For EPA Use Only ID # ______________ SECTOR _________________________

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, crops/ crop groupings, 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.

EPA Form # 7620 18a Pre Plant 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. The information contained in this application is critical to process and assess the need for methyl bromide. Filling out this application in its entirety will bolster the U. S. government's ability to strengthen the nomination package for the international review boards. OMB Control # 2060 0482 WHY IS THIS INFORMATION NEEDED? 2003 Application for Critical Use Exemption of Methyl Bromide for Pre Plant Use in 2005 and beyond in the United States Click on the Instructions tab located at the bottom of the screen for additional information. WHO APPLIES?

STATE CONTACTS HOW DO I APPLY?

IS MY INFORMATION CONFIDENTIAL?

WHEN IS THE INFORMATION NEEDED?

Mailing Address for applications being submitted by mail directly to the EPA: Address for applications being sent by courier or non U. S. Postal overnight express delivery to the EPA:

US Environmental Protection Agency US Environmental Protection Agency Methyl Bromide Critical Use Exemption Methyl Bromide Critical Use Exemption Office of Pesticide Programs Office of Pesticide Programs Mail Code 7503C 911 Bay, BEAD 1200 Pennsylvania Ave, NW 1921 Jefferson Davis Highway Washington, DC 20460 Arlington, VA 22202 Telephone: ( 703) 308 8200 INSTRUCTIONS The information provided by you in this application will be used to evaluate the requested methyl bromide use. The U. S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer decided that: " a use of methyl bromide should qualify as " critical" only if the nominating Party determines that: ( i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a significant market disruption; and ( ii) There are no technically and economically feasible alternatives available to the user that are acceptable from the standpoint of environment and health and are suitable to the crops and circumstances of the nomination  "

WHERE DO I SUBMIT THE APPLICATION?

HOW CAN I RECEIVE ADDITIONAL INFORMATION? Electronic Address for applications: methyl. bromide@ epa. gov ( When submitting an application electronically, you should also print a hard copy, sign it, and submit it by mail)

If you have general questions about this application call:

Stratospheric Ozone Hotline 1 800 296 1996 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.

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.

States that have agreed to participate in the exemption process are listed on EPA's website at www. epa. gov/ ozone/ mbr/ cueqa. html 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. 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 responsibility for the confidentiality of the electronic message transmission.

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. OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant SECTIONS OF WORKBOOK 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.

EXCEL USER TIPS Inserting a blank worksheet:

1. To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select " Insert" then " worksheet" Worksheet 3. Alternatives Worksheet 2 A. Methyl Bromide  Pest and Crop Information Worksheet 2 B. Methyl Bromide  Historical Use for 1997  2002 Worksheet 2 C. Methyl Bromide  Crop/ Crop Grouping Yield & Gross Revenue for 2000  2002 Worksheet 2. Methyl Bromide 2. A tab with the name " Sheet 1" will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor and double click the " new tab" 3. By double clicking in the tab you can now rename the worksheet to the appropriate number letter designation ( e. g., 3 A( 1), 3 A( 1)( a), etc.)

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

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

Copying and pasting an entire worksheet's contents into a blank worksheet:

1. Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in color when it has been selected. Worksheet 1. Contact and Methyl Bromide Request Information Worksheet 2 D( 1& 2). Methyl Bromide  Baseline  Operating Costs for 2002 ( Annual or Perennial)

Worksheet 5. Application Summary Definitions Climate Zone Map Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Worksheet 3 B( 1& 2). Alternatives  Changes in Operating Costs ( Annual or Perennial) Worksheet 4. Future Research Plans Instructions 2. Select the top left corner of the worksheet ( this is the space to the left of column A and above row 1. You will know that the entire worksheet has been selected because the row and column marks as well as the worksheet itself Note: This is the only way you can copy a worksheet and not lose portions of the text instructions.

Viewing worksheets 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. 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" OMB Control # 2060 0482 Printing worksheets To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select " View" and then " Zoom".

Navigating between worksheets The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to access the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the left or right will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows allow you move the worksheet tabs to the right or to the left incrementally. 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 7. Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet tab. EPA Form # 7620 18a Pre Plant 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." Yes No x x Cell Fax x Cell Fax Address 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.

Is this information Confidential Business Information?

B 18 Food Safety and Toxicology Bldg. Agronomic Michigan State University East Lansing, MI 48824 Economic 517 663 5608 Salisbury Management Services, Inc. 2487 S. Michigan, P. O. Box 10 Eaton Rapids, MI 48827 0010 Agronomic Economic Date Title Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered " critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree now to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application. Print Name I certify that all information contained in this document is factual to the best of my knowledge.

Signature Title Signature Date Print Name If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.

Applicant Name Primary Contact Contact Name ( Check One) Specialty Diane Brown Rytlewski Michigan's Field Grown Herbaceous Perennial Growers E mail Address Address Daytime Phone 517 663 5600 bdartt@ salisburymanagment. com Barbara Dartt 517 432 0480 rytlews1@ msu. edu 517 353 4995 Specialty Daytime Phone E mail Address Alternate Contact Contact Name OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant 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. 1. Location 2. Crop/ Crop Grouping 3.

6 3 2 4. Climate Zone Zones: ( check all that apply)

5. Soil Type & Organic Matter Light x Medium x Heavy x 0 to 2 % x 2 to 5 % x over 5 % x 6. Yes x Pounds 213,477 No 7. Yes CUE #

No x 8.

Year 2005 Acres 2006 Acres 2007 Acres 9.

10.

11. Yes Lbs No x 12. Yes Lbs No x Please explain why methyl bromide is being requested. ( Insert number or percentage of users in each category) 0  25 acres lbs. 35 lbs. What is the amount of methyl bromide being requested by this application ? ( Do NOT include QPS amounts)

10,500 Has this applicant previously applied for Critical Use Exemption of methyl bromide? Range of acres farmed by growers included in this application Is this applicant eligible for Quarantine and Preshipment ( QPS) uses of methyl bromide? 100  200 acres 200  400 acres 25  50 acres 50  100 acres Michigan, and one grower in Illinois herbaceous perennials two year seeded, three year transplant, two year transplant 30 ( Indicate the soil type and percent organic matter where methyl bromide would be applied.)

Soil Type:

Organic Matter:

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

Do you anticipate that you will have any methyl bromide in storage after January 1, 2005? to control weeds, nematodes and soil borne plant pathogens in field grown herbaceous perennials Do you have access to recycled methyl bromide?

If yes, please specify amount ( in pounds). If yes, please specify amount ( in pounds). 20 Worksheet 1. Contact and Methyl Bromide Request Information Total Pounds Active Ingredient ( a. i.) of Methyl Bromide 12388 Total Area to be Treated 2 1 ( check all that apply) ( Indicate the climate zone designation by reviewing the U. S. climate zone map located at the end of this workbook or online at http:// www. usna. usda. gov/ Hardzone/ ushzmap. html.)

1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a_ x_ 5b_ x_ 6a_ x__ 6b____ 7a____ 7b____ 8a____ 8b____ 9a____ 9b____ 10a____ 10b____ 11____ over 400 acres OMB Control # 2060 0482 we hope to begin phasing in alternatives after research is completed in 2004 20066. lbs. 7000 Please see worksheet titled CUE summary Please explain why there may be variations in the pounds or acres treated from year to year. EPA Form # 7620 18a Pre Plant Worksheet Title 2 A Methyl Bromide  Crop & Pest Information If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

The purpose of this worksheet is to determine pest infestation and crop information where methyl bromide is used. This forms the baseline for evaluating the impacts of using an alternative to replace methyl bromide.

2 B Methyl Bromide  Historical Use 1997  2002 If a consortium is submitting this application, all data should reflect the actual data for the consortium.

This worksheet provides data in actual usage for 1997 2002.

2 C Methyl Bromide  Crop/ Crop grouping Yield and Gross Revenue for 2000 2002 If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

This worksheet provides crop/ crop grouping yield and gross revenue for 2000 through 2002.

The purpose of this worksheet is to determine past gross revenues when methyl bromide is used. This forms the baseline for evaluating the revenue impacts of using an alternative to replace methyl bromide.

2 D( 1 & 2) Methyl Bromide  Baseline  Operating Costs for 2002 If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

This data is needed to estimate a baseline for operating costs in order to estimate changes in costs and the impact on operating profit and short run economic viability as a result of not using methyl bromide and to provide required information to the international review board.

The purpose of this worksheet is to determine operating expenses when methyl bromide is used. This forms the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help you identify how your operation would change if methyl bromide were unavailable, which will be shown in Worksheet 3 B. Worksheet 2 D( 1) is for users with a fumigation cycle of less than 5 years. Worksheet 2 D( 2) is for users growing perennial crops following a single fumigation at establishment.

In collaboration with USDA, we will estimate fixed and overhead costs across crops and regions to ensure consistency within the U. S. nomination. OMB Control # 2060 0482 Purpose of Data: To establish a baseline estimate of crop/ crop grouping yields, gross revenues, and costs using methyl bromide.

Instructions specific to each worksheet are located at the top of each sheet. Worksheet 2. Methyl Bromide EPA Form # 7620 18a Pre Plant 1. Crop/ Crop Grouping or Consortium 2. Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec 2. Fumigation and Crop Timeline Beginning Fumigation Cycle Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps Continuation of Fumigation Cycle ( if needed)

Month 13 Month 14 Month 15 Month 16 Month 17 Month 18 Month 19 Month 20 Month 21 Month 22 Month 23 Month 24 Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps Which month does your fumigation cycle start? ( check only one)

Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Comments: Worksheet 2 A. Methyl Bromide  Crop & Pest Information Michigan's Field Grown Herbaceous Perennial Growers ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.)

Time Interval ( e. g. MONTH/ YEAR/ SEASON) OMB Control # 2060 0482 3. Target Pest( s) or Pest Problem( s):

Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 4. Pest Economic Threshold Year Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 5. Target Pest Infestation Pest 1 % Pest 2 % Pest 3 % Pest 4 % Pest 5 %

6. Representative User : Source Other descriptive factors regarding representative user: Acres Acres ( Please provide descriptive factors regarding your operation.)

Average Farm Size Average acres in this crop Average Area Treated with Methyl Bromide: Acres ( Please identify the top target pests or pest problems. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment.) Worksheet 2 A. Methyl Bromide  Crop & Pest Information Common Name Genus Describe a few crops that could follow this crop: Source Threshold EPA Form # 7620 18a Pre Plant OMB Control # 2060 0482 Percentage of Total Growing Area ( Please estimate the percentage of the consortia's total growing area with a moderate to severe problem with these pests. Describe source of information such as a survey or expert estimate.) ( Please provide the economic threshold information for each pest. Describe year and source of information such as survey or expert estimate.)

Units ( e. g. pests/ sq ft) EPA Form # 7620 18a Pre Plant 1. Crop/ Crop Grouping or Consortium 2. Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec 2. Fumigation and Crop Timeline Beginning Fumigation Cycle J F M A M J J A S O N D Fallow Land Preparation Fumigation Planting Harvest Establish Cover Crop Other Key Pest Steps Continuation of Fumigation Cycle ( if needed)

J F M A M J J A S O N D Land Preparation Fumigation Planting Harvest Fallow Establish Cover Crop Other Key Pest Steps Pre Plant Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Comments: Time Interval ( e. g. MONTH/ YEAR/ SEASON) Two year seeded herbaceous perennials ( Delphinium ' Round Table Mix' is representative crop)

( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Which month does your fumigation cycle start? ( check only one) OMB Control # 2060 0482 Worksheet 2 A( 2a) Methyl Bromide  Crop & Pest Information  0482 Worksheet 2 A. Methyl Bromide  Crop & Pest Information 3. Target Pest( s) or Pest Problem( s):

Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 4. Pest Economic Threshold Year Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 5. Target Pest Infestation Pest 1 % Pest 2 % Pest 3 % Pest 4 % Pest 5 %

6. Representative User :

Pre Plant Hemerocallis, Hosta, Iris, Tradescantia etc Keik Yellow Nutsedge N. root knot nematode Rorippa sylvestris Canada Thistle Cirsium arvense ( Please identify the top target pests or pest problems. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment.)

eftover Herbaceous Perennial Cro Source Hemerocallis, Hosta, Iris, Tradescantia etc Cyperus esculentus ( Please provide descriptive factors regarding your operation.)

Average Farm Size Acres Average acres in this crop Average Area Treated with Methyl Bromide: Meloidogyne hapla Source Threshold1 MSU weed scientists MSU nematologist 10 50 70 Describe a few crops that could follow this crop: 700 60 280 Other descriptive factors regarding representative user: Acres Acres The overall ' representative user' is a composite of 2 large, and one small sized growing operations; one base budget was composed by each of three growers for the two year seeded, three year transplant and two year transplant crop groupings. The grower used for the two year seeded budget has 60 acres in 2 yr seeded, 240 acres in 2yr transplant, and 300 400 acres in 3 yr transplant. 1Plants grown " for planting" must be free of weeds, nematodes and diseases. Units ( e. g. pests/ sq ft) Common Name Genus 75 50 MSU weed scientists MSU weed scientists 100 Percentage of Total Growing Area ( Please estimate the percentage of the consortia's total growing area with a moderate to severe problem with these pests. Describe source of information such as a survey or expert estimate.) ( Please provide the economic threshold information for each pest. Describe year and source of information such as survey or expert estimate.) 1. Crop/ Crop Grouping or Consortium 2. M J J A S O N D J F M A 2. Fumigation and Crop Timeline Beginning Fumigation Cycle M J J A S O N D J F M A Land Preparation Fumigation Planting Harvest Fallow Cover Crop Cultivate ( Mechanical) Hand Weeding Insecticide & Fungicide Continuation of Fumigation Cycle ( if needed) M J J A S O N D J F M A Land Preparation Fumigation Planting Harvest Fallow Cultivate ( Mechanical) Hand Weeding Insecticide & Fungicide Which month does your fumigation cycle start? ( check only one)

for this crop grouping, methyl bromide is applied 1x times per 3 years. YEAR 2 Comments:

harvest sometimes stretches into May of the following year Worksheet 2 A( 2b). Methyl Bromide  Crop & Pest Information Three year transplanted herbaceous perennials ( Phlox subulata is representative crop).

( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.)

YEAR 1 OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant 3. Target Pest( s) or Pest Problem( s):

Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 4. Pest Economic Threshold Year Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 5. Target Pest Infestation Pest 1 % Pest 2 % Pest 3 % Pest 4 % Pest 5 %

6. Representative User : Fusarium, Phytophthora, Pythium, Rhizoctonia N. root knot nematode lesion nematodes weeds Meloidogyne hapla Pratylenchus sp.

as described in 2A ( 2a) soil borne plant diseases Source 10 ( Please provide descriptive factors regarding your operation.)

Other descriptive factors regarding representative user: Acres Acres Average Farm Size Average acres in this crop Average Area Treated with Methyl Bromide: Acres This crop is assumed to be sold wholesale in very large volume. Price is FOB at the growing operation. The overall ' representative user' is a composite of 2 large, and one small sized growing operations; one base budget was composed by each of three growers for the two year seeded, three year transplant and two year transplant crop groupings. The grower used for the three year transplant budget has 2 acres in 2 yr seeded, 30 acres in 2yr transplant, and 268 in 3 yr transplants. 1Plants grown " for planting" must be free of weeds, nematodes and diseases. stem and bulb nematodes Ditylenchus sp.

Describe a few crops that could follow this crop: 300 30 75 ajuga, sedums, artemesia, Source ( Please identify the top target pests or pest problems. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment.) Worksheet 2 A. Methyl Bromide  Crop & Pest Information Common Name Genus Threshold1 MSU nematologist OMB Control # 2060 0482 50 70 10 Percentage of Total Growing Area ( Please estimate the percentage of the consortia's total growing area with a moderate to severe problem with these pests. Describe source of information such as a survey or expert estimate.) ( Please provide the economic threshold information for each pest. Describe year and source of information such as survey or expert estimate.)

Units ( e. g. pests/ sq ft) EPA Form # 7620 18a Pre Plant 1. Crop/ Crop Grouping or Consortium 2. Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec 2. Fumigation and Crop Timeline Beginning Fumigation Cycle J F M A M J J A S O N D Land Preparation Fumigation Planting Harvest Fallow Fertilize Irrigate Hand Weed Continuation of Fumigation Cycle ( if needed)

J F M A M J J A S O N D Land Preparation Fumigation Planting Harvest Fallow Fertilize Irrigate Hand Weed Which month does your fumigation cycle start? ( check only one)

Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Comments: Worksheet 2 A( 2c). Methyl Bromide  Crop & Pest Information Two year transplanted herbaceous perennials ( Hosta is representative crop)

( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.)

Time Interval ( e. g. MONTH/ YEAR/ SEASON) OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant OMB Control # 2060 0482 3. Target Pest( s) or Pest Problem( s):

Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 4. Pest Economic Threshold Year Pest 1 Pest 2 Pest 3 Pest 4 Pest 5 5. Target Pest Infestation Pest 1 % Pest 2 % Pest 3 % Pest 4 % Pest 5 %

6. Representative User : Inula brittanica, Rorippa sylvestris leftover perennial crop, crop debris ( Source of diseases, nematodes) yellow woodsorrel Meloidogyne hapla Oxalis stricta inula, keik Source N. root knot nematode 50 MSU weed scientists MSU weed scientists ( Please provide descriptive factors regarding your operation.)

Other descriptive factors regarding representative user: Acres Acres Average Farm Size Average acres in this crop Average Area Treated with Methyl Bromide: Acres The overall ' representative user' is a composite of 2 large, and one small sized growing operations; one base budget was composed by each of three growers for the two year seeded, three year transplant and two year transplant crop groupings. The grower used for the 2 year transplant budget grows only 2 yr transplants. 1Plants grown " for planting" must be free of weeds, nematodes and diseases. canada thistle Cirsium arvense Describe a few crops that could follow this crop: 30 30 5 Ajuga, Vinca minor, daylily Source ( Please identify the top target pests or pest problems. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment.) Worksheet 2 A. Methyl Bromide  Crop & Pest Information Common Name Genus Threshold1 MSU nematologist 50 70 5 10 100 75 MSU weed scientists Percentage of Total Growing Area ( Please estimate the percentage of the consortia's total growing area with a moderate to severe problem with these pests. Describe source of information such as a survey or expert estimate.) ( Please provide the economic threshold information for each pest. Describe year and source of information such as survey or expert estimate.)

Units ( e. g. pests/ sq ft) EPA Form # 7620 18a Pre Plant Column A:

Column B:

Column C:

A B C Total Actual Pounds a. i. of Methyl Bromide Applied per Year Total Actual Acres Treated per Year Average Pounds a. i. Applied per Acre per Year 1997 227850 651 350 1998 223300 638 350 1999 214900 614 350 2000 197400 564 350 2001 111300 318 350 2002 112350 321 350 Worksheet 2 B. Methyl Bromide  Historical Use for 1997 2002 Total Actual Pounds a. i. of Methyl Bromide Applied per Year Enter the total actual pounds active ingredient ( a. i.) of methyl bromide applied. Note: This number should be the total pounds a. i. applied by the individual user or the entire consortium, for the year indicated. Include only the pounds active ingredient of methyl bromide. Do not include the pounds of chloropicrin that may be part of the same product.

Total Actual Acres Treated per Year Enter the total actual acres treated. Note: This number should be the total actual acres treated by the individual user or total actual acres treated for the entire consortium, for the year indicated. For furrow treatment the acres should include the area between the rows as well as the area of the rows. i. e. acres treated is the area of the cultivated fields being treated including the area between rows even if they are not treated.

Average Pounds a. i. Applied per Area per Year The average application rates in pounds a. i. of methyl bromide per area may be calculated by dividing Column A by Column B.

Year If there is a variation ( greater than 10%) in the quantity a. i., the acres treated or average application rate from year to year, please explain the reasons for the variation. What is the frequency of methyl bromide applied per area? ( 1x / year, 2x / year, 1x / 3 years, etc.)

______ 1___ times per __ year__________ OMB Control # 2060 0482 fewer acres treated each year due to less total production and higher production per acre Comments: EPA Form # 7620 18a Pre Plant Column A:

Column B:

Column C:

Column D:

Column E:

Column F:

Column G:

A B C D E F G Year Crops/ Crop Groupings Market Category Yield Unit of Measurement Price ($) Gross Revenue per Acre ($)

If this application is for multiple crops/ crop groupings ( e. g. nurseries producing evergreens, deciduous, and forbs) please indicate the proportion of land area allocated to each crop/ crop grouping. Worksheet 2 C. Methyl Bromide  Crop/ Species Yield & Gross Revenue for 2000 2002 Market Categories Be sure to enter the year. Use as many rows as needed for each year for all the crops/ crop groupings in the fumigation cycles from 2000 to 2002. 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/ crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple crops/ crop groupings 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/ crop groupings during the entire interval.

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/ crop groupings grown on the same land, please indicate so in the comments section below. Year Crops/ Crop Groupings Comments: OMB Control # 2060 0482 Gross revenue per acre for each market category and or each crop/ crop grouping may be calculated using the data you entered as price times yield. If revenue is not equal to price times yield, you may enter a different revenue amount, but please explain the difference in the comments section below. Gross Revenue Price Enter the unit of measurement for each crop/ species ( lbs, cwt, carton, bin). If not by weight, specify in the comments section the average weight of the measure. Units of Measurement Enter average prices received by the users for that crop/ crop grouping and market category. Average price over all categories can be calculated separately, if needed. Enter marketing categories that determine prices received, for example, grade ( size, color), timeliness ( early season, late season), or end use ( fresh, processing). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide would effect the yields in each category.

Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops, please enter yields at full production. Be sure to indicate yields at other stages in the timeline in Worksheet 2 A. Yield EPA Form # 7620 18a Pre Plant Column A:

Column B:

Column C:

Column D:

Column E:

Column F:

Column G:

A B C D E F G Year Crops/ Crop Groupings Market Category Yield Unit of Measurement Price ($) Gross Revenue per Acre ($)

2000 2 Year Seeded # 1 Grade 8,985 1 Root $ 0.460 $ 4,133.06 2000 2 Year Seeded Liners 18,242 1 Root $ 0.310 $ 5,655.05 2000 2 Year Seeded TOTAL 27,227 $ 9,788.11 2001 2 Year Seeded # 1 Grade 15,289 1 Root $ 0.470 $ 7,185.94 2001 2 Year Seeded Liners 31,042 1 Root $ 0.335 $ 10,398.99 2001 2 Year Seeded TOTAL 46,331 $ 17,584.93 2002 2 Year Seeded # 1 Grade 14,874 1 Root $ 0.497 $ 7,392.26 2002 2 Year Seeded Liners 30,198 1 Root $ 0.357 $ 10,780.77 2002 2 Year Seeded TOTAL 45,072 $ 18,173.03 OMB Control # 2060 0482 Gross revenue per acre for each market category and or each crop/ crop grouping may be calculated using the data you entered as price times yield. If revenue is not equal to price times yield, you may enter a different revenue amount, but please explain the difference in the comments section below. Gross Revenue Price Enter the unit of measurement for each crop/ species ( lbs, cwt, carton, bin). If not by weight, specify in the comments section the average weight of the measure. Units of Measurement Enter average prices received by the users for that crop/ crop grouping and market category. Average price over all categories can be calculated separately, if needed. Enter marketing categories that determine prices received, for example, grade ( size, color), timeliness ( early season, late season), or end use ( fresh, processing). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide would effect the yields in each category.

Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops, please enter yields at full production. Be sure to indicate yields at other stages in the timeline in Worksheet 2 A. Yield Comments: If this application is for multiple crops/ crop groupings ( e. g. nurseries producing evergreens, deciduous, and forbs) please indicate the proportion of land area allocated to each crop/ crop grouping.

based on the three representative growers, the proportion of land allocated to this crop grouping would be 6% Worksheet 2 C. Methyl Bromide  Crop/ Species Yield & Gross Revenue for 2000 2002 Market Categories Be sure to enter the year. Use as many rows as needed for each year for all the crops/ crop groupings in the fumigation cycles from 2000 to 2002. 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/ crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple crops/ crop groupings 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/ crop groupings during the entire interval.

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/ crop groupings grown on the same land, please indicate so in the comments section below. Year Crops/ Crop Groupings EPA Form # 7620 18a Pre Plant Column A:

Column B:

Column C:

Column D:

Column E:

Column F:

Column G:

A B C D E F G Year Crops/ Crop Groupings Market Category Yield Unit of Measurement Price ($) Gross Revenue per Acre ($)

2000 3 Year Transplanted Phlox subulata 20,755 1/ 2 Flat ( 11x11") $ 3.60 $ 74,716.98 2001 3 Year Transplanted Phlox subulata 20,795 1/ 2 Flat ( 11x11") $ 3.60 $ 74,863.64 2002 3 Year Transplanted Phlox subulata 20,476 1/ 2 Flat ( 11x11") $ 3.60 $ 73,714.29 If this application is for multiple crops/ crop groupings ( e. g. nurseries producing evergreens, deciduous, and forbs) please indicate the proportion of land area allocated to each crop/ crop grouping.

based on the three representative growers, the proportion of land allocated to this crop grouping would be 65% Worksheet 2 C. Methyl Bromide  Crop/ Species Yield & Gross Revenue for 2000 2002 Market Categories Be sure to enter the year. Use as many rows as needed for each year for all the crops/ crop groupings in the fumigation cycles from 2000 to 2002. 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/ crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple crops/ crop groupings 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/ crop groupings during the entire interval.

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/ crop groupings grown on the same land, please indicate so in the comments section below. Year Crops/ Crop Groupings Comments: methyl bromide is applied 1x per three years for this crop grouping. The crop is designated as 3 year transplant because production stretches over parts of three years. OMB Control # 2060 0482 Gross revenue per acre for each market category and or each crop/ crop grouping may be calculated using the data you entered as price times yield. If revenue is not equal to price times yield, you may enter a different revenue amount, but please explain the difference in the comments section below. Gross Revenue Price Enter the unit of measurement for each crop/ species ( lbs, cwt, carton, bin). If not by weight, specify in the comments section the average weight of the measure. Units of Measurement Enter average prices received by the users for that crop/ crop grouping and market category. Average price over all categories can be calculated separately, if needed. Enter marketing categories that determine prices received, for example, grade ( size, color), timeliness ( early season, late season), or end use ( fresh, processing). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide would effect the yields in each category.

Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops, please enter yields at full production. Be sure to indicate yields at other stages in the timeline in Worksheet 2 A. Yield EPA Form # 7620 18a Pre Plant Column A:

Column B:

Column C:

Column D:

Column E:

Column F:

Column G:

A B C D E F G Year Crops/ Crop Groupings Market Category Yield Unit of Measurement Price ($) Gross Revenue per Acre ($)

2000 2 Year Transplanted # 1 ( 2 eye splits) 250,000 Divisions 0.75 $ 187,500 $ 2000 2 Year Transplanted 1 eye splits 200,000 Divisions 0.30 $ 60,000 $ 2000 2 Year Transplanted TOTAL 450,000 247,500 $ 2001 2 Year Transplanted # 1 ( 2 eye splits) 150,000 Divisions 1.00 $ 150,000 $ 2001 2 Year Transplanted 1 eye splits 100,000 Divisions 0.30 $ 30,000 $ 2001 2 Year Transplanted TOTAL 250,000 180,000 $ 2002 2 Year Transplanted # 1 ( 2 eye splits) 200,000 Divisions 0.88 $ 176,000 $ 2002 2 Year Transplanted 1 eye splits 150,000 Divisions 0.30 $ 45,000 $ 2002 2 Year Transplanted TOTAL 350,000 221,000 $

If this application is for multiple crops/ crop groupings ( e. g. nurseries producing evergreens, deciduous, and forbs) please indicate the proportion of land area allocated to each crop/ crop grouping.

based on the three representative growers, the proportion of land allocated to this crop grouping would be 29% Worksheet 2 C. Methyl Bromide  Crop/ Species Yield & Gross Revenue for 2000 2002 Market Categories Be sure to enter the year. Use as many rows as needed for each year for all the crops/ crop groupings in the fumigation cycles from 2000 to 2002. 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/ crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple crops/ crop groupings 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/ crop groupings during the entire interval.

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/ crop groupings grown on the same land, please indicate so in the comments section below. Year Crops/ Crop Groupings Comments:

This is a representative example of a crop grown as a two year transplant. OMB Control # 2060 0482 Gross revenue per acre for each market category and or each crop/ crop grouping may be calculated using the data you entered as price times yield. If revenue is not equal to price times yield, you may enter a different revenue amount, but please explain the difference in the comments section below. Gross Revenue Price Enter the unit of measurement for each crop/ species ( lbs, cwt, carton, bin). If not by weight, specify in the comments section the average weight of the measure. Units of Measurement Enter average prices received by the users for that crop/ crop grouping and market category. Average price over all categories can be calculated separately, if needed. Enter marketing categories that determine prices received, for example, grade ( size, color), timeliness ( early season, late season), or end use ( fresh, processing). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide would effect the yields in each category.

Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops, please enter yields at full production. Be sure to indicate yields at other stages in the timeline in Worksheet 2 A. Yield EPA Form # 7620 18a Pre Plant Column A:

Column B:

Column C:

Column D:

Column E: Constant Cost per Acre For harvest operations, specify costs that depend on land area, for example, picking costs, per acre of land.

Cost per Unit of Yield For harvest operations, specify costs that depend on amount of product harvested, for example, packing material, per unit of produce. Units Harvest costs may likewise be calculated as costs per acre ( Column B) plus variable costs per unit of yield ( Column C) times yield ( Column D). Total Cost per Acre Unit Costs Total Cost per Acre Quantity Used per Acre Operation / Input for Perennial Crops For perennial crops ( Worksheet D( 2)), we have divided the lifespan into three basic periods: pre production ( including establishment), initial production, and full production. Please ensure that the timeline in Worksheet 2 A indicates the years of each period. Operating costs should be an average of costs incurred during each period. Please consider expected replanting rates and indicate which year dead or poorly performing young trees would be replaced. You may copy columns/ rows as needed if these periods need to be refined for your situation.

For inputs and operations detailed in Columns B and D, total costs can be calculated as Column B times Column D. Otherwise, enter total cost of the input or operation. As a check, you may add up Column E to obtain an estimate of total variable operating costs. These will not include fixed and overhead costs, nor a return to the owners' labor. It should, therefore, be less than gross revenues calculated in Worksheet 2 C. If it is not, please explain ( for example, unusually poor yields or unusually poor prices). For perennial crops, Column E should only be totaled for the years at full production. For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying methyl bromide, including any material costs, for example, tarps. If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E. For all inputs and operations detailed in Column B, please specify the units of measurement.

Yield For harvest operations, indicate average yields or representative yields from Worksheet 2 C. OMB Control # 2060 0482 Worksheet 2 D( 1& 2). Methyl Bromide  Baseline  Operating Costs for 2002 Enter all operating costs incurred during a fumigation cycle. Users with a relatively short fumigation cycle ( less than five years) should use version D( 1); users cultivating perennial crops should use version D( 2). Users with multiple crops, either on the same area in a single fumigation cycle or on different areas treated separately, should copy this sheet and provide costs for each crop. If multiple crops are cultivated sequentially following a single fumigation, replace fumigation costs in Pre plant Operations with any additional pest control costs used prior to the following crops. If a fallow season is an important part of the fumigation cycle, include costs incurred ( for example, cultivating a cover crop) as a separate line or as a separate sheet, if costs are extensive. Please fill in the unshaded areas. The shaded areas can be used if the information is known.

The operations/ inputs listed here are not meant to be exhaustive or representative of your specific production system. They are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable. Be as precise as necessary otherwise you may aggregate operations or inputs. For example, specify herbicide costs if additional treatments would become necessary with the use of a methyl bromide alternative, otherwise you may simply specify total pesticide costs. Please specify only variable operating costs.

This field is required only for methyl bromide. However, you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant. Operation / Input EPA Form # 7620 18a Pre Plant B C D E Quantity Used per Acre Units ( lbs, hours, etc) Unit Cost ($) Total Cost per Acre ($)

Constant Cost per Acre ($) Cost per Unit of Yield ($) Yield Total Cost per Acre ($)

Grading / Packing / Storage Other Costs Harvest Operations Labor Hauling Material Fungicide Nematicide Irrigation Labor ( manual)

Fuel / Machine Labor Other Costs Cultural Operations Seed / Seedlings Fertilizer / Soil Amendments Pesticides Insecticide Herbicide application Irrigation Other costs Pre plant Operations Land preparation Fumigation product ( methyl bromide) Operation / Input OMB Control # 2060 0482 A Worksheet 2 D( 1). Methyl Bromide  Baseline  Operating Costs for 2002 EPA Form # 7620 18a Pre Plant A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2) B ( 3) C ( 3) D ( 3) E ( 3)

Operation or Input Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation Fumigation product application Irrigation Seedlings Other costs Cultural Operations Fertilizer/ soil amendments Pesticides Insecticide Herbicide Fungicide Nematicide Irrigation Labor ( manual)

Fuel/ machine labor Other costs Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Picking/ hauling Material Grading/ packing Other costs OMB Control # 2060 0482 Worksheet 2 D( 2). Methyl Bromide  Baseline  Operating Costs for Perennial Crops INITIAL PRODUCTION YEARS _____ FULL PRODUCTION YEARS _____

PRE PRODUCTION YEARS _______ EPA Form # 7620 18a Pre Plant A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2) B ( 3) C ( 3) D ( 3) E ( 3)

Operation or Input Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 148 Fumigation product 312.5 lbs MB/ chl $ 2.85 891 application 809 Irrigation Seed and Seeding 287 Other costs 63 63 Cultural Operations Fertilizer/ soil amendments 73 60 Pesticides Insecticide Herbicide 12 Fungicide 356 Custom Application of Fungicide 12 applications 15.00 $ 180 Irrigation 70 Hand Hoeing & Trimming 120 hrs 12.00 $ 1,440 Fuel/ machine labor 100 Interest on Operating Cap 2,016 $ 6.0% 30 7,273 $ 6.0% 164 Dpt of Ag Inspection 20 20 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Digging & Transporting 876 Grading/ packing 1,495 Cold Storage 997 Shipping 1,329 OMB Control # 2060 0482 Worksheet 2 D( 2a). Methyl Bromide  Baseline  Operating Costs for Perennial Crops 2yr seeded HARVEST  YEAR 2 FULL PRODUCTION YEARS _____

PRE PRODUCTION  YEAR 1 see addendum 1, an explanation of the economics approach taken by the economist who modelled the budgets for this application. EPA Form # 7620 18a Pre Plant A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2) B ( 3) C ( 3) D ( 3) E ( 3)

Operation or Input Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 98 Fumigation product 350 lbs MB/ chl $ 2.85 998 application 807 Cover Crop 100 Seedlings 38,000 divisions $ 0.033 1,241 Planting Labor 1,624 Equipment Operation ( Planting) 6 Cultural Operations Fertilizer/ soil amendments 42 150 Pesticides Insecticide & Fungicide 150 600 Custom Application of F 3 application$ 15.00 45 15 application 15.00 $ 225 Hand Weeding 10 hours 12.00 $ 120 40 hours 12.00 $ 480 Irrigation Labor & Operation 1.5 hours 15.00 $ 23 3.5 hours 15.00 $ 53 Labor ( manual)

Mechanical Cultivation 10 times 15.00 $ 150 Dpt of Ag Inspection 20 20 Interest on Operating Cap 5,273 $ 6.0% 158 13,489 $ 6.0% 405 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Cutting ( Mechanical Operation) 2.7 hr/ ac 15.00 $ 41 Cutting & Packaging ( Labor) 522 hours 12.00 $ 6,261 Equpment Rental Hi Los 435 Truck 495 Trailers 275 see addendum 1, an explanation of the economics approach taken by the economist who modelled the budgets for this application.

OMB Control # 2060 0482 Worksheet 2 D( 2b). Methyl Bromide  Baseline  Operating Costs for Perennial Crops 3 yr transplant HARVEST  YEAR 2 PRE PRODUCTION  YEAR 1 Packing Materials 20,500 flats 0.21 $ 4,305 5,273 $ 9,589 $

EPA Form # 7620 18a Pre P A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2)

Operation or Input Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Quantity used per acre Units ( lbs,

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 145 Fumigation product 400 lbs MB/ chl $ 2.85 1,140 application 609 Field clean up 125 Irrigation Seedlings 50,000 plants $ 0.87 44,333 Other costs Cultural Operations Fertilizer/ soil amendments 450 lbs $ 0.50 243 450 lbs 0.50 $ 243 Pesticides Insecticide Herbicide Fungicide Nematicide Irrigation 16 man hours $ 15.00 240 16 man hours 15.00 $ 240 Labor ( manual)

Interest on Operating Cap 49,159 $ 6.0% 988 11,162 $ 6.0% 335 Hand weeding 192 man hours 12.00 $ 2,304 192 man hours 12.00 $ 2,304 Dpt of Ag Inspection 20 20 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Digging Labor 600 Digging Equipment 55 Storage Cost 1,700 Processing 0.03 $ 200,000 6,000 OMB Control # 2060 0482 Worksheet 2 D( 2c). Methyl Bromide  Baseline  Operating Costs for Perennial Crops 2yr transplant HARVEST  YEAR 2 PRE PRODUCTION  YEAR 1 see addendum 1, an explanation of the economics approach taken by the economist who modelled the budgets for this application. 50,147 $ 11,497 $ 61,644 $ Year 1 and 2 Total Cost per Acre EPA Form # 7620 18a Pre Plant Economist's comments for worksheet 2 D ( 2a) two year seeded Land preparation: Includes soil test, disk, plow, drag, float, apply fert, drag, apply herbicide, disk, drag, float  priced as custom rates so includes some fixed expense Application: Includes custom application, tarp removal and tarp disposal Seed and seeding, other cost: Post planting field prep and cover crop  cover crop is certified seed to minimize weed contamination Irrigation: Solid set and hard hose  includes some fixed expense Fuel, machine labor: Field Maintenance  cultivation and driveway and ditch maintenance  includes some fixed cost Interest on Operating Capital: Assume grower borrows half of variable expenses for 6 months in Year 1 and 9 months in Year 2 Cold Storage: $ 0.90 per sq ft  90d on # 1 and 50d on Liners Economist's comments for worksheet 2 D ( 2b) three year transplant Year 1 Land preparation: Includes soil test, disc, subsoil, plant & disc cover crop, disc, plow, drag Application: Includes custom application cost ( less materials) and plastic disposal and clean up Cover crop: Cover crop seed is certified to minimize weed contamination Planting labor: Includes splitting plants into divisions, transplanting into field and transport to field Interest on Operating Capital: Assume grower borrows half of variable expenses for 12 months in Year 1 and 12 months in Year 2 Equipment Operation ( Planting): Fuel & Maint on transplanter Irrigation Labor & Operation: Includes labor ( calculated) plus $ 0.10 per application in electricity & maint cost Year 2 Irrigation Labor & Operation: Includes labor ( calculated) plus $ 0.10 per application in electricity & maint cost Includes labor ( calculated) plus $ 0.10 per application in electricity & maint cost Equip. rental: 10 hi los, Truck rental ( 4 trucks) plus truck mileage to and from field, Trailer rental ( 3 trailers) plus mileage to and from field Economist's comments for worksheet 2 D ( 2c) two year transplant Year 1 Land preparation: Includes chisel plow 3x and rototill once before and once after fumigation Application: Includes 2 people on hand at application to bury ends of plastic and assist custom operators Field cleanup: Labor to pick up plastic, plastic disposal fee and tractor & trailer use ( custom rate)

Seedlings: Plants and planting costs Fertilizer/ soil amendments: Includes material and application cost Irrigation: Labor to water about 1" per week June 1 Sept 30 Interest on Operating Capital: Assume grower borrows half of variable expenses for 8 months in Year 1 and 12 months in Year 2 Year 2 Digging Equipment: Includes custom rates for 2 tractors  1 for digger and 1 for trailer  potato digger and trailer Storage cost: Includes mulch to cover in polyhouse and polyhouse rental ($ 0.50 per sq ft * 3,000 sq ft necessary for 1 acre hosta yield)

Processing: Splitting divisions Worksheet 3 A 3 B Alternatives  Changes in Operating Costs Worksheet 3. Alternatives  Feasibility of Alternative Pest Control Regimens Title You must complete one worksheet for each alternative. Please inset the name of the alternative in the area on top of the page. If you prefer, you may provide the information requested in this worksheet in a narrative review. However, you must fill in the information in Question # 1 and # 3 or we will assume no yield or quality loss. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to compare data ( yields, crop/ species prices, gross revenues and costs) on the use of methyl bromide and alternative pest control regimens.

Complete worksheet 3 A 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 nonchemical 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.

Enter all alternative pesticides and pest control methods ( and associated cost and yield data) that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Definition worksheet for a comprehensive definition on fumigation cycles. OMB Control # 2060 0482 If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

This data is needed to estimate changes in costs and the impact on operating profit and short run economic viability as a result of not using methyl bromide and to provide required information to the international review board.

The purpose of this worksheet is to determine operating expenses when alternatives are used for evaluating the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help you identify how your operation would change if methyl bromide were unavailable. Worksheet 3 B( 1) is for users with a fumigation cycle of less than 5 years. Worksheet 3 B( 2) is for users growing perennial crops following a single fumigation at establishment.

In collaboration with USDA, we will estimate fixed and overhead costs across crops and regions to ensure consistency within the U. S. nomination. Please fill out this worksheet for each alternative specified in the U. S. Matrix and for other alternatives for which the economic evaluation would bolster the case that methyl bromide is needed. EPA Form # 7620 18a Pre Plant 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No 5.

6. * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available.

Pest Resistant To Alternative Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction Quality Loss *

Are there any variety or cultivar issues associated with this alternative? Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) 1 2 3 4 Details % Pest Control * Alternative:

% Yield Loss * [ Insert Alternative ]

Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Details Attached?

Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category OMB Control # 2060 048 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Non Chemical Pest Control ( please describe) Units ( gals, lbs. Etc.) Active Ingredient ( a. i.) Name of Product and Formulation Land Preparation Fumigation Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting OMB Control # 2060 048 Comments: Alternative: [ Insert Alternative ] EPA Form # 7620 18a Pre Plant 482 es 482 1.

2.

Study # 1 2 3 4 5 3.

Units Units 1 root 1 root 1 root 1 root 4.

No x 5.

6.

yellow nutsedge, kiek, soil borne diseases Pest Resistant To Alternative Restrictions on Alternative Use Are there any variety or cultivar issues associated with this alternative?

Details  Label Restriction Regulatory Restriction % of Area Yes This information will be used to determine the amount of methyl bromide needed.

Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Soil Restriction 1 2 3 4 50 80 11,155 22,649 Details grower experiences an average 25% loss using this product compared to methyl bromide 25% Alternative:

% Yield Loss * Telone II Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

% Pest Control *

Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available.

Details Attached?

EPA Form # 7620 18a Pre Plant Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Quality Loss *

# 1 Grade Liners 14,874 30,198 Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) OMB Control # 2060 0482 Worksheet 3 A( 1) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide 7.

8.

9.

J F M A M J J A S O N D J M A M J J A S O N D J Spot Spray Herbicide Pre Plant Harvest Fallow Land Preparation Fumigation Planting Hand Hoeing Fungicide Non Chemical Pest Control ( please describe)

Establish Cover Crop Herbicide 7 1,3 dichloropropene Units ( gals, lbs. Etc.) lb Alternative: Telone II Worksheet 3 A( 1) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation 1 ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Telone II 97.5% 393.9 Comments:

areas where nematodes are the primary concern, and these weeds and diseases aren't present. One grower applies Telone II with Yetter coulters to get deeper soil penetration ( 12") and improved nematode control. Telone does not control yellow nutsedge, kiek, other weeds. Telone II does not control soil borne diseases. It can be used in Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Fallow Establish Cover Crop Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation ( See methyl bromide alternatives newsletter. January 2001, Application technology for injecting Telone) OMB Control # 2060 0482 1.

2.

Study # 1 2 3 4 5 3.

Units Units Divisions Divisions Divisions Divisions 4.

No x 5.

6. OMB Control # 2060 048 Worksheet 3 A( 2) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Pest Resistant To Alternative Soil Restriction no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) 200,000 150,000 135,520 # 1 ( 2 eye splits) Quality Loss *

1 eye splits Yield with Methyl Bromide Yield With Alternative Quality Impact Description Market Category Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C. Alternative:

% Yield Loss * Grown in Artificial Media on Acreage Prepared as Container Field ( soilless culture/ substrates plug production)

Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

Details Study Information Attached? * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available.

For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 1 2 3 4 Yes  Label Restriction  Township Caps Are there any variety or cultivar issues associated with this alternative?

This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area 5 Enter Average Loss Splits lower due to increased density of plants.

Details 203,280 Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe) EPA Form # 7620 18a Pre Plant 7.

8.

9.

J F M A M J J A S O N D J F M A M J J A S O N D Comments: Alternative: Grown in Artificial Media on Acreage Prepared as Container Field ( soilless culture/ substrates plug production)

Hand Weed Harvest Planting Time Interval ( e. g. MONTH/ YEAR/ SEASON) OMB Control # 2060 048 Fallow Beginning Fumigation Cycle Land Preparation Fumigation Hand hoeing is decreased because artificial media does not contain any weed seeds.

Fertilize Planting Harvest Fallow Fertilize Irrigate Hand Weed Continuation of Alternative Cycle ( if needed) Worksheet 3 A.( 2) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Units ( gals, lbs. Etc.) Name of Product and Formulation Non Chemical Pest Control ( please describe)

Development of a container field involves leveling the ground, installation of below ground irrigation and gravel driveways and laying down of a ground mat in beds. Because of driveways, only about 70% of the 43,560 sq ft in an acre can be utilized. In addition, after a container field is developed, the ground is not useable for alternative farming practices. Therefore, a grower would only develop owned ground into a container field. Irrigate Land Preparation Fumigation ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) EPA Form # 7620 18a Pre Plant 482 482 of eld nd 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No x 5.

6. OMB Control # 2060 048 Worksheet 3 A ( 3) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide expect similar results to Telone II see worksheet 3 A( 1) Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Telone C 35 under tarp is being evaluated under field conditions see research summary attachment for more detail Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * 1,3 Dichloropropene, Chloropicrin ( Telone C 35)

Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

research is currently underway; completion date 2004 1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain)

yellow nutsedge, kiek This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction 50 80 root knot nematodes, weeds Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 see worksheet 3 A( 1)

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative: 1,3 Dichloropropene, Chloropicrin ( Telone C 35)

Telone does not control yellow nutsedge, kiek, other weeds. Telone C 35 might be expected to give improved control of Time Interval ( e. g. MONTH/ YEAR/ SEASON)

borne diseases, where they are present. It can be used in areas where nematodes are the primary concern, and these weeds aren't present. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 3) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.) 1 65% 1,3 dichloropropene Telone C 35 35 gals 35% chloropicrin Non Chemical Pest Control ( please describe) EPA Form # 7620 18a Pre Plant 482 482 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No 5.

6. OMB Control # 2060 048 Worksheet 3 A( 4) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * 1,3 Dichloropropene, Metam sodium Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

research is currently underway; completion date 2004 1 2 3 4 Details Telone II and metam sodium and telone C 35 and metam sodium under tarp are being evaluated under field conditions see research summary attachment for more details Soil Restriction Quality Loss *

Are there any variety or cultivar issues associated with this alternative? not known Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain)

This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details 30 35 weeds northern root knot nematod Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Fusarium spp. Pest Resistant To Alternative 80 90 nurseries in urbanized areas odor problems with metam on fields adjacent to homes and businesses; most owned or rented land in this category * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative: 1,3 Dichloropropene, Metam sodium metam sodium has been erratic in its performance, giving inconsistent results. The fumes are a problem for growers in Time Interval ( e. g. MONTH/ YEAR/ SEASON)

urbanized areas. Metam sodium is not as effective against Fusarium spp. as methyl bromide. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 4) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.) 1 Telone II combined with 35 gal metam sodium metam sodium 75 1 gal ( 1: 4 water) Telone C 35 combined Non Chemical Pest Control ( please describe) 35 75 gal ( 1: 4 water) gal EPA Form # 7620 18a Pre Plant 482 482 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

x No 5.

6. OMB Control # 2060 0482 Worksheet 3 A( 5) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide be up to 60 days before new crop can be planted, depending on rate of metam sodium used, and how quickly the fumigant clears from the soil.

EPA Form # 7620 18a Pre Plant Yield with Methyl Bromide Yield With Alternative Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Quality Loss * Details see attached methyl bromide alternative research for herbaceous perennials Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * metam sodium Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

% Pest Control *

research is currently underway; completion date 2004 3 4 Details Quality Impact Description Are there any variety or cultivar issues associated with this alternative? Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) Additional time may be necessary between crops as it may Yes This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details 30 35 Fusarium spp.

Other Restrictions ( Describe)  Township Caps weeds rootknot nematodes Soil Restriction 1 2 80 90 safety and health issues make it difficult to use in urbanized areas  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available.

Pest Resistant To Alternative 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 75 gal/ Acre ( 1: 2 water) OMB Control # 2060 0482 Alternative: metam sodium Active Ingredient ( a. i.) Name of Product and Formulation EPA Form # 7620 18a Pre Plant Comments:

Growers report that metam applied through center pivot irrigation can be effective, but urbanization makes it impossible. Metam Sodium is not a technically feasible alternative because is does not consistently control all the target pests. Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Growers formerly using metam sodium report that it does not penetrate into the soil as well as methyl bromide, resulting in erratic and less than adequate control. Additional cultivation to aerate the soil before planting may be needed. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 5) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year rates under evaluation: Metam sodium, not tarped Metam sodium, tarped 75 gal/ Acre ( 1: 4 water) 75 gal/ Acre ( 1: 4 water) Units ( gals, lbs. Etc.)

Metam sodium, tarped Non Chemical Pest Control ( please describe) 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No 5.

6. OMB Control # 2060 048 Worksheet 3 A( 6) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? control weeds or nematodes.

Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * chloropicrin Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

Chloropicrin alone is not under evaluation in current research because it does not adequately 1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain)

This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction weeds rootknot nematodes Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative: chloropicrin Chloropicrin alone is not technically feasible because it is not effective against nematodes or weeds. Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 6) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) EPA Form # 7620 18a Pre Plant 482 482 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

x No 5.

6. OMB Control # 2060 048 Worksheet 3 A( 7) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide be up to 60 days before new crop can be planted, depending on rate of metam sodium used, and how quickly the fumigant clears from the soi Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * metham sodium/ chloropicrin Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

Chloropicrin / metam sodium is not under evaluation in current research. 1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) Additional time may be necessary between crops as it may This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction weeds nroot knot nematodes Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative: Metam sodium, Chloropicrin metam sodium has been erratic in its performance, giving inconsistent results. The fumes are a problem for growers in Time Interval ( e. g. MONTH/ YEAR/ SEASON)

urbanized areas. Metam sodium is not as effective against Fusarium spp. as methyl bromide, however the addition of chloropicrin might improve control of Fusarium. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 7) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) EPA Form # 7620 18a Pre Plant 482 soil. 482 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No x 5.

6. OMB Control # 2060 048 Worksheet 3 A( 8) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide be up to 60 days before new crop can be planted, depending on rate of metam sodium used, and how quickly the fumigant clears from the soi Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * metham sodium/ crop rotation Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) Additional time may be necessary between crops as it may Fusarium spp. This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction 30 35 Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative 80 90 safety and health issues make it difficult to use in urbanized areas * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative:

Metam Sodium concerns are expressed in. 3A ( 5a) Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Growers already use some crop rotation to lessen the buildup of nematodes, but crop rotation doesn't address issues with weeds. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 8) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) EPA Form # 7620 18a Pre Plant 482 soil. 482 1.

2.

Study # 1 1 2 2 3.

Units Units 4.

x No 5.

6. OMB Control # 2060 0482 Worksheet 3 A( 9) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide EPA Form # 7620 18a Pre Plant Proceedings, 2000 An. Int. Rsch. Conf. On MB Alt.

Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category x Solarization and biofumigation for field grown flowers C. L. Elmore, J. Roncoroni, J. MacDonald, L. Bolkin, I. Zasala, H. Ferris and S. Tjosvold Details x Macerated Brassica leaves suppress Pythium ultimum and Rhizoctonia solani mycelial growth Craig S. Charron and Carl E. Sams 1998 An. Int. Rsch Conf. On MB Alt. & Emission Reduction Attached? broccoli residue combined with solarization broccoli residue alone Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. Enter Average Loss Alternative:

% Yield Loss * biofumigation Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

100 Details % Pest Control *

72.6 90 66 % reduction of fungal growth on petri plate compared to untreated control 1 1 2 2 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) 6 weeks for solarization This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction weed seedlings calla lily tubers Pythium ultimum, Rhizoctonia solani Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 EPA Form # 7620 18a Pre Plant Comments:

Additionally, biofumigation doesn't adequately control all the targeted pests to produce pest free plants. Alternative: Biofumigation Michigan growers are unlikely to have access to the massive quantity of crucifer waste to treat needed acreage. Time Interval ( e. g. MONTH/ YEAR/ SEASON)

Harvest OMB Control # 2060 0482 technique was combined with solarization under California conditions. Study 1 technique carried out in petri plates, not in the field not enough research to demonstrate that process would work under field conditions. Fallow Other Key Crop Steps Other Key Pest Steps Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Worksheet 3 A( 9) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide study 2) Broccoli waste applied at 5 T and 35 T per ( acre?) rate, incorporated into soil or pot to 2 or 6 inch depth. study 1) Fungal mycelium exposed to volatiles from macerated brassica leaves Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) 1.

2.

Study # 1 3.

Units Units 4.

x No 5.

6. OMB Control # 2060 048 Worksheet 3 A( 10) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide summer lose income from at least one cropping season Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details x Effect of Soil Solarization and Cover Crops on Populations of Selected Soilborne Plant Pathogens in Western Oregon J. N Pinkerton et al, Plant Disease, Vol 84, No 9 Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. Enter Average Loss Alternative:

% Yield Loss * solarization Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

see study for details not reported as % pest control 1 Quality Loss *

Are there any variety or cultivar issues associated with this alternative?

no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) Solarization must be done during the This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction Phytophthora cinnamomi lesion nematode Verticillium dahliae Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative: Solarization Solarization is not a technically feasible alternative because it does not provide control of common nursery pests in a Time Interval ( e. g. MONTH/ YEAR/ SEASON)

northern climate. In Michigan, summer temperatures are too low, humidity is high, and skies are often cloudy. While nematodes populations were reduced, they were not adequately controlled to produce pest free planting stock. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 10) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) EPA Form # 7620 18a Pre Plant 482 482 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No x 5.

6. OMB Control # 2060 0482 Worksheet 3 A( 11) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide EPA Form # 7620 18a Pre Plant Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * steam Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain)

This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant Comments: One consortium grower has spent over $ 200,000 so far to develop monotube boilers to steam his fields.

Steam also requires a high initial investment of capital; it was over twice the cost of methyl bromide for Yoder Bros. Alternative: Steam He is attempting to use high temperature, high pressure steam, which he says is more efficient, but has had difficulty with Time Interval ( e. g. MONTH/ YEAR/ SEASON)

regulating the equipment. One problem with steam is that it adversely affects the carbon in the organic matter. Yoder Bros. Uses steam successfully, but MI growers do not crop small acres continuously, have more organic matter in so Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A ( 11) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No x 5.

6. OMB Control # 2060 0482 Worksheet 3 A( 12) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide EPA Form # 7620 18a Pre Plant Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * Biological control Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain)

This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant Comments: Alternative: Biological control Biological controls have not been developed for the majority of pest problems faced by growers. Generally. Biocontrols Time Interval ( e. g. MONTH/ YEAR/ SEASON)

would result in suppression of a pest, which would not produce the pest free plants required for growing on. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 12) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Various biocontrol agents ( fungi, bacteria, nematodes, etc.) are used to suppress pests. Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

No x 5.

6. OMB Control # 2060 0482 Worksheet 3 A ( 13) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide EPA Form # 7620 18a Pre Plant Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * Crop residue compost Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain)

This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction Rorippa sylvestris Inula spp.

Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant Comments: Alternative: Crop residue compost Composting crop debris alone is not a technically feasible alternative because it will not control target pests to the degree Time Interval ( e. g. MONTH/ YEAR/ SEASON)

necessary to ensure pest and pathogen free plants for planting. Any remaining uncomposted crop debris could serve as a source for disease organisms and nematodes. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 13) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

x No 5.

6. OMB Control # 2060 0482 Worksheet 3 A( 14) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide EPA Form # 7620 18a Pre Plant least a year. Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * Crop rotation/ fallow Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

Details % Pest Control *

1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) Fallowing requires that land be taken out of production for at This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction Rorippa sylvestris Inula spp.

Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant Comments: Alternative: Crop rotation/ fallow Doesn't allow growers to meet requirements for shipping propagative material. Crop rotation/ fallow alone won't control targe Time Interval ( e. g. MONTH/ YEAR/ SEASON)

pests. Fallow Other Key Crop Steps Other Key Pest Steps Harvest Continuation of Alternative Cycle ( if needed)

Planting Land Preparation Fumigation Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps ( Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/ crop groupings not grown sequentially, they will need to provide this information for all crops/ crop groupings. Please adjust timeline as necessary. Please provide additional comments or description below or on a separate page. Please begin the timeline with the first land preparation. For perennials, please begin with the year of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) Alternative Timeline Time Interval ( e. g. MONTH/ YEAR/ SEASON) Beginning Fumigation Cycle Land Preparation Fumigation Worksheet 3 A( 14) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Use Rate of Chemical Alternative Quantity a. i. per Acre # of Acres Treated # of Applications per Year Active Ingredient ( a. i.) Name of Product and Formulation Units ( gals, lbs. Etc.)

Non Chemical Pest Control ( please describe) 1.

2.

Study # 1 2 3 4 5 3.

Units Units 4.

x No 5.

6. OMB Control # 2060 048 Worksheet 3 A ( 15) Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Yield with Methyl Bromide Yield With Alternative Quality Impact Description Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. Refer to market category question in Worksheet 2 C.

Market Category Details Soil flooding during the off season as an alternative to methyl bromide L. H. Allen Jr., D. R. Sotomayor, D. W. Dickson, and Z. Chen Attached? Study Information For the information in # 1 above list: the study name, authors, publication, date, and if a copy is attached. 5 Enter Average Loss Alternative:

% Yield Loss * flooding/ water management Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide Pest Being Tested Study # ( list below) Provide numerical estimates where possible.

83 90 Details % Pest Control *

1 2 3 4 Quality Loss *

Are there any variety or cultivar issues associated with this alternative? no Are there any production delays ( planting/ harvesting) associated with this alternative?

( If yes, please explain) flooding ties up production land for at least 2 3 months This information will be used to determine the amount of methyl bromide needed. Restrictions on Alternative Use Regulatory Restriction % of Area Details Soil Restriction rootknot nematode Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. EPA Form # 7620 18a Pre Plant 7.

8.

9.

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 OMB Control # 2060 048 Comments: Alternative: Flooding and water management Flooding may help to control nematodes, but will not control most weeds and may actually make some soilborne diseases wo Time Interval ( e. g. MONTH/ YEAR/ SEASON)