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

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

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

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

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 324 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. STATE CONTACTS HOW DO I APPLY?

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

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

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

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

WHO APPLIES?

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

WHEN IS THE INFORMATION NEEDED?

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

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

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

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

Electronic Address for applications:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Navigating between worksheets Printing worksheets 1.

2.

3.

4.

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

5.

6. Specialty ( check one)

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

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

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

Contact name Address Daytime phone E mail Sacramento, CA 95814 adowns@ exponent. com Anne Downs 916.443.2793 916.443.3071 910 K Street, Suite 325 Location ( Enter the state, region, or county. Provide more detail about the location if relevant to the feasibility of alternatives to methyl bromide.)

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

Climate ( Individual users should enter their climate zone designation by reviewing the U. S. climate zone map. If a consortium is submitting this application, please indicate the estimated percentage of consortium users in each climate zone. This map is located at the end of this workbook or it can be reviewed online at http:// www. usna. usda. gov/ Hardzone/ ushzmap. html).

Various, mediterranean to arid 910 K Street Worksheet 1. Contact and Methyl Bromide Request Information The following information will be used to determine the amount of methyl bromide requested and the contact person for this request. It is important that we know whom to contact in case we need additional information during the review of the application.

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

CAN Citrus & Avocado Nursery CUE Southern California and San Joaquin Valley Citrus and avocado nursery Soil Type:

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

Consortium name Sacramento, CA 95814 jwells@ exponent. com 916.443.3071 Contact name Address 916.443.2793 E mail Jim Wells Exponent Worksheet 1. Contact and Methyl Bromide Request Information 17. 42,000 lbs.

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

19.

20.

20a.

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

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

Are you requesting methyl bromide for additional years beyond 2005?

acres acres 2007 In the table below, area is defined as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

There are very few citrus nursery stock producers for commercial plantings. All but one producer grow plants in the field. 30 acres is an average size for field grown citrus nursery stock. The representative citrus user harvests approximately 30 acres of field grown citrus nursery stock annually. The stock is sold to commercial producers of citrus fruit. The ground is fumigated pre plant with methyl bromide every growing cycle for nematode, disease and weed control. The grower participates in the California nursery certification program. The representative avocado user grows avocado nursery stock in containers for comercial planting. The container substrate is fumigated with methyl bromide. Because the container growerd use of methyl bromide is substantially different from the representative grower. Supplemental worksheets have been added where necessary. How much area will this be applied to? Please list units. 105 For EPA Use Only ID#

Explain why this user represents the typical user in the consortium. 105 Industry standards and regulatory requirements require commercially clean nursery stock. None of the available alternatives to date have demonstrated that these standards can be met consistently in all soil types and growing areas.

2006 Quantity ai ( lb.) of Methyl Bromide 42,000 Area to be Treated 105 If yes, please list year and quantity active ingredient ( ai) of methyl bromide requested in the table below and explain why you need authorization for multiple years.

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

Phytophthora cinnamomi. Armillaria mellea. Dry Root Rot. 42,000 Unit of Area Treated Nematodes, e. g. Tylenchulus semipenetrans, Radopholus similis, Meloidogyne spp.

Soil fungi, e. g. Phytophthora citrophthora, Phytophthora parasitica. Worksheet Title Instructions specific to each worksheet are located at the top of each sheet.

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

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

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

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

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

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

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

Purpose of Data: To establish a baseline estimate of crop/ commodity yields, gross revenues, and costs using methyl bromide. Worksheet 2. Methyl Bromide  Historical Use of Methyl Bromide California Association of Nurserymen Citrus and Avocado Nursery Production Narrative The market for wholesale citrus and avocado nurseries in California is divided into two sectors: 1) commercial fruit producing orchard operations, and 2) retail/ garden center outlets. This consortium consists of nursery growers producing trees for use in orchards for fruit production. Most trees produced for the retail/ garden center are container grown. Nearly all of the citrus trees produced for commercial fruit production are grown in the ground ( field grown). The nurseryman's objective in producing these trees is to furnish the California agricultural industry with trees of known genetic properties, which are free from pests and diseases.

Commercial producers prefer field grown nursery stock because it is larger, stronger, adapts to the orchard better and begins producing earlier than container grown stock. This is important to the commercial fruit producer who must produce income from a planting as early as possible to offset growing costs ( 18 [ All references are attached to 1,3 D worksheet]).

CITRUS Citrus trees for commercial fruit production consist of a seedling rootstock, which is budded to a fruiting scion variety. The production process consist of two phases: 1) seedling production until transplanting, and 2) field growing.

Seedling production Seeds are harvested from orchard trees of known lineage, which are grown specifically for seed production. These trees are produced from registered bud lines maintained by the Clonal Citrus Protection Program ( CCPP) and overseen by the California Department of Food and Agriculture ( CDFA). Seeds can be harvested from a nursery's own registered seeds trees or procured from other producers.

Seeds are generally sown into flats, seedbeds or other seedling containers in the greenhouse or other protected growing area during the spring. Off season sowing is fairly common, as seeds can be maintained in acceptable condition for several months under controlled conditions. As seedlings emerge, they are inspected for off types and weak individuals, which are discarded. The resulting selected seedlings are grown up to the desired height, which can vary from 8" 24" depending on the nursery's techniques, time of year and the prospective demand for nursery trees. In some cases the seedlings are transplanted into larger interim containers which do not exceed 3" diameter x 12" tall. During this phase, the seedlings are usually grown in a clean soilless substrate. Routine inspections are performed to detect any pests or diseases, and appropriate treatments are administered. Weak or otherwise under performing seedlings are continuously sought and discarded.

When the seedlings have reached the desired size they are transplanted into the field. Production of field ready seedlings can take anywhere from 4 12 months.

Field Growing In this phase, the selected seedlings are removed from the greenhouse or protected growing area and transplanted, either into larger pots that are typically 7" diameter x 17" tall or directly into the ground. In either case the growing area is outdoors and exposed to full sunlight. Most of the growers in this consortium grow in the ground ( see discussion above). One grower produces lemon trees for commercial planting in containers for a niche market in a particular growing region of California.

The substrate in pots generally consists of a mixture of topsoil, sand and organic material. These materials are usually brought to the nursery from outside sources and stockpiled, sometimes for many years. For in ground production the substrate is the native soil. Organic amendments may be worked into the soil. In either case, the California Department of Food & Agriculture ( CDFA) requires that the substrate be commercially clean of pests and diseases ( 8). Of particular concern are nematodes, which are the subject of a mandatory certification program administered by CDFA. To comply with these requirements, as well as with the implicit covenant the nursery has with its customer to supply materials that are free of pests and disease, the substrate is fumigated with methyl bromide. This ensures freedom from nematodes, as well as, other pests such as soil borne fungi and noxious weeds.

In the case of pot culture, the soil is blended to the desired makeup by large machinery, then spread and fumigated in compliance with CDFA regulations. Pots are then filled with the fumigated substrate. For in ground production, the soil is worked and irrigated to the proper moisture levels and fumigation is performed in place.

The seedlings are developed in the field until they reach the desired size for budding. This can be a period as short as three months or as long as a year, depending on variety, nurseryman's preference, and market conditions.

The plant materials utilized in budding are the progeny of the Citrus Registration / Certification program which is administered by CDFA. Under this program, only bud sources that are approved by CDFA, as being free from Citrus Tristeza Virus, are utilized. Sources of bud material are tested on a recurring basis by CDFA. Budding is accomplished by the insertion of a single bud of the desired fruiting variety under the bark of the stem of the seedling, at a height 6" 12" above the soil. The budding site is then wrapped with clear polyethylene budding tape to provide physical support and prevent desiccation. The seedling is then bent over to encourage sap flow to the budding site and discourage terminal growth of the seedling. In approximately three weeks the bud heals into the tissue of the seedling and begins to grow. At this point the budding tape is removed and the new sprout emerges.

It is necessary to retain the bent over seedling because the leaves on this portion of the plant act as a sink for nutrients as well as collectors of the sun's energy. This, in turn, helps to sustain a healthy root system while the new bud develops.

During subsequent months the bud elongates and becomes the principal stem of the nursery tree. The seedling is maintained in its bent over position and growth that sprouts from this portion of the plants is removed by hand. When the new stem has attained a height of approximately 30" and developed a sufficient amount of leaves, the seedling growth is removed above the point where the bud was inserted, leaving the growth from the bud as the sole leaf bearing portion of the plant.

The bud is grown up to a height of 36"   60", then pruned back to approximately 30" prior to sale. Elapsed time from budding to sale is highly variable, depending mostly upon the vigor of the budded variety. In general, it ranges from 8   16 months.

During the field growing phase, frequent inspections are performed to identify and remedy any problems. These may include infestations of pests and disease, weak trees or nutritional imbalances. An entomologist performs weekly inspections. Inferior trees are identified and destroyed.

Method of harvest is distinct for each type of tree. In the case of in ground production, trees are dug from the ground by hand with a cylinder of soil around the principal roots. This root cylinder is then wrapped in burlap for physical protection and to avoid desiccation. For pot culture, the potted trees are simply loaded onto a delivery vehicle. In either case, the fumigated substrate is delivered with the nursery tree and is not reused by the nursery.

Total time to produce a saleable tree is 12 28 months. The variables are the vigor of the seed and bud varieties, weather and temperature conditions in the nursery, and decisions on the nurseryman's part on when to transplant and sell.

The resulting product is a nursery tree of known genetic characteristics that has been produced under stringent controlled conditions to avoid the presence or introduction of harmful pests and diseases. Orchard operators therefore can utilize these trees with confidence that their lifespan and productivity will be up to industry standards without risk of the proliferation of dangerous pests and diseases.

AVOCADOS The production process for avocados is substantially similar to that of citrus. As with citrus, the process can be divided into two phases, 1) greenhouse propagation, and 2) field growing. The principal differences in production techniques are ( 1) avocados are grafted rather than budded, and ( 2) the grafting takes place in the greenhouse phase rather than the field growing phase.

Another aspect of avocado nursery tree production is that avocado trees are susceptible to Phytophthora cinnamomi ( Pc), a soil borne fungus that attacks avocado roots. This fungus is especially damaging to avocado trees, having the ability to attack and kill perfectly healthy trees in a relatively short period. In past years, nurseries unfortunately proved to be a very effective means of distribution of this fungus, to the point that the future of avocado production in California was at risk. For this reason, CDFA established, and still maintains, an Avocado Nursery Certification Program that specifies steps that complying avocado nurseries must take to prevent the presence of this fungus in the nursery, and by extension avoid distribution of the fungus in infested nursery trees ( 8). The vast majority of avocado trees produced in California are from nurseries that participate in this program.

Greenhouse propagation Avocado nursery trees for commercial fruit production consist of two types: trees grafted to seedling rootstocks, and trees grafted to clonal rootstocks. From a nursery production perspective, the difference between them is that the clonal rootstocks require extra steps during the greenhouse phase to produce roots from asexual tissue, as opposed to seedling rootstocks that utilize the sexually reproduced seed as the permanent rootstock tissue. For purposes of this discussion, the two processes do not differ from each other in a meaningful way, so the more straightforward seedling rootstock process will be described.

Fruit are harvested from trees of known varieties that have desirable rootstock characteristics. This occurs during the period from October January. The fruit are allowed to soften, and the seeds are extracted by hand and cleaned of all pulp. The seeds are surface dried, then in accordance with the Certification Program, immersed in hot water at a temperature of 120 122 ° F for a period of not less than 30 minutes. This treatment is sufficient to kill any fungi that may be present on the seeds and thereby eliminates seeds as a source of introduction of Pc.

The seeds are bedded in clean soilless substrate in lug boxes inside the greenhouse under controlled temperatures. After approximately 15 days they germinate. As germination occurs, seeds with healthy initial root development are selected and transplanted into bags measuring 2" diameter x 12" deep. Three passes are made through a given lot of bedded seeds, after which the remaining seeds are discarded. The transplanted seeds develop into seedlings in the greenhouse over the course of 4 8 weeks. During this period they are frequently inspected for pests and diseases, and seedlings that are slow to develop are discarded.

When the seedlings reach a height of 12 20" they are grafted with a fruiting scion variety. The graft material is harvested from orchard trees of known desirable varieties. Before entering the certified nursery, the grafting material is disinfested with a chemical treatment.

Grafting differs from budding in that instead of placing a single bud under the bark of the stem, a cutting measuring 3 5" long and of approximately pencil diameter and bearing several buds is inserted directly into the stem of the seedling. The seedling is cut off at a height of approximately 6" and a cut is made directly into the cut surface, splitting the stem into two equal halves to 1" from the top. A corresponding wedge cut is made to the bottom of the graft stick, and the graft stick is inserted into the seedling stem so that the cut surfaces mate. The site of the graft union is then wrapped with an elastic strip to sustain the intimate contact of the mated surfaces and avoid desiccation.

After three weeks the mated surfaces will ' knit' together and sap will flow across the bud union. At this point the buds on the graft begin to grow. Plants that are slow to develop are removed and grafted a second time. As the plants grow, they are sorted numerous times to ensure uniformity, and shoots that develop from latent buds on the rootstock are eliminated.

After an additional 4 12 weeks the plants will have developed sufficient size to be transplanted into the larger field pots. At this point they are removed from the greenhouse environment and placed under 50% shade for ' hardening off', which prepares them for outdoor conditions. They remain under shade for 7 10 days, after which they are placed under full sun without protection.

Field Growing The plants are then transplanted into pots in the same manner as the citrus seedlings, In the case of avocados; fumigation of the potting substrate is especially critical, given that Pc is a soil borne fungus. Within two days of transplanting, stakes are placed in the pots and the young plants are tied to the stakes to ensure an upright growth habit.

From this point the avocados trees are ' visited' by nursery staff an average of once per week, and any necessary training, pruning and weeding is performed. Weak trees are identified and destroyed. Weekly inspections are performed by an entomologist to identify any insect pests and prescribe remedial treatment. The elapsed time in the field is 6 18 months.

Prior to delivery, cardboard trunk protectors are applied to the base of the stem to protect trees from sunburn in the orchard. Harvest is accomplished by loading the trees directly into the delivery vehicle. As is the case with citrus, the fumigated soil is delivered with the tree and is not re used.

As with citrus, the resulting product is one that the orchard operator can utilize with the confidence that the trees will perform to expectations without the risk of introduction of dangerous insects and pathogens. Col A: Formulation of Methyl Bromide Col B, E, H, K: Actual Area Treated Col C, F, I, L: Actual Total lbs. ai of Methyl Bromide Applied Col D, G, J, M: Actual Average lbs. ai Applied per Area A B C D E F G H I J K L M Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area over 95% methyl bromide 100 37,600 376 98 36,750 375 102 37,944 372 105 34,125 325 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide 100 37,600 376 98 36,750 375 102 37,944 372 105 34,125 325 Comments:

All members of the consortium have not reported. Above figures probably underestimate acres treated with methyl bromide.

OMB Control # 2060 0482 For EPA Use Only ID#

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

If a consortium is submitting this application, all data should reflect the actual data for the consortium.

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

for the year indicated.

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

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

1997 1998 1999 Col A: Formulation of Methyl Bromide Col B, E, H, K: Actual Area Treated Col C, F, I, L: Actual Total lbs. ai of Methyl Bromide Applied Col D, G, J, M: Actual Average lbs. ai Applied per Area A B C D E F G H I J K L M Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area Total Actual Area Treated Actual Total lbs. ai of Methyl Bromide Applied Average lbs. ai Applied per Area over 95% methyl bromide 12,500 250 0.02 11850 237 0.02 12600 252 0.02 27000 540 0.02 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide Comments:

OMB Control # 2060 0482 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

Formulation of Methyl Bromide 1997 1998 1999 2000 Enter the appropriate data in Col B M for each formulation, if known, and/ or the totals and averages for all formulations. If you enter only the total and averages for all formulations in the last row of the table, please describe in the comments section the formulations typically used, or the approximate proportions of the formulations used.

Enter the total actual area treated. Note: This number should be the total actual area treated by the individual user or total actual area for the entire consortium, for the year indicated.

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

The average application rates in pounds ai of methyl bromide per area are automatically calculated from the previous 2 columns.

For EPA Use Only ID#

Worksheet 2 A. Methyl Bromide  Use 1997 2000 If a consortium is submitting this application, all data should reflect the actual data for the consortium. For EPA Use Only ID#

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

1997 trees 20,080 $ 8.65 $ 173,692.00 1998 trees 19,859 $ 9.14 $ 181,511.26 1999 trees 17,861 $ 9.43 $ 168,429.23 2000 trees 19,339 $ 9.60 $ 185,654.40 $ 0.00 Total Revenue for 1997 $ 173,692.00 Total Revenue for 1998 $ 181,511.26 Total Revenue for 1999 $ 168,429.23 Total Revenue for 2000 $ 185,654.40 Average Revenue Per Year $ 177,321.72 Comments:

OMB Control # 2060 0482 Citrus Nursery Stock Citrus Nursery Stock Citrus Nursery Stock Citrus Nursery Stock B Col. E: Price Col. F: Revenue Crop/ Commodity Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

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

Col. A: Year Col. B: Crop/ Commodity Col. C: Unit of Crop/ Commodity Col. D: Crop/ Commodity Yield Worksheet 2 B. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 1997 2000 If a consortium is submitting this application, the data for this table should reflect the actual averages for the consortium.

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

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

Enter the unit of measurement for each crop/ commodity.

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

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

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

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

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

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

1997 each 169,356 $ 11.42 $ 1,934,045.52 1998 each 186,678 $ 12.05 $ 2,249,469.90 1999 each 213,622 $ 12.81 $ 2,736,497.82 2000 each 242,942 $ 13.06 $ 3,172,822.52 $ 0.00 Total Revenue for 1997 $ 1,934,045.52 Total Revenue for 1998 $ 2,249,469.90 Total Revenue for 1999 $ 2,736,497.82 Total Revenue for 2000 $ 3,172,822.52 Average Revenue Per Year $ 2,523,208.94 Comments:

OMB Control # 2060 0482 Nursery trees subtropical fruiting Crop/ Commodity Nursery trees subtropical fruiting Nursery trees subtropical fruiting Nursery trees subtropical fruiting Average Revenue per Year: The average revenue per year is calculated automatically using the summary data you enter for each year.

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

B Col. F: Revenue This number is calculated automatically using the values you entered in Cols. D and E. You may override the formula to enter a different revenue.

Please explain why the revenue amount is different in the comment section below.

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

Col. D: Crop/ Commodity Yield Enter the number of units of crop/ commodities produced per area.

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

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

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

Col. C: Unit of Crop/ Commodity Enter the unit of measurement for each crop/ commodity.

Worksheet 2 B. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 1997 2000 If a consortium is submitting this application, the data for this table should reflect the actual averages for the consortium.

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

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

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

Citrus Nursery Stock none  price remains fairly constant trees 18,344 $ 10.32 189,310.00 Total Revenue 189,310.00 Comments: Not all trees are marketable due to substandard size or uniformity.

Not all trees are sold within the same year. Some trees are replanted into pots for future sales to retail outlets.

All figures are on a per acre basis.

OMB Control # 2060 0482 Worksheet 2 C. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 2001 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 estimate the gross revenue for 2001when using methyl bromide. Post harvest users may modify this form to accommodate differences when providing gross revenue data. If 2001 was not a typical year for the individual or for the representative user of a consortium, the applicant may provide additional data for a different year. However, all applicants must complete this worksheet for the year 2001 regardless. Please explain in the comment section at the bottom of the worksheet why 2001 is not considered a typical year, if that is the case.

Col. A: Crop/ Commodity Enter all crops/ commodities that benefit from methyl bromide in the fumigation cycle ( interval between fumigations) beginning with the treatment of methyl bromide in 2001. If multiple crops are grown during the interval between fumigations ( e. g. tomatoes followed by peppers in a single growing season, or strawberries followed by lettuce over 2 or 3 years) include all of the crops during the entire interval. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.

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

Enter factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality,

grade, market ( e. g. fresh or processing), timing of harvest, etc., you may itemize by using more than one row. Itemize or aggregate these factors to the extent appropriate in making the case that the use of methyl bromide affects these price factors.

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

Enter the unit of measurement for each crop/ commodity.

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

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

Revenue is automatically calculated using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this revenue amount is different in the comment section below. For EPA Use Only ID#

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

Nursery Trees each 258,350 $ 12.95 3,345,632.50 Total Revenue 3,345,632.50 Comments:

OMB Control # 2060 0482 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

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

Revenue is automatically calculated using the data you entered for yield and price. If revenue is not equal to yield times price, you may override the formula and enter a different revenue amount. Please explain why this revenue amount is different in the comment section below.

Enter factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality, grade,

market ( e. g. fresh or processing), timing of harvest, etc., you may itemize by using more than one row. Itemize or aggregate these factors to the extent appropriate in making the case that the use of methyl bromide affects these price factors.

Enter the unit of measurement for each crop/ commodity.

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

The purpose of this worksheet is to estimate the gross revenue for 2001when using methyl bromide. Post harvest users may modify this form to accommodate differences when providing gross revenue data. If 2001 was not a typical year for the individual or for the representative user of a consortium, the applicant may provide additional data for a different year. However, all applicants must complete this worksheet for the year 2001 regardless. Please explain in the comment section at the bottom of the worksheet why 2001 is not considered a typical year, if that is the case. Enter all crops/ commodities that benefit from methyl bromide in the fumigation cycle ( interval between fumigations) beginning with the treatment of methyl bromide in 2001. If multiple crops are grown during the interval between fumigations ( e. g. tomatoes followed by peppers in a single growing season, or strawberries followed by lettuce over 2 or 3 years) include all of the crops during the entire interval. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.

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

Col. A: Crop/ Commodity Worksheet 2 C. Methyl Bromide  Crop/ Commodity Yield and Gross Revenue 2001 Col. A: Formulation of Methyl Bromide Col B: Average lbs. active ingredient ( ai) of Methyl Bromide Applied per Area Cols. C, D, E, G: Prices and Costs Col. F: Actual Area Treated A B C D E F G Formulation of Methyl Bromide Lb. ai of Methyl Bromide Applied per Area ( 2001 Average) Price per lb. ai of Methyl Bromide ( 2001 Average) Cost of Applying Pesticide per Area ( 2001 Average) Other MBr Costs ( e. g. tarps,

etc.) per Area ( 2001 Average) Total Actual Area Treated in the Consortium Cost per Area over 95% methyl bromide 302 $ 3.12 $ 265.00 $ 387.00 101 $ 1,594.24 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide 302 $ 3.12 $ 265.00 $ 387.00 101 $ 1,594.24 Comments:

OMB Control # 2060 0482 For EPA Use Only ID#

If 2001 was not a typical year for the individual or for the representative user of a consortium, the applicant may provide additional data for a different year. However, all applicants must complete this worksheet for the year 2001 regardless. If you provide an additional year's data, please explain in the comment section at the bottom of the worksheet why 2001 is not considered a typical year.

If the methyl bromide is custom applied then put the cost per area in Column G and fill in the average lb ai of methyl bromide applied per area ( Col B) and the Total Actual Area Treated ( Col F).

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

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

Enter the appropriate data in Col B G for each formulation, if known, and/ or the totals and averages for all formulations of methyl bromide. If you just enter data in the bottom row in the table ( All formulations of methyl bromide), please describe in the comments, the relative usage of the various formulations, to the extent known.

Enter the average pounds active ingredient ( ai) of methyl bromide applied per area.

Enter the average price per pound active ingredient ( ai) of methyl bromide in Col. C and the average cost of applying methyl bromide per area treated in Col. D. In Col. E, enter the average other costs per area associated with applying methyl bromide ( e. g., tarps). Column G will be calculated automatically using the values you entered in columns B E. If methyl bromide is custom applied, enter the cost per area in Col. G and fill in Cols. B and F.

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

etc.) per Area ( 2001 Average) Total Actual Area Treated in the Consortium Cost per Area over 95% methyl bromide 2lb./ cu ft. $ 3.59 4.63/ 100 cu ft 3.35/ 100 cu ft. 33400cu ft. $ 15.16 75% methyl bromide, 25% chloropicrin 67% methyl bromide, 33% chloropicrin 50% methyl bromide, 50% chloropicrin __% methyl bromide, __% chloropicrin __% methyl bromide, __% chloropicrin All formulations of methyl bromide Comments:

OMB Control # 2060 0482 Enter the average price per pound active ingredient ( ai) of methyl bromide in Col. C and the average cost of applying methyl bromide per area treated in Col. D. In Col. E, enter the average other costs per area associated with applying methyl bromide ( e. g., tarps). Column G will be calculated automatically using the values you entered in columns B E. If methyl bromide is custom applied, enter the cost per area in Col. G and fill in Cols. B and F.

Enter the actual area treated. Note: This number should be the total area treated by all users in the consortium.

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

If the methyl bromide is custom applied then put the cost per area in Column G and fill in the average lb ai of methyl bromide applied per area ( Col B) and the Total Actual Area Treated ( Col F).

If 2001 was not a typical year for the individual or for the representative user of a consortium, the applicant may provide additional data for a different year. However, all applicants must complete this worksheet for the year 2001 regardless. If you provide an additional year's data, please explain in the comment section at the bottom of the worksheet why 2001 is not considered a typical year. Enter the appropriate data in Col B G for each formulation, if known, and/ or the totals and averages for all formulations of methyl bromide. If you just enter data in the bottom row in the table ( All formulations of methyl bromide), please describe in the comments, the relative usage of the various formulations, to the extent known.

Enter the average pounds active ingredient ( ai) of methyl bromide applied per area.

For EPA Use Only ID#

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

Col A: Operation Col B: Custom Operation Cost Col C: Material Cost per Area Col D: Labor Cost per Area Col E: Total Cost per Area Col F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area Typical Equipment Used Land Prep $ 112.00 Disk/ Ripper Amendments $ 253.00 Irrigation $ 322.00 $ 824.00 $ 2,833.00 $ 3,979.99 Planting $ 8,341.00 $ 8,341.00 Harvest $ 2,805.00 $ 9,458.00 $ 12,263.00 Pest Control/ Fertilizer $ 8,224.00 $ 2,791.00 $ 5,507.00 Sprayer/ Tractor Fertilizer Total Custom per Area $ 687.00 User Total per area $ 30,090.99 Comments:

OMB Control # 2060 0482 Operation Done by User Worksheet 2 E. Methyl Bromide  Other Operating Costs for 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Do not include methyl bromide costs.

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

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

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

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

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

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

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

Submit crop budgets for each crop, if available. You may submit crop budgets electronically or in hard copy. If your costs are significantly different than the crop budgets, please explain in the comments. For EPA Use Only ID#

Col A: Operation Col B: Custom Operation Cost Col C: Material Cost per Area Col D: Labor Cost per Area Col E: Total Cost per Area Col F: Typical Equipment Used A B C D E F Material Cost per Area Labor Cost per Area Total Cost per Area Typical Equipment Used Total Custom per Area User Total per area Comments: Costs for worksheets 2 E and 2 F from this grower not available.

OMB Control # 2060 0482 Operation Custom Operation Cost per Area Operation Done by User If you do not incur custom operation costs, enter the labor cost per area.

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

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

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

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

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

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

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

Worksheet 2 E. Methyl Bromide  Other Operating Costs for 2001 Do not include methyl bromide costs.

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

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

Col A: Cost Item Col B: Description Col C: Allocation Method Col D: Cost per Area A B C D Cost Item Description Allocation Method Cost per Area Land Rent lease $ 666.00 Depreciation on nursery equipment $ 165.00 Management foremen salaries $ 5,990.00 Administration office overhead + administration $ 36,473.00 Total $ 43,294.00 Comments:

OMB Control # 2060 0482 Worksheet 2 F. Methyl Bromide Fixed and Overhead Costs in 2001 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Identify in Col. A the cost items. These items should include, but are not limited to: ( 1) land rent, ( 2) interest, ( 3) depreciation, ( 4)

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

Please describe the cost in more detail.

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

Enter the cost per area of methyl bromide treated.

Enter all fixed and overhead costs incurred during the fumigation cycle ( interval between fumigations) beginning in 2001. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. Worksheet Title 3 A Alternatives  Technical Feasibility This form is used to obtain information on the chemical alternatives identified by the Methyl Bromide Technical Options Committee ( MBTOC) that are registered for use in the United States, as well as the non chemical alternatives identified by the MBTOC. Applicants must address the technical feasibility of all the chemical and non chemical alternatives identified on the list.

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

3 C Alternatives  Crop/

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

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

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

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

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

Alternative: Study:

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

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

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

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

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

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

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

The Agency has posted many research studies on a variety of crops on its website and knows of more studies currently in progress. EPA will add studies to its website as they become publicly available. You are encouraged to review the EPA website and other websites for studies that pertain to your crop and geographic area. There are three major ways you can provide the Agency with proof of your investigative work. ( 1) Conduct and submit your own research ( 2) Cite research that has been conducted by others ( 3) Cite research listed on the EPA website EPA must consider whether alternative pest control measures ( pesticide and non pesticidal, and their combination) could be used successfully instead of methyl bromide by crop and circumstance ( geographic area.) The Agency has developed a list of possible alternative pest control regimens for various crops, which can be found at http:// www. epa. gov/ ozone/ mbr or by calling 1 800 296 1996. If you prefer, you may provide the information requested in this worksheet in a narrative review of one or more relevant research reports. The narrative review must reply to Section I and questions 1 through 8 in Section II. A Research Summary Worksheet of relevant treatments should be provided for each study reviewed. Section II. Existing Research Studies on Alternatives to Methyl Bromide 1. Is the study on EPA's website? Yes No 1a. If not on the EPA website, please attach a copy.

2. Author( s) or researcher( s)

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

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

8.

OMB Control # 2060 0482 For EPA Use Only ID#

Discuss how the results of the study apply to your situation. Would you expect similar results? Are there other factors that would affect your adoption of this tool? Describe the effectiveness of the alternative in controlling pests in the study. Name of alternative( s) in study. If more than one alternative, list the ones you wish to discuss. Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Citrus Worksheet 3A 1,3 D & 1,3 D with chlorpicrin and/ or metam sodium Studies: No formal studies of alternatives have been conducted directly on citrus nursery production in California. With respect to the critical pests of citrus nurseries, nematodes, diseases and weeds, work conducted in deciduous nurseries and strawberry is illustrative. References are provided below.

Section I. 1 There are township caps for 1,3 D in California. Citrus for farm planting must be certified. California nursery stock regulations require citrus to be commercially clean. Section II. 1 References 7, 9, 11 15 & 17 are on the EPA website. 2 Authors, various, see above 3 3. See above 4 location of study: various, see above 5 name of alternative: 1,3 D alone and in combination. 6 Crop yield for citrus not measured 7 Effectiveness a. Control of Nematodes. In tree nursery production, studies have shown control of nematode is necessary at the 99.9% level in order to have nursery stock free of nematodes ( 1, 2, 3) as mandated in the California Department of Food and Agriculture certification program and California Nursery Stock regulations. Since tree crops are deep rooted, the control of nematodes needs to be at least five feet deep. While 1,3 D has been shown to control nematodes in shallow, light soils in some instances ( 17), this is not always the case ( 7). 1,3 D does not control nematodes effectively unless the soil moisture is less than 12%. Soils this dry are difficult to achieve at a depth of five feet ( 1,2,3), in heavier soils, or where applications must be made after in heavy rainfall years before the moisture dissipates. Studies showed that soils in Davis, California that had not been irrigated for two years still exceeded 12% moisture at the four foot level ( 1). Nematodes at multiple sites were not controlled in deeper soils with 1,3 D alone or 1,3 D combinations ( 1, 2, 3) for some of the heavier soil types utilized by tree nurseries. Growers who have used 1,3 D in citrus nurseries reported that control of pests and pathogens was not equivalent to that obtained with methyl bromide and that nursery stock planted into soils treated with 1,3 D were of substandard quality due to persistence of residues. Phytotoxicity has also been reported in an Italian study in tomatoes ( grower communication, 7). b. Control of Pathogens. Pathogens must be controlled in nursery stock in order to prevent the spread of a pathogen through out the area receiving the nursery stock. While 1,3 D was effective in controlling Phytophthora cactorum to a depth of 24 inches ( equivalent to methyl bromide) in some situations ( 14), this is not always the case ( 4, 14). 1,3 D has not been as effective as methyl bromide in controlling Verticillium dahliae in strawberry nursery fields ( 6, 14) but has provided adequate control in fruit production fields ( 17). The 1,3 D and 1,3 D combinations have been compared to methyl bromide for control of Oak Root Fungus in commercial and nursery tree crops. 1,3 D alone only gave control in the top four feet while methyl bromide gave control at a deeper level and that control continued to be effective in a production field for over six years. Split applications of 1,3 D or 1,3 D in combination with metam sodium or basamid did not improve the effectiveness of 1,3 D against Oak Rood Fungus, Armillaria mellea, and still only gave control at a depth of four feet or less. c. Weed Control. 1,3 D ( alone or in combination) has shown good weed control in some situations ( 7, 8, 9, 14) especially with the use of VIF tarp vs. standard tarp. Weed populations following a methyl bromide fumigation were lower after a year than weed populations following a 1,3 D ( or 1,3 D combination) treatment ( 2). The species of weeds also shifted from predominately clovers ( after methyl bromine) to predominately grasses and chickweed ( after 1,3 D). d. No yield data available for alternatives in citrus e. 1,3 D does not move well in medium or heavy soils or in soils with more than 12% moisture ( 1,2,3)

References: 1) Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries. Michael McKenry, Report to DPR 2000. 2) Evaluation of Alternatives to Methyl Bromide for Soil Fumigation at Commercial Fruit and Nut Tree Nurseries. Michael McKenry, Report to DPR 2001. 3) The Replant Problem and Its Management. Michael McKenry, Catalina Publishing, 1999. 4) Strategies for Management of Phytophthora on California Strawberries, G. T. Browne, Report to California Strawberry Commission, March 19, 2002 5) Impact of Township Caps on 1,3 D Use in California. Tom Trout. California Strawberry Commission Pink Sheet June 11, 2001. 6) California Management Plan: 1, 3 Dichloropropene. California Department of Pesticide Regulation. January 30, 2002 7) 1,2, D, A valid alternative to methyl bromide for the control of plant parasitic nematodes. F. Lamberti, Bari, Italy. On the EPA Website. 8) Approved Treatment and Handling Procedures to Ensure Against Nematode Pest Infestation of Nursery Stock. California Department of Food and Agriculture. 9) Options to Methyl Bromide for the Control of Soil Borne Disease and Pests in California. A. Braun and D. Supkoff. July 1994. Pest Management Analysis and Planning Program. California Department of Pesticide Regulation. 10) Weeding Time Estimates in Commercial Scale Shank Applied Fumigant Evaluations at Oxnard, CA. S. Fennimore et al. Report to California Strawberry Commission. 11) Alternative fumigants for control of soil pests: strawberry as a model system. S. Fennimore and J. Duniway. On the EPA Website 12) Metam Sodium as an Alternative to Methyl Bromide for Fruit and Vegetable Production. U. S. EPA. On the EPA Website. 13) Metam Sodium as an Alternative to Methyl Bromide for Fruit and Vegetable Production and Orchard Replanting. U. S. EPA. On the EPA Website. 14) Strawberry Response to Fumigants applied by Drip Irrigation Systems. Tom Trout and Husein Ajwa. On the EPA Website. 15) Chloropicrin application in Italy by soil injection and drip irrigation: Effect against soil borne fungal pathogen. A. Minuto, et al. On the EPA Website. 16) Evaluation of the Weed Control Efficacy of Chloropicrin in Strawberry, Milt Haar et al. Report to California Strawberry Commission. 2000. 17) Replacing Methyl Bromide for Preplant Soil Fumigation with 1,3 D, Chloropicrin and Tillam Combination Treatments. U. S. EPA. 18) Letter to Jackie Maxwell, California Citrus Nursery Advisory Board from Gary Caviglia, Crystal Cove Farms. Citrus Chloropicrin Studies: No formal studies of alternatives have been conducted directly on citrus nursery production in California. With respect to the critical pests of citrus nurseries, nematodes, diseases and weeds, work conducted in deciduous nurseries and strawberry is illustrative.

Please refer to Reference List in worksheet for 1,3 D. Studies Section I. 1 Chloropicrin alone is not approved as a stand alone fumigant by the California Department of Food and Agriculture for certified nursery crops ( 8) for either nematodes or soil borne pathogens.

Section II. 1 References 7, 9, 11 15 & 17 are on the EPA website. 2 Authors, various, see above 3 3. See above 4 location of study: various, see above 5 name of alternative: Chloropicrin. 6 Crop yield for citrus not measured 7 Effectiveness: a. Control of Nematodes. Chloropicrin is not approved as a nematocide by the California Department of Food and Agriculture for tree nurseries in the certification program ( 8). Since it is necessary for the nurseries to be participants in the certification program in order to maintain their customer base, they are unable to use chloropicrin as a stand alone fumigant. Chloropicrin does not provide adequate control of nematodes in nursery situations ( 3, 11, 14). b. Control of Pathogens. Chloropicrin does not provide consistent control of soil borne pathogens: Verticillium dahliae ( 13, 14, 15), Rhizoctonia solani ( 15), Fusarium melonis ( 15) and F. lycopersici ( 15) Phytophthora cactorum ( 4, 15). Chloropicrin did provide control of Pythium ultimum in nursery fields ( 11). c. Weed Control. Neither Chloropicrin nor methyl bromide controlled mallow ( 16) and very high levels of chloropicrin were needed to control purslane and knotweed ( 16). Chloropicrin EC was weak for weed control in comparison with either methyl bromide or 1,3 D. Therefore, the associated weeding times and cost of weeding for Chloropicrin was significantly higher ( 10). Citrus Metam sodium Studies: No formal studies of alternatives have been conducted directly on citrus nursery production in California. With respect to the critical pests of citrus nurseries, nematodes, diseases and weeds, work conducted in deciduous nurseries and strawberry is illustrative. References are provided in the worksheet for 1,3 D.

Section I. 1 There are no township caps for metam sodium in California. Citrus for farm planting must be certified. California nursery stock regulations require citrus to be commercially clean. Section II. 1 References 7, 9 , 11 15 & 17 are on the EPA website. 2 Authors, various, see above 3 See above 4 location of study: various, see above 5 name of alternative: metam sodium. 6 Crop yield for citrus not measured 7 Effectiveness a. Nematode. Control of Nematodes. While nematode control has been achieved in various commodity crops ( 12, 13), most of the work was done in shallower soils. Metam sodium was not as effective as 1,3 D ( there was not a methyl bromide control in the study) for control of root knot nematode ( 9) and Heterodera carotae ( 7) ). Metam sodium alone does not provide the long term, deep control of nematodes needed by nursery growers ( 3). Rates of metam sodium needed to move the material five feet down in the soil profile result in phytotoxic effects ( 3, 9, grower communication). b. Control of Pathogens. When digging the nursery stock, root material is left in the soil. Depending on soil type and environmental conditions, these roots may remain in the soil up to several years. Because of this, it is necessary to have a fumigant that can penetrate the roots and kill pathogens such as Oak Root Fungus ( Armillaria mellea) and nematodes residing in the roots. Metam sodium does not effectively penetrate root tissue ( 3). c. Weed Control. Metam sodium has been effective in controlling chickweed, purslane and knotweed but is not effective for mallow or fillare ( communication from S. Fennimore). If properly applied, Metam sodium was shown to be 95% effective in controlling weeds in the top few inches of soil in orchards ( 3). d. Movement in the Soil Profile. Movement is limited in the soil to the wetted front of the fumigation zone ( 3). Due to limited movement, there may be pockets of soil that are not fumigated. In heavier soils, or years with higher rainfall levels, this can be a particular problem ( 9). Citrus AlternativBasamid Studies: See Reference List in worksheet for 1,3 D.

Section I. 1 There are no town ship caps for Basamid. Basamid is not approved by the California Department of Food and Agriculture as a stand alone fumigant for use in the nursery certification program ( 8).

Section II. 1 All studies are referenced in the 3A worksheet for the 1,3 D chemical alternatives. 2 Author: various, as stated above 3 Publication date: various 4 Multiple locations as per studies above 5 Alternative is Basamid. 6 Yield was not studied for fruit/ nut trees. 7 Effectiveness of Basamid as compared to Methyl Bromide a. Due to the difficulty with uniform application of this material, effective control of nematodes and soil borne pathogens is not possible ( 3). b. Movement of in the Soil Profile. Uniform application of the granular material, which contains various grain sizes, is difficult. Further studies on dissolution rate of the granules as well as methods to optimize penetration of the material into soils need to be conducted. Citrus Worksheet 3A.

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

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

None of the non chemical alternatives is approved by the California Department of Food and Agriculture for use in the certification program ( 8). California regulations require stock be free of nematodes in order to ship the material from a nursery to a buyer. None of the non chemical alternatives can achieve the 99.9% nematode free stock needed to meet this requirement.

Soilless substrates do constitute a significant proportion of the media used in tree nurseries but the industry has been unable to escape the necessity of including soil in the blend. The reason for this has to do with the survival of the trees when planted in the orchard. When the orchard operator plants his tree into native soils, the textural interface between the soil blend from the nursery and the orchard soil cannot be too great, or water will not move properly across that interface, resulting in roots that are either asphyxiated due to drowning ( more common) or drying out ( less common). As long as a certain volume of soil is present in the nursery soil, water will be properly conducted across the interface between nursery and native soils, and trees can be adequately irrigated.

Soilless culture is less acceptable to the nursery that supplies trees foer commercial planting than for one that supplies the garden center/ retail trade. Orchard operators need every advantage available to them, and their success or failure depends in large part on the quality of trees that they use to establish the orchard. The nursery stock for commercial plantings requires a large root biomass in the purchased product to produce a successful grove of trees ( 3, grower communication). There is no tolerance for a tree that is handicapped by a small infestation of nematodes, or a slight touch of soil fungus. While these might seem unimportant to the layman, such deficiencies can easily cause a cropping performance of 5% less than clean trees, and this can spell the difference between profit and loss for the farmer. The standard for cleanliness that applies to nurseries that supply the agricultural industry is high, and this is a cornerstone of the continuing success of the nursery and orchard industries. Generally, trees produced by soilless culture ( container trees) do not meet the demand of the commercial consumer. One grower in this consortium, who produces container lemon trees for commercial planting for a niche market in two counties is the exception. Soil solarization is not an option for cooler, coastal growing areas. Solarization also does not control nematodes and diseases deeper than 8 12" ( 3).

Steam is an alternative for container growers who may already have steam heat in a greenhouse setting. The costs of establishing a steam plant, and subsequent energy costs are prohibitive for growers of trees for commercial planting.

Although non chemical alternatives are used by growers as part of integrated systems ( cover crop, crop rotation, water management, graft resistant rootstocks) in combination with chemical fumigation, none of these alternatives alone or in combination can replace chemical fumigation. Alternative: Study:

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

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

Rating for Interval:

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

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

OMB Control # 2060 0482 Provide one summary table for each study being described.

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

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

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

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

List what type of pest control method was used.

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

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

Use these columns to describe the level of control provided for a specific pest and the time interval at which the rating was taken. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after treatment, and 6 weeks after treatment. In this example, type over the words " Rating Interval 1" with " pre treatment", type over " Rating Interval 2" with " 3 weeks", and type over " Rating Interval 3" with " 6 weeks." If you are completing the printed version, please define Rating Interval in the comments below.

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

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

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

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

See attachments [ Insert Study Title] Alternative: Study:

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

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

Rating for Interval:

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

O): Col. J: Yield A B C DE F GH I J K L M NO P Sting nematode Stunt nematode Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating for Interval 3 Interval 1 Rating for Interval 1 Interval 2 Rating for Interval 2 Interval 3 Rating Interval 3 1 Untreated  pre trt 700 3 wks 700 6 wks 707 pre trt 100 3 wks 111 6 wks 109 5,000 2 Methyl Bromide 300 gal. pre trt 669 3 wks 221 6 wks 120 pre trt 98 3 wks 77 6 wks 36 8,000 3 Iodo methane 150 gal. pre trt 675 3 wks 250 6 wks 125 pre trt 111 3 wks 35 6 wks 32 7,580 Comments:

Ratings are for nematodes per gram of soil OMB Control # 2060 0482 Area is defined below as follows for each user: acres for growers, cubic feet for post harvest operations, and square feet for structural applications.

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

Enter the intervals ( days, weeks or months) that the rating was taken for each treatment in Columns D, F, H, J, L, and N. For example, a study for nematode control may have looked at nematode population in the soil pre treatment, 3 weeks after treatment, and 6 weeks after treatment. For this example, insert " pre treatment" in the " Interval 1" column , insert " 3 weeks" in the " Interval 2"

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

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

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

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

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

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

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

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

List what type of pest control method was used.

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

Example Research Summary Table Example Provide one summary table for each study being described. Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Units of product per Area per Application Product Unit ( e. g., lbs.,

gals) $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Total $ 0.00 Comments:

There is no data from growers to use here.

OMB Control # 2060 0482 For EPA Use Only ID#

Use one row for each active ingredient ( ai). For example, if a product contains 2 ai's use 2 rows for that product. Once a row is completed for a given product, then only Col. B ( if applicable), C, and E need to be completed for additional rows regarding the same product.

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

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

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

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

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

Enter all alternatives and non chemical pest control that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle. If multiple crops are grown during the interval between fumigations ( e. g. tomatoes followed by peppers in a single growing season,

or strawberries followed by lettuce over 2 or 3 years) include all of the pesticides that replace methyl bromide for the entire interval. Do not include pesticides that are used along with methyl bromide enter only the additional pest control if methyl bromide were not available.

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

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

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

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

Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied. Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product Col. B: Target Pests Col. C: Active Ingredients Col. D: Formulation Col. E, F, G: Application Rate Col. H, I, J: Prices and Costs Col. K: Area Treated Col. L: # of Applications per Year Col. M: Cost per Area in 2001 Dollars Non chemical Control A B C D E F G H I J K L M lbs. ai per Area per Application Units of product per Area per Application Product Unit ( e. g., lbs.,

gals)

Product X Pest Y, Pest Z Chemical D,

Chemical F 90% Chemical D,

10% Chemical F 250 278 lbs $ 10.00 $ 20.00 0 25 1 $ 2,800.00 Product U Pest V, Pest Y Chemical C 100% 150 200 gal $ 5.00 $ 20.00 10 25 2 $ 2,060.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non Chemical Pest Control Target Pests Description Cost/ area Control P Pest J, Pest K $ 500.00 Total $ 5,360.00 Comments:

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

OMB Control # 2060 0482 Enter the cost per area in 2001 dollars. Col. M will be calculated automatically using the data you have entered for a chemical pest control, or, the formula in Col. M can be overridden if the cost per area is known because the product was custom applied Area Treated at Least Once Enter data near the bottom of the form. Identify the control in Col. A. Enter the target pests in Col. B. Describe the non chemical pest control Col. B L. Enter the costs in Col. M in 2001 dollars. # of Applications per Year Application Rate Formulation of Product Target Pests Active Ingredients ( ai) in Product Worksheet 3 B. Alternatives  Pest Control Regimen Costs for Alternative: Product X Enter the area receiving at least one application of the pesticide.

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

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

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

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

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

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

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

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

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

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

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

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

No experience with alternative methods or chems for production for commercial plantings OMB Control # 2060 0482 Col. A: Crop/ Commodity If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops grown on the same land, please indicate so in the comments section below.

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

Worksheet 3 C. Alternatives  Crop/ Commodity Yield and Gross Revenue for Alternative: [ Insert name of alternative]

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

In the electronic version, revenue is automatically calculated below using the data you entered for yield and price. If revenue is not equal to yield times price,

you may override the formula and enter a different revenue amount. Please explain why this revenue amount is different in the comment section below.

Enter the unit of measurement for your crop/ commodity.

Enter all crops/ commodities that can be grown/ treated during the same interval of time comprising a methyl bromide fumigation cycle. Please discuss changes in crop cycles resulting from alternative use in the comments. See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.

Enter in Col. B any factors that determine prices ( e. g., grade, time, market). If you received different prices for your crop/ commodity as a result of quality,

grade, market ( e. g., fresh or processing), timing of harvest, etc., you may itemize by using more than one row. Itemize or aggregate these factors to the extent appropriate in making the case that the use of alternatives affects these price factors.

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

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

The purpose of this worksheet is to identify the gross revenue for units ( crop, commodity, structure) when using an alternative compared to gross revenue when using methyl bromide. Post harvest and structural users may modify this form to accommodate differences in operations when providing gross revenue data. For EPA Use Only ID#

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

OMB Control # 2060 0482 [ Insert name of alternative]

Worksheet 3 D. Alternatives  Changes in Other Costs for Alternative:

Custom Operation Cost per Area Operation or Cost Item Enter data only for costs ( other than the cost of alternative pest control) that change as a result of using the alternatives instead of methyl bromide. Enter the whole cost,

not just the incremental changes. Enter the cost in Col. B for custom operation costs, or in Col. C and D for operations done by user.

Identify changes in the typical equipment used by the user as a result of not using methyl bromide. Please be specific such as tractor horsepower. No cost data are required in this column.

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

Enter custom operation costs that change in Col. B.

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

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

Enter in Col. C and D, material and labor costs per area that change for operations done by user. The total cost per area is calculated automatically from the values you enter in Cols. C and D. Typical Equipment Used Operation Done by User 1. Name of study:

2. Researcher( s):

3. Your test is planned for:

4. Location:

5. Name of alternative to be tested:

6. Yes No 7.

OMB Control # 2060 0482 Please describe future plans to test alternatives to methyl bromide. ( All available methyl bromide alternatives from the alternatives list should have been tested or have future tests planned.) There is no need to complete a separate worksheet for future research plans for each alternative  you may use this worksheet to describe all future research plans.

If additional testing is not planned, please explain why. ( For example, the available alternatives have been tested and found unsuitable, an alternative has been identified but is not yet registered for this crop, available alternatives are too expensive for this crop, etc.) Will crop yield be measured in the study? For EPA Use Only ID#

The citrus nursery growers are entertaining proposals for alternative research. At this date, no proposals have been approved. Worksheet 4. Alternatives  Future Research Plans 1.

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

x Virtually impermeable film ( VIF)

Cultural practices ( please specify)

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

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

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

3.

Yes No x If yes, how many pounds? lbs.

4.

$

5.

6.

When do you expect these to occur?

7.

0 10 acres 10 25 acres 25 50 acres 50 100 acres 100 200 acres 200 400 acres over 400 acres Worksheet 5. Additional Information For EPA Use Only ID#

1 2 Do you anticipate that you will have any methyl bromide in storage on January 1, 2005?

Research with alternatives that demonstrates satisfactory control of nematodes and diseases so stock can be certifie Adequate weed control Identify what factors would allow you to stop or reduce your use of methyl bromide ( e. g. registration of particular pesticide; completion of research plan; capital outlay). What is the cumulative amount spent to date by the user or consortium on research to develop alternatives to methyl bromide ( beginning in 1992)? How will you minimize your use and/ or emissions of methyl bromide?

Do you have access to recycled methyl bromide?

none by the ass'n Range of acres farmed by growers included in this application? ( insert number of users in each category) Other investments, if any, made to reduce your reliance on methyl bromide. Describe each investment and its associated cost.

Growers have conducted trials with chemical alternatives on their nurseries Worksheet 5. Additional Information ( continued)

8.

0  5,000 sq. ft.

5,001  10,000 sq. ft.

10,001  20,000 sq. ft.

1 20,001  40,000 sq. ft.

40,001  80,000 sq. ft.

80,001  160,000 sq. ft.

2 over 160,000 sq. ft.

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

Signature Date Print Name Title Signature Date Print Name Title OMB Control # 2060 0482 Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintainin information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to resp collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this colle information is estimated to average 324 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl brom agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. Range of square feet of the area to which applicants included in this application will apply methyl bromide? ( insert number of users in each category)

James W. Wells consultant 9 Sep 02 James W. Wells consultant Sept. 9, 2002 Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered " critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree not to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application. For EPA Use Only ID# ified. es the time ining spond to a ollection of omide. An 1. 2. 3. 4. Pounds of Methyl Bromide Requested 2005 4,200 5. Area Treated with Methyl Bromide 2005 105 acres units 6. If methyl bromide is requested for additional years, reason for request:

2006 4,200 lbs. Area Treated 105 acres units 2007 4,200 lbs. Area Treated 105 acres units Not Technically Feasible Not Economically Feasible X Trees not yet harvested by grower who tried this X X X X X X For EPA Use Only ID#

Worksheet 6. Application Summary This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phase out for methyl bromide. Therefore, this worksheet cannot be claimed as CBI.

Name of Applicant:

Location:

Crop: California Association of Nurserymen Citrus and Avocado Growers Citrus and Avocado Southern and Central California 1,3 D and metam sodium can give phytotoxic effects if applied at the same time. Sequential applications require a long period of time for the fumigation process. This combination does not provide adequate nematode and pathogen control.

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

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

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

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

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

nematodes and weeds has been inconsistent with this material.

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

Potential Alternatives 1,3 D Place an " X" in the column( s) labeled " Not Technically Feasible" and/ or " Not Economically Feasible" where appropriate. Use the " Reasons" column to describe why the potential alternative is not feasible.

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

Year: Comparable data:

2 year example:

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

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

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

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

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

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

Fumigation Cycle Definitions:

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

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

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

The period of time between methyl bromide fumigations.