendments. However, the population of weeds is not influenced and could even increased depending on the source of the organic amendment. Effects on seedling size have been variable. This alternative may be effective in a comprehensive IPM/ crop rotation At present a workable program to control weeds and soil pathogens and parasites has not be devised. This is the most promising area of research.

Place an " X" in the column( s) labeled " Not Technically Feasible" and/ or " Not Economically Feasible" where appropriate. Use the " Reasons" column to describe why the potential alternative is not feasible.

Organic Amendments General IPM / Crop Rotations Solarization Physical Removal Ploughing Flooding Potential Alternatives Reasons Potential human and environmental risks, lack of consistently demonstrable effectiveness, loss in crop quantity and quality. The ability to return a ROI of sufficient magnitude to warrant seedling production is doubtful.

Basamid Proven human and environmental risks, lack of consistently demonstrable effectiveness, loss in crop quantity and quality. The ability to return a ROI of sufficient magnitude to warrant seedling production is doubtful.

Not feasible due to sandy well drained soils. Further, nursery fields are designed to promote water movement from the fields.

Our nursery cycle ( see Appendix 1 Crop Profile for details) requires fumigation to occur just after cover crop removal. This occurs in the late fall to early spring. This period is characterized by low air/ soil temperatures and increased clouds. However, this method may have potential when included in a comprehensive IPM/ crop rotation No practical method to physically remove nutsedge tubers. Handweeding is possible but prohibitively expensive on a large scale.

Traffic over nursery soils increases soil compaction. Repeated ploughing creates a " plow layer" which inhibits root growth and decreases soil aeration.

International Paper SuperTree nurseries grow pine bareroot seedlings on a 2: 2 rotation. For a given acre, two years produce seedlings and two years produce cover crop.

Prior to producing seedlings the land is fumigated. Fumigation is needed every year for those acres just beginning a new rotation cycle.

Savannah, Georgia; Headquarters of the Nursery and Orchard Group Pine SuperTree Seedlings Name of Applicant:

Location:

Crop: International Paper For EPA Use Only ID#

Worksheet 6. Application Summary This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phase out for methyl bromide. Therefore, this worksheet cannot be claimed as CBI. General Production Information   Forestry in the United States, with an annual harvest of $ 24 billion and an employment of 1.6 million directly, 3.8 million indirectly ( Pait, 2001), is dependent on a continuous supply of high quality seedlings. Tree planting in the United States has been on a steady upward trend since the mid 1930' s, when about 140,000 acres were planted to the current ( 1998) level of over 2,600,000 acres ( Moulton and Hernandez, 1999).

  According to Moulton and Hernandez ( 1999), ninety percent of the 1,642,089,000 seedlings produced in 1998 were planted on private lands. Non industrial private forests landowners planted more acres than any other group of owners, 48% of the U. S. total. Forest industry planted 42% of the total. More trees are planted on State forest than on any other category of State and local government lands. Tree planting on the National forest are declining; acres planted in 1998 falling to the lowest level since 1960. The Southern states planted more acreage in trees than any other region ( 2,065,779), accounting for 79% of the U. S. total. More seedlings were planted in Georgia than any other state.

  Over 1.6 billion forest tree seedlings are grown annually on about 2,000 nursery acres in the U. S. Forest tree nurseries are located nationwide with 78% in the South, 17% in the West and 5% in the North. Each acre of loblolly pine nursery in the Southern U. S. has been calculated to be worth about $ 23,000.00 ( South, 1999). Total value of the 1,560 acres of southern forest tree nurseries, the majority of which are loblolly nurseries, would then be approximately $ 35.8 million.

  The seed required to plant the nursery acres are provided from intensively managed Seed Orchards and are valued from $ 65 to $ 85 per pound. Approximately 45 pounds of seed are planted per acre of nursery for a seed cost per acre of $ 3300.

  Forest tree nurseries in the U. S. use a very small percentage of the herbicides, fungicides, insecticides, and fumigants used in the U. S. With the benefits provided by pesticides, seedlings can be produced for less than 4 cents. Without pesticides, seedlings would likely cost more than 15 cents each.

  The most effective pesticide used in pest management strategies is the fumigation of the nursery beds with methyl bromide. The pending loss of this option will likely increases reliance on more Appendix 2. Figures Figure 1. Heavy yellow nutsedge infestation in non fumigated soil.

Photograph of heavy yellow nutsedge infestation on pine seedling beds. Nutsedge is bright green. Pine seedlings are lighter green and can barely be seen. Appendix 2. Figures Figure 2. Metham sodium Outgassing Damage Metham sodium outgassing damage at International Paper's SuperTree Seedling nursery at Bullard, Texas. Soil fumigated with Metham sodium can be seen at the top of the photograph. During the night, metham sodium outgassed from the soil and drifted downwind over the pine seedling beds. Trees killed from the Metham sodium are brownish red. Trees not in the Metham sodium plume remain green and alive. Appendix 3 List of References Auburn University Southern Forest Nursery Management Cooperative. 2002. Application for Critical Use Exemption of Methyl Bromide. ( Submitted to EPA, September 9, 2002)

Barnard, E. L., M. E. Kannwischer Mitchell, D. J. Mitchell, and S. W. Fraedrich. 1997. Development and field performance of slash and loblolly pine seedlings produced in fumigated nursery seedbeds and seedbeds amended with organic residues. Pp. 32 37 Carey, W. A. 1994a. Chemical alternatives to methyl bromide. In: Landis, T. D. andR. K. Dumrose, Tech. Coord., National Proceedings: Forest and Conservation Nursery Association, pp4 11 Carey, W. A. 1994b. Chemical alternatives to methyl bromide. In: Proceedings of the combined Southern/ Northeastern Forest Nursery Conference, Williamsburg, Va, pp. 4 11 Carey, W. A. 1995. Testing alternatives to methyl bromide fumigation at New Kentnursery. Auburn University Nursery Cooperative Research Rpt. 95 1, 4p.

Carey, W. A. 1996. Testing alternatives to methyl bromide fumigation at the Winona Nursery. Auburn University Nursery Cooperative Research Rpt. 96 2, 4p Carey, W. A. 1997. A single test of hot water, 1,3 D, and metham sodium as alternatives to methyl bromide. Auburn University Nursery Cooperative Research Rep. 97 7. 6p.

Carey, W. A. 1998. Alternatives to methyl bromide in forest tree nurseries. In: Landis, T. D.; Barnett, J. P., Tech. Coord. National Proceedings: forest and conservation nursery associations. Gen. Tech. Rep. SRS 25. Ashville, NC, USDA, pp 69 70.

Carey, W. A. 1999. A comparison of chloropicrin, metham sodium, and EPTC combinations as methyl bromide alternatives at three nurseries. Auburn University Nursery Cooperative Research Rpt. 99 2, 4p . Carey, W. A. 2000a. Seedling production and weed control by a potential replacement for methyl bromide at the Flint River Nursery. Auburn University Nursery Cooperative Research Rpt. 00 3, 3p.

Carey, W. A. 2000b. Seedling production by alternative fumigants, application. techniques and EPTC at the Glenville Regeneration Center. Auburn University Nursery Cooperative Research Rpt. 00 6, 4p. Appendix 4. Effect of methyl bromide fumigation on nursery and pine plantation revenue and growth for both International Paper and southeastern forestry.

Benefits of methyl bromide fumigation accrue to both pine nurseries and plantations throughout the southeast. In the nursery, the effects of a single methyl bromide fumigation last for two consecutive pine seedling crops. At International Paper, one acre of fumigated nursery soil will produce over 1.3 million pine seedlings in two years. Only 215lbs of fumigant ( 80/ 20 methyl bromide @ 350lbs/ acre) are needed to produce 1 million SuperTree seedlings or 0.21lbs per 1000 seedlings. The potential revenue for each nursery acre can approach nearly $ 55M over two years.

All chemical fumigation alternatives evaluated to date have lower seedling survival in the nursery bed compared to methyl bromide. The reduction can range from 2 to 9 seedlings per square foot ( South and Carey, 2000). A reduction by 2 to 9 seedlings per square foot in each nursery acre will result in lower annual revenues by $ 2.2M or $ 9.7M, respectively. Without methyl bromide fumigation, the potential annual revenue from all nine International Paper SuperTree nurseries could be reduced by $ 1.1MM to more than $ 5.0MM. Annual pine seedling production in the southeast is approximately 900MM ( Moulton, et al., 1995). A similar 2 to 9 seedling reduction per square foot could result in an annual revenue loss of up to $ 10.8MM across all pine seedling nurseries in the southeast.

Methyl bromide alternatives do not control weeds to any great extent. Weed competition in the nursery beds will result in lower seedling quality, particularly smaller seedling size, since the weeds are competing for the same nutrients and water as pine seedlings. With methyl bromide fumigation, International Paper SuperTree nurseries produce grade one ( Root Collar Diameter > 4.8mm) seedling crops that are sold at an average price of $ 40/ 1000 seedlings. Grade 1 seedlings grow faster in the field and have increased survival once planted than smaller seedlings ( South, et al, 2001). Many customers demand these larger seedlings so that their reforestation or ecosystem regeneration efforts are successful. A loss of methyl bromide fumigation will produce more grade 2 ( RCD > 3.8 < 4.7mm) seedlings and cull seedlings that are too small to be planted. Seedling crops with a high proportion of grade 2 and cull seedlings cannot be sold at the current average selling price. A reduction in the average selling price of just $ 5/ 1000 seedlings would result in an additional loss of nearly $ 5.3M per acre per year.

The effects of one methyl bromide fumigation at a seedling nursery can still be seen at the end of a 25 year pine plantation rotation. Pine plantations established with grade one seedlings have greater stocking ( i. e. number of