UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 Under the Clean Air Act and the international treaty to protect the ozone layer ( the Montreal Protocol on Substances that Deplete the Ozone Layer), the production and import of methyl bromide will be phased out in the United States on January 1, 2005. This application seeks information to support a U. S. request to produce and import methyl bromide for certain critical uses and circumstances beyond this 2005 phaseout date.

The information in this application will be used to review whether your use of methyl bromide is " critical" because no technically and economically feasible alternatives are available. In order to estimate the loss as a result of not having methyl bromide available, EPA needs to compare data ( yields, crop/ commodity prices, revenues and costs) for your use of methyl bromide with uses of alternative pest control regimens.

If you submit a well documented application with sound reasons why alternatives are not technically and economically feasible, the U. S. government can be a better advocate for your exemption request internationally.

OMB Control # 2060 0482 WHY IS THIS INFORMATION NEEDED? Application for Critical Use Exemption of Methyl Bromide for Use in 2005 in the United States Click on the Instructions tab located at the bottom of the screen for additional information.

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. STATE CONTACTS HOW DO I APPLY?

OMB Control # 2060 0482 States that have agreed to participate in the exemption process are listed on EPA's website at www. epa. gov/ ozone/ mbr/ cueqa. html Worksheet 4. Alternatives  Research Plans Worksheet 5. Additional Information Fumigation Cycle Climate Zone Map Worksheet 6. Application Summary 3 B. Alternatives  Pest Control Regimen Costs 3 C. Alternatives  Crop/ Commodity Yield and Revenue 3 D. Alternatives  Other Operating Costs Research Summary Worksheet Example Research Sum ( Summary) Worksheet 2 E. Methyl Bromide  Other Operating Costs for 2001 2 F. Methyl Bromide  Fixed and Overhead Costs Worksheet 3. Alternatives  Feasibility of Alternatives to Methyl Bromide 3 A. Alternatives  Technical Feasibility Please contact your local, state, regional or national commodity association and/ or state representative agency to find out if they plan on submitting an application on behalf of your commodity group.

2 B. Methyl Bromide  Crop/ Commodity Yield and Revenue 1997 2000 2 C. Methyl Bromide  Crop/ Commodity Yield and Revenue 2001 2 D. Methyl Bromide Use and Costs for 2001 INSTRUCTIONS Each worksheet number corresponds to the tab number in the electronic version of the application. Instructions specific to each worksheet are provided at the top of each sheet. A header row is included on each worksheet to include an application ID number that EPA will assign. You may either complete an electronic ( Microsoft Excel) or a printed version of the application. Please fill out each form or worksheet in the application as completely as possible. If you are completing the printed version and need extra space you may attach additional sheets as needed. Additional information may be available from your local state department of agriculture or at the sites listed below or by calling 1 800 296 1996.

Instructions Worksheet 1. Contact and Methyl Bromide Request Information Worksheet 2. Methyl Bromide  Historical Data If you anticipate that you will need methyl bromide in 2005 because you believe there are no technically and economically feasible alternatives, then you should apply for the critical use exemption. This application may be submitted either by a consortium representing multiple users or by individual users. We encourage users with similar circumstances of use to submit a single application ( for example, any number of pre plant users with similar soil, pest, and climactic conditions can submit a single application.)

If a consortium is applying for multiple methyl bromide users, the economic data should be for a representative or typical user within the consortium unless otherwise noted. If economic or technical factors ( such as size of the farm) affecting the ability of this " representative user" to use alternatives are significantly different than other users in the consortium, more than one application should be submitted to reflect these differences. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 2 A. Methyl Bromide Use 1997 2000 ( i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a significant market disruption; and ( ii) There are no technically and economically feasible alternatives available to the user that are acceptable from the standpoint of environment and health and are suitable to the crops and circumstances of the nomination  "

WHO APPLIES?

SECTIONS OF WORKBOOK The information provided by you in this application will be used to evaluate the requested methyl bromide use. The U. S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer decided that: " a use of methyl bromide should qualify as " critical" only if the nominating Party determines that: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 IS MY INFORMATION CONFIDENTIAL?

WHEN IS THE INFORMATION NEEDED?

1 800 296 1996 phone: ( 202) 564 9410 If you have general questions about this application call:

Stratospheric Ozone Hotline Methyl Bromide Critical Use Exemption Global Programs Division Global Programs Division, Mail Code 6205J 1200 Pennsylvania Ave, NW 501 3rd St. NW Washington, DC 20001 Washington, DC 20460 0001 Address for applications being sent by courier or non U. S. Postal overnight express delivery to EPA:

US Environmental Protection Agency ( When submitting an application electronically, you should also print a hard copy, sign the copy, and submit it by mail)

Mailing Address for applications being submitted by mail directly to the EPA: US Environmental Protection Agency Methyl Bromide Critical Use Exemption The applicant may assert a business confidentiality claim covering part or all of the information in the application by placing on ( or attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of notice employing language such as trade secret, proprietary, or company confidential. Allegedly confidential portions of otherwise non confidential documents should be clearly identified by the applicant, and may be submitted separately to facilitate identification and handling by EPA. If the applicant desires confidential treatment only until a certain date or until the occurrence of a certain event, the notice should so state. Information covered by a claim of confidentiality will be disclosed by EPA only to the extent, and by means of the procedures set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no claim of confidentiality accompanies the information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant. Applicants submitting their application via e mail assume respo This application must be postmarked to the EPA address below no later than 120 days after the Notice was published in the Federal Register requesting critical use exemption applications.

Electronic Address for applications:

methyl. bromide@ epa. gov HOW CAN I RECEIVE ADDITIONAL INFORMATION? WHERE DO I SUBMIT THE APPLICATION? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 1 To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select " Insert" then " worksheet"

2 A tab with the name " Sheet 1" will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor and double click the " new tab"

3 By double clicking in the tab you can now rename the worksheet to the appropriate number letter designation ( e. g., 3 A( 1), 3 A( 1)( a), etc.)

4 To move a newly inserted worksheet, simply drag the worksheet with your mouse to the desired location.

5 Once you add a new worksheet, Excel will automatically name each subsequently added worksheet as Sheet 2, Sheet 3, Sheet 4, etc  Follow the instructions above to rename the new blank worksheets as appropriate.

1 Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in color when it has been selected.

2 Select the top left corner of the worksheet ( this is the space to the left of the column A and above the row 1. You will know that the entire worksheet has been selected because the row and column marks as well as the worksheet itself will change to a different color.

3 Go to the menu line at the top of the worksheet and select " Edit" then " Copy".

4 Go to the blank worksheet where you want the copied information to be pasted.

5 Again, select the top left corner of the worksheet ( left of column A and above row 1) to select the entire worksheet.

6 Go to the menu line at the top of the worksheet and select " Edit" then " Paste"

7 Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet tab. Inserting a blank worksheet:

Note: This is the only way you can copy a worksheet and not lose portions of the text instructions.

Viewing worksheets The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to access the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the left or right will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows allow you move the worksheet tabs to the right or to the left incrementally. Copying and pasting an entire worksheet's contents into a blank worksheet:

If you would like to print all worksheets that are contained in this workbook, go to the menu bar at the top of the screen and select " File" and then " Print." Then in the section of the menu that appears called " Print what," select " Entire Workbook." EXCEL USER TIPS The two arrows on the bottom right of the screen allow you to move the worksheet that you are viewing to the right or to the left. This is useful if the viewable area of on the screen is smaller than the entire page that is in the worksheet. Worksheets are best viewed in " Page Break Preview." To select the view of the worksheet, go to the menu bar and select " View" and then " Page Break Preview." Page break preview shows only the printable area of the worksheet, with the blue lines that surround the screen indicating the edges of each page.

To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select " View" and then " Zoom".

Navigating between worksheets Printing worksheets 1.

2.

3.

4.

Light 20% Medium 50% Heavy 30%

0 to 2% X 2 to 5 % over 5%

5.

6. Specialty ( check one)

7. agronomic x 8. economic x 9. Daytime phone 10. FAX 11.

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

12. agronomic x 13. economic x 14. 15. FAX 16. James W. Wells For EPA Use Only ID#

Contact name Address Daytime phone E mail Sacramento, CA 95814 Nursery tree stock is grown in the Sacramento and San Joaquin valleys for several reasons including ideal climate, soil type, and sufficient, reliable water. These areas receive enough deep chilling hours to allow the trees to go dormant while at the same time not receive such extreme chill such that frost protection is required. The Mediterranean climate, with its long growing period and dry summer temperatures is extremely conducive to tree growth, both upper canopy and root development. Plentiful, high quality water is available for use in nurseries. Both well water and surface water are used for irrigation.

910 K Street, Suite 325 Sacramento, CA 95814 jwells@ exponent. com 916.443.3071 916.443.2793 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.

The annual rainfall in this region ranges from 10 to 25 inches per year with soil varying from light to heavy. Generally, rainfall follows soil type, meaning that the further south you go, the less rain you receive and the lighter the soils in general.

Calif. Assn. of Nurserymen Deciduous Fruit & Nut Tree CUE Soil Type:

Organic Matter: Location California's tree nursery growers are concentrated principally in the Sacramento and San Joaquin Valleys with limited production in Lake County.

Deciduous tree nursery stock includes, but is not limited to, ( 1) Fruit; i. e., peaches ( cling and freestone), prunes, nectarines, cherries, plums, apples, pears, Asian pears, apricots, ornamental pears, ornamental peach, ornamental plum, and ornamental cherry ( 2) Nut, i. e. almonds, walnuts, pistachios, pecans, and chestnuts.

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

Consortium name The Sacramento and San Joaquin valleys are generally comprised of deep ( 3 to 6 feet), well drained A and B soils which allow for good water percolation and very good root development which are necessary for the production of commercially acceptable nursery stock. Soils are generally fertile, with ideal pH and lack of salinity. Review of the Soil Conservation Service survey maps indicate that much of the soil throughout the valley is sandy loam. However, depending on their location in the valley, soils range from sandy clay loam to sandy loam to silt loam and clay loam.

Contact name Address 916.443.3071 916.443.2793 E mail Anne Downs adowns@ exponent. com 910 K Street, Suite 325 Worksheet 1. Contact and Methyl Bromide Request Information 17. 495,000 lbs.

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

19.

20.

20a.

because of the significant difference in yield per acre and price received per tree when compared to other nursery tree stock.

One nursery grower represented by the consortium grows in field exclusively for home and garden and ornamental use.

Separate worksheets are provided for this grower when applicable.

OMB Control # 2060 0482 If applying as a consortium for many users of methyl bromide, please define a representative user . Define exactly, issues such as size of the operation ( acres treated with methyl bromide for growers, cubic feet for post harvest operations, and square feet for structural applications), whether the representative user owns or rents the land or operation, intensity of methyl bromide use ( treat regularly or only when pest reaches a threshold), pest pressure, etc. Target Pest( s) or Pest Problem( s): ( Be as specific as possible about the species or classes of pests relevant to the feasibility of alternatives.) If a consortium is submitting this application, the data for question 17 and 17a. should be the total for the consortium.

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.

Are you requesting methyl bromide for additional years beyond 2005?

acres acres 2007 How much active ingredient ( ai) of methyl bromide are you requesting for 2005?

Most, but not all, growers produce a range of different species. The majority of nursery growers produce trees for commercial planting grow in the soil (" in field") and use methyl bromide. Walnuts are treated separately The representative user grows multiple species of trees; 1 year trees, 2 year trees, walnuts and seedlings. The representative grower owns most of all of the ground on which the stock is produced. Methyl bromide is used for each crop cycle.

( Nursery must be free of commercially important pests to be sold for commercial plantings). It is estimated that 95% of the deciduous nursery gr Explain why this user represents the typical user in the consortium.

Most nursery stock producers own their land. All nursery growers must treat each crop cycle to meet certification requirements. 1650 Yes. No indication that acceptable alternatives will be in place sufficient to meet certification requirements. 1650 2006 Quantity ai ( lb.) of Methyl Bromide 495,000 Area to be Treated 1650 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.

Year Nematodes, Crown Gall, Verticillium Wilt, Pythium, Fusarium, Rhizoctonia, Phytophthora If a consortium is submitting this application, the data below should be the total for the consortium.

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. For EPA Use Only ID#

Common Purslane, Lambsquarter, Little Mallo, Spurge, Watergrass, Field Bindweed, Redroot Pigweed, Nutsedge, Ragweed,

Burclover, Oxalis, Fescue, Johnson Grass, Bermuda Grass 495,000 Unit of Area Treated How much area will this be applied to? Please list units. Application for a Critical Use Exemption for Methyl Bromide California Association of Nurserymen NARRATIVE The tree nurseries in California grow a variety of tree crops including almonds, walnuts, pistachios, pecans, chestnuts, peaches ( both cling and free stone), prunes, nectarines, cherries, plums, apples, pears, Asian pears, apricots, and ornamental pear, peach, plum and cherry. About 95% of the trees are fruiting varieties sold mainly to commercial fruit producers, while the remaining 5% of the trees are flowering varieties sold for landscaping purposes. Planting stock is sold to either commercial fruit producers or home gardeners with most of the nurseries selling in both markets. However, the vast majority of nursery stock is produced for commercial planting and approximately 95% of the deciduous nursery stock produced in California is sold in California. Growers of trees for ornamental and home garden markets are also represented by the consortium.

Trees are grown in the Sacramento and San Joaquin Valleys. The annual rainfall in this region ranges from 12 to 25 inches per year with soil texture varying from light to heavy. The sandy soils tend to be in the southern end of the San Joaquin Valley, while the northern counties have heavier soils. Nurseries are located in these areas due to the fact that the climatic conditions in these areas are ideal for nursery tree production. Nursery locations receive enough deep chill hours to allow the trees to go dormant but do not receive extreme chill, so that frost control is rarely required. The Mediterranean climate, with dry summer temperatures is also conducive to tree growth, both upper canopy and root development. The deep soils ( 3 to 6 feet) allow for good water percolation and also permit the excellent root development that is necessary for production of superior nursery stock. There is plentiful, high quality water available for use in the nurseries. Well water as well as surface water is used for irrigation.

Tree nursery operations range from 40 to over 1500 acres. The median operation in the California consortium is between 200 300 acres. While some nurseries specialize in a specific tree crop, most of the nurseries grow and sell a variety of different trees. Nursery stock is grown on a cropping system that includes crop rotation or cover cropping between tree production cycles. Thus, not all of the nursery is in tree production in a given year. The tree production cycle can be anywhere from a single year to several years depending on the type of tree crop being produced. Most nurseries own the ground on which their nursery stock is produced. Very little nursery ground is leased. Actual nursery production of trees takes from one to four years in the ground depending on the type of tree being produced ( almonds take one year, walnuts at least two), and the size of tree needed ( larger trees take longer to grow). The most common cycle is for the tree crop to be in the ground for either one or two years. A typical nursery cycle ( Figure 1) starts by digging out the current tree crop ( for sale) then planting a cover crop for one or two years, followed by replanting with a tree crop. In order to prepare the soil for a tree crop, the fields are disked, deep ripped, leveled and then fumigated to meet certification standards ( see Appendix 1). The fumigation is contracted to one of two major fumigation companies. A shank applied, broadcast fumigation of 75% methyl bromide, 25% chloropicrin ( 300 lbs per acre MeBr) covered with high barrier tarp is used by the majority of nursery growers. The fumigation is carried out in September and planting begins in October. Planting can continue though January.

Figure 1. Typical Growing Cycle for Nursery Tree Production Year Season Process Year 1 October through December Dig Previous Tree Crop Year 2 February Plant Cover Crop Summer Fallow field October Plant Cover Crop Year 3 Spring Harvest Cover Crop or Incorporate as Green manure August or September Fumigate October Plant seed for rootstock October through November Plant Hard wood rootstock Year 4 April or May Cut Budwood, rootstocks are budded Summer Prune, train, Stake October If the tree is a one year tree, it is harvested October If the tree was harvested, plant cover crop Year 5 October If the tree was not harvested, it is grown for another year, then harvested Open pollinated peach seed ( which is true to type for plant vigor) is used for the majority ( 85%) of the stone fruit rootstock ( including almonds). Nurseries produce their own peach seed for the rootstock planting. The remaining 15% of the rootstock are produced on hard wood cuttings. The hard wood used as a rootstock varies somewhat but is mainly plum wood cuttings which are either stored to produce callus and then planted in the field in January or February or directly planted in the field without callus production in October or November.

In spring, the rootstock begins to grow and is ready for budding. The nurseries then decide what wood is necessary for the budding process. Budwood can originate from a variety of sources: 1) A mother block orchard maintained by the nursery. 2) Trees grown in a cooperator's field 3) Bud wood can be purchased from the clean stock program at UC Davis, Foundation Plant Material Service. 4) Budwood can be cut out of commercial orchards.

After tree rootstock is budded, the budwood begins to grow; it is pruned, trained and staked. Each of these processes requires extensive hand labor. Within the first year, each tree is handled around fifteen times for various reasons. By mid to late October, the trees are near eight feet tall and around 5/ 8 inch diameter ( the girth is measured two inches above the bud union). Trees are dug with U blades on tractors, digging 18 24 inches deep. Although the state or county biologists inspect for nematodes during the growing season, another inspection occurs at digging for nematodes and general cleanliness of stock. The trees are graded to determine quality. The grade is determined by tree diameter ( caliper), straightness of trunk, quality of roots, and disease and pest levels. Trees are bundled in fives or tens by size. These bundles are heeled into sawdust or held in cold storage until the material is shipped to the buyer. Yield is determined by the percent dig out ( the number of saleable trees versus the total number of trees planted in a field). Yield is also determined by size ( caliper) as measured by diameter of the trunk ( not height of the tree).

Irrigation is predominantly by sprinkler but can also be either furrow or drip depending on location and water availability. Water quality is generally good and quantity is currently not a problem. Trees are sprayed by tractor on a regular basis, mainly for insect pests such as thrips, mites ( spider, two spotted, etc.), and lygus as well as several other less common insects. A good fumigation gives a growth response that allows for an initial growth spurt. This growth response helps maintain a healthy tree, as a stronger tree is better able to handle the stress induced by pathogens and pests. A healthier tree consequently requires a fewer number of sprays during the season. Since stock rarely flowers in the nursery, pollen borne viruses are not considered a problem. Viruses that can be transmitted through budwood are problematic. However, many nurseries participate in a certification program conducted by the California Department of Food and Agriculture, that test for bud transmitted viruses. Powdery mildew may also require a fungicide treatment at some point in the growing season. Some nurseries use Ridomil and Alliette to suppress Phytophthora, but these chemicals do not prevent or cure the disease. Whereas, methyl bromide soil fumigation virtually eliminates, rather than suppresses soil borne pathogens such as Phytophthora.

California nurseries contend with a number of pests and diseases ( Table 1) as well as, numerous weeds ( Table 2) that must be controlled in order to produce clean nursery stock. Nursery stock is inspected by county Agricultural Commissioners under the supervision of the California Department of Food and Agriculture ( CDFA) and it must be " found free of especially injurious pests and disease symptoms" in order to qualify for a CDFA Nursery Stock Certificate for Interstate and Intrastate Shipments. California nursery regulations require specific fumigation protocols to be used in order to control nematodes, pathogens and weeds in different soil and moisture settings. If there is a history of nematodes in the field, no known history of the field, or if the soil has a moderate to heavy clay content, methyl bromide is currently the only approved fumigation. In some other cases, Telone II meets certification guidelines. If fumigation is not used in the nursery, a nematode sampling system is imposed by CDFA. The sampling procedure is cost prohibitive and, if even one nematode is found within a 100 foot grid, all trees within the grid must be destroyed resulting in the loss of one or two years work and income.

Pest or Pathogen Causal Organism Root Knot, Lesion and Stubby Root Nematodes Meloidogyne spp., Pratylenchus spp., Trichodorus sp, Xiphinema spp., Criconemelia sp.

Crown Gall Agrobacterium tumefasciens Wilt Verticillium spp., Fusarium spp.

Root Rot, Damping Off, Soft Rot Phythium sp., Rhizoctonia sp., Phytophthora spp., etc. Table 1. Pest and Insect Problems in the Tree Nurser Table 2. Common Weeds in the Tree Nursery Industry Common Name Scientific Name Common Purslane Portulaca oleracea Lambsquarter Chenopodium album Little Mallow Malva rotundifolia Spurge Euphorbia humistrata Watergrass Heteranthera dubia Field bind weed Convoulus arvensis Redroot Pigweed Amaranthus retroflexus Nutsedge Cyperus spp. Rotundus ( purple) or esculenlus ( yellow)

Ragweed Ambrosia psilostachya Burclover Medicago hispidus Oxalis Oxalis spp. Fescue Festuca megalura Johnson grass Sorghum halepense*

Burmuda Grass Cynodon dactylon *

* Considered noxious weeds by the California Department of Food and Agriculture.

The key pest of deciduous tree nursery stock is nematode. Soil must be treated to a depth of 5 feet to ensure clean stock that meets certification standards. In heavier soils, methyl bromide is the only fumigant proved to be effective at this depth. In order for Telone II to be effective, the soil cannot contain more than 12% moisture. This moisture level cannot be achieved deep in heavy soils and, depending on rainfall, may not always be achievable in medium soils. It is estimated that 30% of the deciduous tree nursery growing areas in California are in silt or clay loam soils. Of the 70% in sand or sandy loam soils, about one half will require fumigation with methyl bromide due to the inability to achieve 12% moisture in any given year. Therefore, up to 65% of the deciduous tree nursery ground may require fumigation with methyl bromide to meet certification requirements, especially in wet years. Depending on the growing area, limitations on Telone use ( Township Caps), imposed by the California Department of Pesticide Regulation may further limit the use of Telone II, the only alternative treatment that meets certification requirements.

Weed control will be a special problem if methyl bromide fumigation is not used in the nursery fields. Winter annuals, summer annuals and perennials are all problems for the nurseries. None of the current pre or post emergent herbicides can control the entire spectrum of weeds in the tree nursery crops. Combinations of several herbicides may control most of the weeds, but not all of the herbicides are labeled for nursery use. High cost of applying multiple herbicides is also a factor. In addition, there is a significant risk of plant damage or failure when using herbicide " cocktails". Pre emergent herbicides are especially problematic and most labels have special precautions for nursery use. Any chemical that affects the root growth of the trees is especially detrimental to the nursery industry as one of the characteristics used to grade product quality is root growth.

The Methyl Bromide Technical Options Committee of the United Nations Environment Programme recognized the dilemma facing the nursery industry in their 1998 report stating "  it is likely that MB will be required for some time to solve replant problems that occur in areas where the same land is used repeatedly due to limited land availability and for producing pest free propagation materials" ( UNEP 1998 Assessment of Alternatives to Methyl Bromide).

It should be noted that the total number of acres treated for this consortium may be underestimated in the tables that follow. Actual numbers are difficult to determine and 100% of the growers in the consortium did not report methyl bromide use numbers as of the date of this application. The number of pounds of methyl bromide requested and the estimated number of acres to be treated in 2005 have been adjusted upward by 10% to account for the lack of 100% reporting. Worksheet Title Instructions specific to each worksheet are located at the top of each sheet.

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

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

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

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

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

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

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

Purpose of Data: To establish a baseline estimate of crop/ commodity yields, gross revenues, and costs using methyl bromide. Worksheet 2. Methyl Bromide  Historical Use of Methyl Bromide Col A: Formulation of Methyl Bromide Col B, E, H, K: Actual Area Treated Col C, F, I, L: Actual Total lbs. ai of Methyl Bromide Applied Col D, G, J, M: Actual Average lbs. ai Applied per Area A B C D E F G H I J K L M Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area over 95% methyl bromide 470 136,300 290 448 116,330 259 629 168,781 268 456 123,272 270 75% methyl bromide, 25% chloropicrin 1140 339,000 297 1113 327,258 294 1097 321,600 293 1123 334,750 ( 298)

67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide 1610 475300 295 1561 443588 284 1726 490381 284 1579 458022 290 Comments:

OMB Control # 2060 0482 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.

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#

A C D E F Year Methyl Bromide was Applied Unit of Crop/ Commodity ( e. g., pounds, bushels) Crop/ Commodity Yield ( units per area) Price ( per unit of crop/ commodity) Revenue ( per area)

1997 11,407 trees/ acre $ 6.37 $ 56,694.45 1998 Nursery Stock 11,986 trees/ acre $ 6.24 $ 59,249.86 1999 Nursery Stock 14,669 trees/ acre $ 6.60 $ 77,842.26 2000 15,051 trees/ acre $ 6.67 $ 74,853.83 $ 0.00 Total Revenue for 1997 $ 56,694.45 Total Revenue for 1998 $ 59,249.86 Total Revenue for 1999 $ 77,842.26 Total Revenue for 2000 $ 74,853.83 Average Revenue Per Year $ 67,160.10 Comments: Nursery Stock is represented by 1 & 2 year deciduous fruit and nut trees, as well as seedlings.

OMB Control # 2060 0482 Nursery Stock B Nursery Stock 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.

Col. A: Year Col. B: Crop/ Commodity Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield 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. Year Methyl Bromide was Applied Crop/ Commodity Unit of Crop/ Commodity Crop/ Commodity Yield Price Revenue 1997 Fruit/ Nut Nursery each tree 4568 $ 8.03 36,681.04 1997 Planted back into Flowering, Shade each tree 4710 $ 8.79 41,403.98 1998 Fruit/ Nut Nursery each tree 4595 $ 8.09 37,173.55 1998 Planted back into Flowering, Shade each tree 4723 $ 8.81 41,609.63 1999 Fruit/ Nut Nursery each tree 4571 $ 8.13 37,162.23 1999 Planted back into Flowering, Shade each tree 4719 $ 8.89 41,951.91 2000 Fruit/ Nut Nursery each tree 4601 $ 8.21 37,774.21 2000 Planted back into Flowering, Shade each tree 4763 $ 8.93 42,533.59 Total Revenue for 1997 $ 78,085.02 Total Revenue for 1998 $ 78,783.18 Total Revenue for 1999 $ 79,114.14 Total Revenue for 2000 $ 80,307.80 Average Revenue Per Year $ 79,072.53 Specialty Deciduous Fruit and Nut Nursery Grower who sells exclusively to Home and Garden 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) Price ( per unite of crop/ commodity) Revenue ( per area)

Nursery Stock market 14,904 trees/ acre $ 6.24 $ 70,634.94 Total Revenue $ 70,634.94 Comments:

Nursery Stock is represented by 1 & 2 year deciduous fruit and nut trees, as well as, seedlings.

OMB Control # 2060 0482 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.

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. 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 Acre ( 2001 Average) Other MBr Costs ( e. g. tarps,

glue) per acre ( 2001 Average) Total Actual Area Treated in the Consortium Cost per Acre over 95% methyl bromide 75% methyl bromide, 25% chloropicrin 300 $ 2.58 $ 195.00 $ 665.00 1563 $ 1,634.00 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide 300 $ 2.58 $ 195.00 $ 665.00 1563 $ 1,634.00 Comments:

OMB Control # 2060 0482 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.

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#

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 Acre Typical Equipment Used Land Preparation* $ 16.00 $ 549.00 $ 565.00 Irrigating $ 50.00 $ 327.00 $ 377.00 Fertilizers** $ 312.00 $ 328.00 $ 640.00 Labor*** $ 15,435.00 Other Pest Control $ 2,353.00 Repairs/ Maint./ Shop/ Tools, etc. $ 1,178.00 General Expense $ 1,699.00 Total Custom per Area $ 0.00 User Total per area $ 22,247.00 * Includes: ripping, discing, bedding,

** Includes fertilizers, manure spreading *** Includes planting, thinning, weeding, hand defoliation, budding, tying, grafting, staking, rogueing, suckering, etc.

OMB Control # 2060 0482 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.

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. 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 Land Lease/ Land Payments $ 2,175.00 Interest $ 1,500.00 Other O. H. s ( See Comments) $ 36,073.00 Total $ 39,748.00 OMB Control # 2060 0482 Comments: Other Overhead includes, but is not limited to, office salaries, insurance, utilities, office supplies, purchase of seed and budwood, equipment and buildings, marketing, distribution, etc.

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

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

3 C Alternatives  Crop/

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

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

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

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

Worksheet 3. Alternatives  Feasibility of Alternative Pest Control Regimens Enter all alternative pesticides and pest control methods ( and associated cost and yield data) that would replace one treatment of methyl bromide throughout the fumigation cycle. See the fumigation cycle worksheet for a comprehensive definition. Use additional pages as needed.

Alternative: Study:

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

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

Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Please see Narratives In addition, EPA acknowledges that, for certain circumstances, some alternatives are not technically feasible and therefore no research has been conducted ( i. e. solarization may not be feasible in Seattle). You should look at the list of alternatives provided by the Agency and explain why they cannot be used for your crop and in your geographic area. For worksheet 3 A you must complete one worksheet for each alternative, for each research study addressed. Please number the worksheets as follows. For the same alternative, first research study, label the worksheet 3 A( 1)( a). For the same alternative, second research study, label the worksheet 3 A( 1)( b). For the first alternative, third research study, label the worksheet 3 A( 1)( c). For the second alternative, first research study, label the worksheet 3( A)( 2)( a). For the second alternative, second research study, label the worksheet 3( A)( 2)( b).

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

Please see Narratives In this worksheet, you should address why an alternative pest management strategy on the list ( see previous page) is or is not effective for your conditions. This worksheet contains 9 questions. You must complete one copy of worksheet 3 A for each research study you use to evaluate a single methyl bromide alternative. Use additional pages as need.

Summarize each of the research studies you cite in the Research Summary Worksheet.

Whether you conduct the research yourself or cite studies developed by others, it is important that the studies be conducted in a scientifically sound manner. The studies should include a description of the experimental methodology used, such as application rates, application intervals, pest pressure, weather conditions, varieties of the crop used, etc. All results should be included, regardless of outcome. You must submit copies of each study to EPA unless they are listed on the Agency website.

The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and other websites for studies that pertain to your crop and geographic area. There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible alternative pest control regimens for various crops, which can be found at http:// www. epa. gov/ ozone/ mbr or by calling 1 800 296 1996. If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet of relevant treatments should be provided for each study reviewed.

Please see Narratives Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

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

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

8.

OMB Control # 2060 0482 For EPA Use Only ID#

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

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

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

Rating for Interval:

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

Col. J: Yield A B C DE FGH I J K L MNO P Pest 1 Pest 2 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Comments:

OMB Control # 2060 0482 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.

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)

[ Insert Alternative] [ Insert Study Title] Alternative: 1,3 D, 1,3 D + Metam Sodium, 1,3 D + Basamid Worksheet 3A.

Alternative: 1,3 D 1,3 D + Chloropicrin 1,3 D + Chloropicrin + Metam Sodium 1,3 D + Metam Sodium Studies: Please refer to Reference List.

Section I. 1 There are township caps for 1,3 D ( 5, 10). Several of the counties where tree nursery crops are grown would be affected by the caps ( 5).

Section II.

1 Studies 1 13 and 23 are not on EPA website, Studies 14 22 and 24 27 are on the EPA website. 2 Author: various, as stated above 3 Publication date: various as above. 4 Multiple locations as per studies above. 5 1,3 D, and 1,3 D combinations 6 Yield was studied for fruit/ nut trees in Study # 2. 7 Effectiveness of 1,3 D and 1,3 D combinations compared to Methyl Bromide a. Control of Nematodes. In tree nursery production, studies have shown control of nematode is necessary at the 99.9% level in order to have nursery stock free of nematodes ( 1, 2, 3) as mandated in the California Department of Food and Agriculture certification program and California Nursery Stock regulations. Since tree crops are deep rooted, the control of nematodes needs to be at least five feet deep. While 1,3 D has been shown to control nematodes in shallow, light soils in some instances ( 16), this is not always the case ( 21). 1,3 D does not control nematodes effectively unless the soil moisture is less than 12%. Soils this dry are difficult to achieve at a depth of five feet ( 1,2,3), in heavier soils, or where applications must be made after in heavy rainfall years before the moisture dissipates. Studies showed that soils in Davis, California that had not been irrigated for two years still exceeded 12% moisture at the four foot level ( 1). Nematodes at multiple sites were not controlled in deeper soils with 1,3 D alone or 1,3 D combinations ( 1, 2, 3) for some of the heavier soil types utilized by tree nurseries.

b. Control of Pathogens. Pathogens must be controlled in nursery stock in order to prevent the spread of a pathogen through out the area receiving the nursery stock. While 1,3 D was effective in controlling Phytophthora cactorum to a depth of 24 inches ( equivalent to methyl bromide) in some situations ( 14), this is not always the case ( 4, 14). 1,3 D has not been as effective as methyl bromide in controlling Verticillium dahliae in strawberry nursery fields ( 6, 14) but has provided adequate control in fruit production fields ( 17). The 1,3 D and 1,3 D combinations have been compared to methyl bromide for control of Oak Root Fungus in commercial and nursery tree crops. 1,3 D alone only gave control in the top four feet while methyl bromide gave control at a deeper level and that control continued to be effective in a production field for over six years. Split applications of 1,3 D or 1,3 D in combination with metam sodium or basamid did not improve the effectiveness of 1,3 D against Oak Rood Fungus, Armillaria mellea, and still only gave control at a depth of four feet or less.

c. Weed Control. 1,3 D ( alone or in combination) has shown good weed control in some situations ( 7, 8, 9, 14) especially with the use of VIF tarp vs. standard tarp. Weed populations following a methyl bromide fumigation were lower after a year than weed populations following a 1,3 D ( or 1,3 D combination) treatment ( 2). The species of weeds also shifted from predominately clovers ( after methyl bromine) to predominately grasses and chickweed ( after 1,3 D).

d. Effect on yield. There were no significant differences in yield for first and second year tree growth in trials were yield was measured ( 2,3). However, there has been some phytotoxic affect associated with 1,3 D ( 18, 21) for certain commodities.

e. Movement of 1,3 D in the Soil Profile. 1,3 D can either be shank or drip applied. Shank applied material had a low rate of success in moving material deep in the soil in heavier soil types ( 3). Either drip or drench applied 1,3 D reduces volatilization of the product ( 3, 19). However, high amounts of water may be necessary to effectively move the material through the soil profile ( 3, 19, 20). Further research to design equipment necessary for efficient and economic placement of material in deep soil profiles needs to be conducted.

Conclusions. In all the above studies where 1,3 D has been shown to give effective control, high rates of the product were used. 1,3 D or 1,3 D in combination is being used successfully in some California nurseries ( grower communication). Areas where 1,3 D is replacing methyl bromide tend to have lighter soils and drier climates. Even so, in heavy rainfall years, growers report difficulty in achieving the requisite 12% or less moisture ( grower communication). Weed problems and poor performing trees have been reported in one nursery using 1,3 D in 2001, although, since this was not a controlled trial other factors could not be ruled out as contributing to the performance problem. However, weeds continue to be a problem when 1,3 D is used on a large scale even in combination with Vapam or Basamid ( grower communications). Labeled soil moisture requirements are an impediment to the herbicidal activity of MITC generators ( 2, M. McKenry personal communication). Difficulties in applying the material in sub optimal conditions and poor performance in medium and heavy soils restrict the use of this compound as a viable alternative in many cases. Further studies with multiple rates and different application methods and tarp types are needed to see if the overall performance of 1,3 D across a wider environmental range can be improved. Restrictions on the total amount of 1,3 D that can be used on all crops in a given area ( Township Caps), also may significantly limit the utility of 1,3 D as a methyl bromide replacement for deciduous nursery in some locations ( 5, 10).

Reference List:

1) Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries. Michael McKenry, Report to DPR 2000. 2) Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries. Michael McKenry, Report to DPR 2001. 3) The Replant Problem and Its Management. Michael McKenry, Catalina Publishing, 1999. 4) Strategies for Management of Phytophthora on California Strawberries, G. T. Browne, Report to California Strawberry Commission, March 19, 2002 5) Impact of Township Caps on 1,3 D Use in California. Tom Trout. California Strawberry Commission Pink Sheet June 11, 2001. 6) Management of Verticillium Wilt in Strawberry Nurseries. Tom Gordon. Report to California Strawberry Commission. 1999 and 2000. 7) Weeding Time Estimates in Commercial Scale Shank Applied Fumigant Evaluations at Oxnard, CA. S. Fennimore et al. Report to California Strawberry Commission. 8) Weeding Time Estimates in Commercial Scale Drip Applied Fumigant Evaluations at Oxnard, CA. S. Fennimore et al. Report to California Strawberry Commission. 9) Weed Control Efficacy of Alternative Fumigants at Oxnard, CA. S. Fennimore et al. Report to California Strawberry Commission. 10) California Management Plan: 1, 3 Dichloropropene. California Department of Pesticide Regulation. January 30, 2002 11) Alternative fumigant efficacy on Weeds in Strawberry Nursery and Fruiting Fields. S. Fennimore et al. Report to California Strawberry Commission. 12) Weeding time estimates in commercial scale fumigant evaluations at Oxnard, Ca. S. Fennimore, et al. Report to California Strawberry Commission. 13) Evaluation of the Weed Control Efficacy of Chloropicrin in Strawberry, Milt Haar et al. Report to California Strawberry Commission. 2000. 14) Alternative fumigants for control of soil pests: strawberry as a model system. S. Fennimore and J. Duniway. On the EPA Website. 15) Strawberry Response to Fumigants applied by Drip Irrigation Systems. Tom Trout and Husein Ajwa. On the EPA Website. 16) Replacing Methyl Bromide for Preplant Soil Fumigation with 1,3 D, Chloropicrin and Tilliam Combination Treatments. U. S. EPA. 17) Chemical and Cultural Alternatives to Methyl Bromide Fumigation of Soil for Strawberry. J. M. Duniway. On the EPA Website. 18) Chemical Alternatives to Methyl Bromide for Strawberry Production in North Carolina. Ge. E. Fernandez. On the EPA Website. 19) Distribution of Drip Applied Fumigants Under Various Conditions. H. Ajwa and T. Trout. On the EPA Website. 20) Strawberry Growth and Yield with Three Years of Drip Fumigation. H. Ajwa and T. Trout. On the EPA Website. 21) 1,2, D, A valid alternative to methyl bromide for the control of plant parasitic nematodes. F. Lamberti, Bari, Italy. On the EPA Website. 22) Chloropicrin application in Italy by soil injection and drip irrigation: Effect against soil borne fungal pathogen. A. Minuto, et al. On the EPA Website. 23) Approved Treatment and Handling Procedures to Ensure Against Nematode Pest Infestation of Nursery Stock. California Department of Food and Agriculture. 24) Metam Sodium as an Alternative to Methyl Bromide for Fruit and Vegetable Production. U. S. EPA. On the EPA Website. 25) Metam Sodium as an Alternative to Methyl Bromide for Fruit and Vegetable Production and Orchard Replanting. U. S. EPA. On the EPA Website. 26) Basamid for the Forest Nursery Industry. U. S. EPA. On the EPA Website. 27) Options to Methyl Bromide for the Control of Soil Borne Disease and Pests in California. A. Braun and D. Supkoff. July 1994. Pest Management Analysis and Planning Program. California Department of Pesticide Regulation. Worksheet 3A.

Alternative: Chloropicrin Studies: Please refer to Reference List in worksheet for 1,3 D.

Section I. 1 Chloropicrin alone is not approved as a stand alone fumigant by the California Department of Food and Agriculture for certified nursery crops ( 23) for either nematodes or soil borne pathogens.

Section II. 1 Studies 1 13 and 23 are not on EPA website, Studies 14 22 and 24 27 are on the EPA website. 2 Author: various, as stated above 3 Publication date: various as above. 4 Multiple locations as per studies above 5 Chloropicrin is being compared to methyl bromide. 6 Yield was specifically studied using only Chloropicrin for fruit/ nut trees. 7 Effectiveness of Chloropicrin compared to Methyl Bromide a. Control of Nematodes. Chloropicrin is not approved as a nematocide by the California Department of Food and Agriculture for tree nurseries in the certification program ( 23). Since it is necessary for the nurseries to be participants in the certification program in order to maintain their customer base, they are unable to use chloropicrin as a stand alone fumigant. Chloropicrin does not provide adequate control of nematodes in nurseries situations ( 3, 14, 15).

b. Control of Pathogens. Chloropicrin does not provide consistent control of soil borne pathogens: Verticillium dahliae ( 14, 15, 22), Rhizoctonia solani ( 22), Fusarium melonis ( 22) and F. lycopersici ( 22) Phytophthora cactorum ( 4, 15). Chloropicrin did provide control of Pythium ultimum in nursery fields ( 14).

c. Weed Control. Neither Chloropicrin nor methyl bromide controlled mallow ( 13) and very high levels of chloropicrin were needed to control purslane and knotweed ( 13). Chloropicrin EC was weak for weed control in comparison with either methyl bromide or 1,3 D. Therefore, the associated weeding times and cost of weeding for Chloropicrin was significantly higher ( 8). Conclusions:

Because Chloropicrin is not approved as a stand alone fumigant for nematode or soil borne pathogen control, it is not used commercially as an alternative to methyl bromide. Although this compound has been included in many studies examining alternatives to Methyl Bromide, it does not appear to be useful as a stand alone alternative. It does appear to be useful in combination with Methyl Bromide and in combination with 1,3 D. Worksheet 3A.

Alternative: Metam Sodium Studies: Studies: Please refer to Reference List in 1,3 D worksheet.

Section I. 1 While there are no township caps associated with metam sodium, there is a problem with consistent application of this material. Metam sodium moves in water and does not fumigate soil that is not within the wetted front ( 3). Any pockets of saturated soil, or near saturated soil in the profile, will not receive an effective dose of fumigant. Metam sodium is not approved by the California Department of Food and Agriculture as a fumigant for the nursery certification process ( 23).

Section II. 1 Studies 1 13 and 23 are not on EPA website, Studies 14 22 and 24 27 are on the EPA website. 2 Author: various, as stated above 3 Publication date: various as above. 4 Multiple locations as per studies above 5 Metam sodium is being compared to Methyl Bromide. 6 Yield was not studied for Metam Sodium as a stand alone fumigant in fruit/ nut trees. 7 Effectiveness of Metam Sodium to Methyl Bromide a. Control of Nematodes. While nematode control has been achieved in various commodity crops ( 24, 25), most of the work was done in shallower soils. Metam sodium was not as effective as 1,3 D ( there was not a methyl bromide control in the study) for control of rootknot nematode and Heterodera carotae ( 21). Metam sodium alone does not provide the long term, deep control of nematodes needed by nursery growers ( 3). Rates of metam sodium needed to move the material five feet down in the soil profile result in phytotoxic effects ( 3).

b. Control of Pathogens. When digging the nursery stock, root material is left in the soil. Depending on soil type and environmental conditions, these roots may remain in the soil up to several years. Because of this, it is necessary to have a fumigant that can penetrate the roots and kill pathogens such as Oak Root Fungus ( Armillaria mellea) and nematodes residing in the roots. Metam sodium does not effectively penetrate root tissue ( 3).

c. Weed Control. Metam sodium has been effective in controlling chickweed, purslane and knotweed but is not effective for mallow or fillare ( communication from S. Fennimore). If properly applied, Metam sodium was shown to be 95% effective in controlling weeds in the top few inches of soil in orchards ( 3).

d. Movement in the Soil Profile. Movement is limited in the soil to the wetted front of the fumigation zone ( 3). Due to limited movement, there may be pockets of soil that are not fumigated. In heavier soils, or years with higher rainfall levels, this can be a particular problem.

Conclusions. Metam sodium alone is not a feasible alternative for methyl bromide in deciduous nursery production. In addition, the California Department of Food and Agriculture does not approve the use of Metam sodium as a standalone fumigant in the Nursery Certification Program. Some growers are using this compound, but it is always used in combination with other materials. Worksheet 3A.

Alternative: Basamid Studies: See Reference List in worksheet for 1,3 D.

Section I. 1 There are no town ship caps for Basamid. Basamid is not approved by the California Department of Food and Agriculture as a stand alone fumigant for use in the nursery certification program ( 23).

Section II. 1 All studies are referenced in the 3A worksheet for the 1,3 D chemical alternatives. 2 Author: various, as stated above 3 Publication date: various 4 Multiple locations as per studies above 5 Alternative is Basamid. 6 Yield was not studied for fruit/ nut trees. 7 Effectiveness of Basamid as compared to Methyl Bromide a. Due to the difficulty with uniform application of this material, effective control of nematodes and soil borne pathogens is not possible ( 3).

b. Movement of in the Soil Profile. Uniform application of the granular material, which contains various grain sizes, is difficult. Further studies on dissolution rate of the granules as well as methods to optimize penetration of the material into soils need to be conducted. Worksheet 3A.

Alternative: Non Chemical Alternatives   Biofumigation, Solarization, Steam Heat, BioControl, Cover crop/ Mulch, Crop Rotation, Flood and Water Management, Graft Resistant Rootstocks, Organic Amendments, Physical Removal/ Sanitation, Resistant Cultivars, Soilless culture, Substrates/ plug plants.

Studies: Please refer to Reference List in worksheet for 1,3 D.

None of the non chemical alternatives is approved by the California Department of Food and Agriculture for use in the certification program ( 23). California regulations require stock be free of nematodes in order to ship the material from a nursery to a buyer. None of the non chemical alternatives can achieve the 99.9% nematode free stock needed to meet this requirement. Since the buyers of the nursery stock for commercial plantings require a large root biomass in the purchased product to produce a successful grove of trees ( 3), soilless culture ( container trees) is not an option that can meet the demand of the consumer. Although some of the non chemical alternatives are used by growers as part of integrated systems ( cover crop, crop rotation, water management, graft resistant rootstocks) in combination with chemical fumigation, none of these alternatives is a stand alone replacement for chemical fumigation. 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 DE F GH I J K L M NO P Sting nematode Stunt nematode 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 Interval 3 1 Untreated  pre trt 700 3 wks 700 6 wks 707 pre trt 100 3 wks 111 6 wks 109 5,000 2 Methyl Bromide 300 gal. pre trt 669 3 wks 221 6 wks 120 pre trt 98 3 wks 77 6 wks 36 8,000 3 Iodo methane 150 gal. pre trt 675 3 wks 250 6 wks 125 pre trt 111 3 wks 35 6 wks 32 7,580 Comments:

Ratings are for nematodes per gram of soil 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.

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

Enter the intervals ( days, weeks or months) that the rating was taken for each treatment in Columns D, F, H, J, L, and N. 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. For this example, insert " pre treatment" in the " Interval 1" column , insert " 3 weeks" in the " Interval 2"

column, and insert " 6 weeks" in the " Interval 3" column."

In columns E, G, I, K, M, and O insert the rating ( the level of control provided for a specific pest) for each interval for each treatment described. In this example, for the methyl bromide treatment for sting nematode enter 669 for the " Rating for Interval 1", 221 for the " Rating for Interval 2", and 120 for the " Rating for Interval 3." In the comments section below describe the rating scale ( e. g.,

nematodes per gram of soil, number of colony forming units per gram of soil, etc.).

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.

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.

Example Research Summary Table Example Provide one summary table for each study being described. 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)

Telone Nematodes 1,3 D custom $ 2,300.00 Metam Sodium Weeds MITC application $ 0.00 $ 0.00 Telone Nematodes 1,3 D custom $ 1,900.00 Chloropicrin Pathogens Chloropicrin application $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total $ 2,100.00 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 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 the same product.

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

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

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

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

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

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

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

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

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

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

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 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)

Product X Pest Y, Pest Z Chemical D,

Chemical F 90% Chemical D,

10% Chemical F 250 278 lbs $ 10.00 $ 20.00 0 25 1 $ 2,800.00 Product U Pest V, Pest Y Chemical C 100% 150 200 gal $ 5.00 $ 20.00 10 25 2 $ 2,060.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Control P Pest J, Pest K $ 500.00 Total $ 5,360.00 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 Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: Product X 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.

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

Control P is done 2 times per year according to ____ methods.

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

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

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

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

Col. B: Price Factors Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Col. E: Price Col. F: Gross Revenue A B C D E F Crop/ Commodity Price Factors ( grade, time, market) Unit of Crop/ Commodity ( e. g., pounds, bushels) Crop/ Commodity Yield ( Units per area) Price ( per unit of crop/ commodity) Revenue ( per area) $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Revenue see comments Comments:

No direct information available on yield with alternative regimes OMB Control # 2060 0482 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. Post harvest 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.

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

Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternative: Telone Combinations 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 section below.

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. For EPA Use Only ID#

Col. A: Operation or Cost Item Col. B: Custom Operation Cost Col. C, D, E: Costs per Area Col. F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area Weed Control 1295 $ 1,295.00 hand weeding $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Custom per Area $ 0.00 User Total per area $ 1,295.00 Comments:

With the use of Telone Combinations, weed populations increased which resulted in increased hand labor to remove weeds.

OMB Control # 2060 0482 Typical Equipment Used Operation Done by User Telone Combinations 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 .

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. 1. Name of study:

2. Researcher( s):

3. Your test is planned for:

4. Location:

5. Name of alternative to be tested:

6. Yes No 7.

OMB Control # 2060 0482 See attached sheet 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.) Will crop yield be measured in the study? For EPA Use Only ID#

Worksheet 4. Alternatives  Future Research Plans Research Funded by the Fruit Tree, Nut Tree, and Grapevine Improvement Advisory Board ( IAB) from 1999 through 2002*

Year Proposal Researcher Affiliation Amount Approved 1991 1998 Alternatives to Methyl Bbromide McKenry UC Kearney Ag $ 50,000 2000 2001 Alternatives to Methyl bromide on stone fruit and walnut Eayre USDA $ 40,000 2001 2002 Plant Growth Promoting Rhizobacteria in Walnut and Prunus Nurseries and Orchards Eayre USDA $ 20,000 1999 2000 Epidemilogy and control of crown gall on walnuts Epstein UC $ 20,000 2000 2001 Epidemilogy and control of crown gall on walnuts Epstein UC $ 20,000 2001 2002 Epidemilogy and control of crown gall on walnuts Epstein UC $ 19,298 1999 2000 Evaluation of alternatives to methyl bromide for fumigation at commercial fruit and nut tree nurseries McKenry UC Kearney Ag $ 27,000 2000 2001 Evaluation of alternatives to methyl bromide for fumigation at commercial fruit and nut tree nurseries McKenry UC Kearney Ag $ 27,000 2001 2002 Evaluation of alternatives to methyl bromide for fumigation at commercial fruit and nut tree nurseries McKenry UC Kearne Ag $ 27,000 1999 2000 Evaluation of broccoli residue for nematode control on nursery fruit and nut tree rootstocks and grapevines Westerdahl UC $ 20,095 2001 2002 Evaluation of broccoli residue for nematode control on nursery fruit and nut tree rootstocks and grapevines Westerdahl UC $ 20,095 2001 2002 Tarped metam sodium as a replacement for methyl bromide for nematode control on nursery fruit and nut tree rootstocks and grapevines under northern California nursery conditions Westerdahl UC $ 26,679 2000 2001 Evaluation of alternatives to methyl bromide for grapevine nurseries Schneider $ 55,650 2001 2002 Evaluation of alternatives to methyl bromide for grapevine nurseries Schneider $ 55,650 Total Spent between 1999 2000 and 2001 2002 $ 378,467 Note: This is the amount of funding by the IAB, there is an equal amount of funding the researcher's institute. Research Funded by the Fruit Tree, Nut Tree, and Grapevine Improvement Advisory Board ( IAB) for the 2002 2003 Production Year Proposal Researcher Affiliation Amount Requested Amount Approved Location Alternative to be Tested Crop yield Measured?

Investigation of the Etiology, Epidemiology and Control of Crown Gall on Walnuts,

and the Detection of its Pathogenic Agents Epstein/ Mircetich Joint with California Walnut Board, UC $ 38,395 $ 38,395 no Propagation and Retesting of Walnut Rootstock Genotypes Putatively Resistant to Phytophthora, Crown Gall and Nematodes Hackett California Walnut Board, UC $ 43,408 $ 43,408 UC Davis,

UC Kearney Ag Center resistant rootstock yes Four Possible Approaches to Treatment of Finer Textured Nursery Soils after 2005 McKenry UC $ 30,000 $ 30,000 UC Davis,

UC Kearney Ag Center Chloropicrin, methyl iodine, high rates of Telone with multiple tarps yes Development of Molecular Assay for Identification of Plant Parasitic Nematode Species in Soil Samples Williamson $ 33,057 $ 33,057 Bacteriophage for Control of Crown Gall Eayre USDA $ 30,000 $ 30,000 biocontrol no Evaluation of Alternatives to Methyl Bromide for Grapevie nurseries Schneider USDA $ 59,135 $ 59,135 Iodomethane, Telone+ Metam Sodium, Sodium Asize, Propargyl Bromide, Chloropicrin all with different application methods Tarped metam Sodium as a Replacement for Methyl Bromide for Namatode Control on Nursery Fruit and Nut Tree Rootstocks and Grapevines under Northern California Nursery Conditions Westerdahl UC Davis $ 28,007 $ 28,007 Shank injected Metam Sodium with and with out tarps,

Chloropicrin, Telone II no $ 262,002 $ 262,002 Note: This is the amount of funding by the IAB, there is a equal amount of funding from the researchers institute. 1.

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

x Virtually impermeable film ( VIF)

x 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 25 50 acres 50 100 acres 100 200 acres 200 400 acres over 400 acres Worksheet 5. Additional Information For EPA Use Only ID#

1 1 Do you anticipate that you will have any methyl bromide in storage on January 1, 2005? deep injection 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)? How will you minimize your use and/ or emissions of methyl bromide?

Integrated pest management Do you have access to recycled methyl bromide? Some growers are using 1,3 D/ chloropicrin combinations where soil and moisture conditions allow. % Chloropicrin in the MB/ pic formulation has been increased re MB 378,467 1 3 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. 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.

6 over 160,000 sq. ft.

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

Signature Date Print Name Title Signature Date Print Name Title OMB Control # 2060 0482 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 needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintainin 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 resp 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 colle 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 brom 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. 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)

James W. Wells Consultant James W. Wells Consultant Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered " critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree 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. For EPA Use Only ID# re relative to es the time ining spond to a ollection of omide. An 1. 2. 3. 4. Pounds of Methyl Bromide Requested 2005 495,000 5. Area Treated with Methyl Bromide 2005 1,650 acres units 6. If methyl bromide is requested for additional years, reason for request:

2006 495,000 lbs. Area Treated 1,650 acres units 2007 495,000 lbs. Area Treated 1,650 acres units Not Technically Feasible Not Economically Feasible X Trees not yet harvested by grower who tried this X X X X X X 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.

Name of Applicant:

Location:

Crop: California Association of Nurserymen Deciduous Fruit & Nut Tree Peaches, Prunes, Nectarines, Cherries, Plums, Apples, Pears, Asian Pears, Apricots, Ornamental Peach, Ornamental Plum,

Ornamental Cherry, Almonds, Walnuts, Pistachios, Pecans, Chestnuts.

San Joaquin Valley & Sacramento Valley of Californa 1,3 D and metam sodium can give phytotoxic effects if applied at the same time. Sequential applications require a long period of time for the fumigation process. This combination does not provide adequate nematode and pathogen control.

This material does not control weeds. 1,3 D does not control pathogens or nematodes deeply enough in the soil profile to keep the pathogens and nematodes out of the rooting zone of nursery trees. There are township caps associated with this material.

Reasons Even in association with chloropicrin, 1,3 D does not control weeds. 1,3 D/ chloropicrin combinations do not control pathogens or nematodes deep enough in soil profile. This is a very expensive mix.

1,3 D in association with chloropicrin and metam sodium have not been shown to be effective deep enough in the soil profile. This is a prohibitively expensive mix.

1,3 D, Chloropicrin 1,3 D, Chloropicrin, Metam Sodium Chloropicrin is an expensive product and large amounts are needed if applied alone. The efficacy of this material is inconsistent for control of pathogens.

Metam Sodium only moves in water and does not fumigate soil that is not within the wetted soil front. Control of pathogens,

nematodes and weeds has been inconsistent with this material.

There is no indication that acceptable alternatives will be in place sufficient to meet state nursery certification requirements.

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.

Chloropicrin Metam Sodium 1,3 D, Metam Sodium Basamid Potential Alternatives 1,3 D Basamid is difficult to apply uniformly and thus does not provide even control. Fumigation cycle:

Year: Comparable data:

2 year example:

Other beneficiary example Crop cycle change example: If a methyl bromide fumigation is made every 2 years, then the 2001 fumigation cycle began in 2001 and would end in 2003. The data should cover the methyl bromide costs and usage for the methyl bromide fumigation made in 2001, and all yields and revenues received and other costs incurred during the 2 year period. To be comparable, the data on alternatives should cover a similar 2 year period beginning in 2005 beginning at the same time of year when a methyl bromide fumigation would be made. The data should cover all methyl bromide alternatives used,

and all yields and revenues received during that 2 year interval. Other pest control and other costs would only need to be provided for that interval if they would change from what they were with methyl bromide.

If someone other than the applicant benefits from a methyl bromide fumigation, you should comment on these benefits if you do not have quantitative data for the entire fumigation cycle.

For example, if a rotational crop in the second year benefits from a methyl bromide fumigation a year earlier, but there is quantitative data only on the first crop, then the data on the alternatives should cover only the first crop, and the benefits of methyl bromide and the additional pesticides that would have to be used on the rotational crop should be discussed in the comments sections.

If in a one year interval, methyl bromide is applied, tomatoes are grown and harvested followed by peppers, then the fumigation cycle would be one year including the tomatoes and peppers. If,

however, without methyl bromide, it is not possible to follow tomatoes with peppers in the same one year interval, then the alternative data on pesticides, costs, yields, and revenues should just cover tomatoes. The loss of profit from not being able to grow peppers with the alternatives would be part of the loss from not having methyl bromide.

Fumigation Cycle Definitions:

In order to compare revenues and costs with and without methyl bromide, data on alternatives for pest control, yields, revenues, and costs must be for the same time interval as the methyl bromide fumigation cycle. If, however, quantitative data, is not available for the entire fumigation cycle,

then to be comparable, the quantitative data for the alternatives should cover the same portion of the fumigation cycle as the quantitative data for methyl bromide, and the rest of the cycle should be discussed in the comments sections.

If a fumigation cycle overlaps more than one calendar year, " year" refers to the calendar year when methyl bromide is applied ( or the beginning of the cycle).

The period of time between methyl bromide fumigations.