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? 2004 Application for Critical Use Exemption of Methyl Bromide for Pre Plant Use in 2006 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 Air and Radiation Office of Air and Radiation Global Programs Division ( 6205 J) Global Programs Division 1200 Pennsylvania Ave, NW 1310 L Street, NW Washington, DC 20460 Washington, DC 20005 Telephone: ( 202) 343 9321 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) 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? 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 August 8, 2004 or 90 days after the Notice was published in the Federal Register requesting critical use exemption applications, whichever is later. 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.

Instructions 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 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 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. 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 Cell Fax 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?

Agronomic Economic 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 E mail Address Address Daytime Phone 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.

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

5. Soil Type & Organic Matter Light Medium Heavy 0 to 2 % 2 to 5 % over 5 %

6. Yes Pounds No 7. Yes CUE #

No 8.

Year 2006 Acres 2007 Acres 2008 Acres 9.

10.

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

( Include all crops/ crop groupings that benefit from an application of methyl bromide in a fumigation cycle. For a definition of fumigation cycle see Worksheet entitled " Definitions".)

( 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, 2006? Do you have access to recycled methyl bromide?

If yes, please specify amount ( in pounds). If yes, please specify amount ( in pounds). Worksheet 1. Contact and Methyl Bromide Request Information Total Pounds Active Ingredient ( a. i.) of Methyl Bromide Total Area to be Treated ( 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____ 5b____ 6a____ 6b____ 7a____ 7b____ 8a____ 8b____ 9a____ 9b____ 10a____ 10b____ 11____ over 400 acres OMB Control # 2060 0482 lbs.

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 1998  2003 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 1998 2003.

2 C Methyl Bromide  Crop/ Crop grouping Yield and Gross Revenue for 2001 2003 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 2001 through 2003.

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 2003 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)

Comments: Time Interval ( e. g. MONTH/ YEAR/ SEASON) Worksheet 2 A. Methyl Bromide  Crop & Pest Information ( 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 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 1998 1999 2000 2001 2002 2003 Worksheet 2 B. Methyl Bromide  Historical Use for 1998 2003 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.)

_________ times per ____________ OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant Comments: 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 2001 2003 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 2001 to 2003. 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: 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 2003 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 2003 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 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.

Yes  Label Restriction Organic Matter Restriction Off Site Damage ( outgassing) Other Restrictions ( Describe)  Township Caps Pest Resistant To Alternative 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 EPA Form # 7620 18a Pre Plant OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide 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 0482 EPA Form # 7620 18a Pre Plant Comments: Alternative: [ Insert Alternative ] Column A:

Column B:

Column C:

Column D:

Column E:

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 units of measurement.

Yield For harvest operations, indicate average yields or representative yields from Worksheet 3 A.

Total Cost per Acre Total Cost per Acre 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).

EPA Form # 7620 18a Pre Plant 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. 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.

Unit Costs Operation / Input for Perennial Crops For perennial crops ( Worksheet B( 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 3 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.

Quantity Used per Acre 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.

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

Units OMB Control # 2060 0482 Worksheet 3 B( 1& 2). Alternatives  Changes in Operating Costs Enter all operating costs incurred during a fumigation cycle. Users with a relatively short fumigation cycle ( less than five years) should use version B( 1); users cultivating perennial crops should use version B( 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.

Operation / Input 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. Alternative: [ Insert Alternative] 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 ($)

Hauling Material Grading / Packing / Storage Other Costs Harvest Operations Labor Fuel / Machine Labor Other Costs Fungicide Nematicide Irrigation Labor ( manual) Fertilizer / Soil Amendments Pesticides Insecticide Herbicide Cultural Operations Seed / Seedlings Irrigation Other costs Land preparation Fumigation product ( methyl bromide)

application Pre plant Operations Alternative: [ Insert Alternative]

Operation / Input Worksheet 3 B( 1). Alternatives  Changes in Operating Costs A OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant Alternative:

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 3 B( 2). Alternatives  Changes in Operating Costs for Perennial Crops PRE PRODUCTION YEARS _______ INITIAL PRODUCTION YEARS _____ FULL PRODUCTION YEARS _____

[ Insert Alternative ] EPA Form # 7620 18a Pre Plant 1. 1 4 2 5 3 2. 1 4 2 5 3 3. 1 4 2 5 3 4.

5.

6. Yes No 7. Yes No 8.

From:

To:

9.

Years Amount ($)

10. $

Cost 11. Will economic impacts be measured?

Tarpaulin ( High Density Polyethylene)

Other Will yield/ quality loss be measured?

_____% methyl bromide, _____% chloropicrin _____% methyl bromide, _____% chloropicrin Virtually Impermeable Film ( VIF)

Non Chemical Methods ( please specify) Worksheet 4. Future Research Plans Please describe future plans to test alternatives to methyl bromide. You may use this worksheet to describe all future plans.

Identify the top 3 to 5 target pests for your research.

Provide a list of alternative chemicals or cultural practices that have been tested.

How will you minimize your use and/ or emissions of methyl bromide? What would be the best currently available alternative if methyl bromide were not available? Prioritize the alternative chemicals or cultural practices to be tested.

Formulation Changes Grant requests made to USDA, EPA, state, or other funding group. Investment Please provide an overview/ timeline of the plan to transition away from using methyl bromide.

Other total investments, if any, made to reduce your reliance on methyl bromide? Formulation Changes ( please specify)

( check all that apply)

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

What is the cumulative amount spent and the types of contributions this consortium has made to fund research to develop alternatives to methyl bromide since 1992? ( e. g. consortium dues, direct research funding, etc.)

Name of Organization / Research Institution OMB Control # 2060 0482 ( Describe each investment and its associated costs. e. g. specialized machinery, etc.) EPA Form # 7620 18a Pre Plant 1.

2.

3.

4. 2007 5. 2007 6.

2006 lbs.

2007 lbs.

2008 lbs.

Not Technically Feasible Not Economically Feasible Area Treated Acres For EPA Use Only ID # _______________ SECTOR __________________________

Worksheet 5. Application Summary This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phase out for methyl bromide. Therefore, this worksheet cannot be claimed as CBI.

Consortium Name:

Location:

Crop: Pounds of Methyl Bromide Requested lbs. Acres Treated with Methyl Bromide Acres If methyl bromide is requested for additional years, reason for request:

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

Potential Alternatives Reasons OMB Control # 2060 0482 EPA Form # 7620 18a Pre Plant 82 Fumigation cycle:

Year:

Comparable data:

2 year example:

Other beneficiary example Crop cycle change example:

Crop Grouping EPA Form # 7620 18a The period of time between methyl bromide fumigations.

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

In order to compare revenues and costs with and without methyl bromide, data on alternatives for pest control, yields, revenues, and costs must be for the same time interval as the methyl bromide fumigation cycle. If, however, quantitative data, is not available for the entire fumigation cycle, then to be comparable, the quantitative data for the alternatives should cover the same portion of the fumigation cycle as the quantitative data for methyl bromide, and the rest of the cycle should be discussed in the comments sections.

If a methyl bromide fumigation is made every 2 years, then the 2001 fumigation cycle began in 2001 and would end in 2003. The data should cover the methyl bromide costs and usage for the methyl bromide fumigation made in 2001, and all yields and revenues received and other costs incurred during the 2 year period. To be comparable, the data on alternatives should cover a similar 2 year period beginning in 2005 beginning at the same time of year when a methyl bromide fumigation would be made. The data should cover all methyl bromide alternatives used, and all yields and revenues received during that 2 year interval. Other pest control and other costs would only need to be provided for that interval if they would change from what they were with methyl bromide.

If someone other than the applicant benefits from a methyl bromide fumigation, you should comment on these benefits if you do not have quantitative data for the entire fumigation cycle. For example, if a rotational crop in the second year benefits from a methyl bromide fumigation a year earlier, but there is quantitative data only on the first crop, then the data on the alternatives should cover only the first crop, and the benefits of methyl bromide and the additional pesticides that would have to be used on the rotational crop should be discussed in the comments sections.

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

The applicant can group simliar crops together if: ( i) Crops would experience similar yield and quality losses in the absence of methyl bromide; and ( ii) Crops are grown on the same fumigation and cultivation cycle with similar operating costs. For example, nursery crops including various flower or tree species can be aggregated, with average yields per acre and prices. However, if crops are distinctly different in revenues and operating costs, or the cycles, the applicant may want to present yield, price and operating costs for each crop separately and also indicate the proportion of land area allocated to each crop. Definitions: OMB Control # 2060 0482 Pre Plant