[Federal Register: November 7, 2008 (Volume 73, Number 217)]
[Notices]
[Page 66277-66278]
[DOCID:fr07no08-90]

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SECURITIES AND EXCHANGE COMMISSION

Proposed Collection; Comment Request

Upon written request, copies available from: Securities and Exchange
Commission, Office of Investor Education and Advocacy, Washington, DC
20549-0213.

Extension:
    Rule 18f-3, SEC File No. 270-385, OMB Control No. 3235-0441.

    Notice is hereby given that, pursuant to the Paperwork Reduction
Act of 1995 (44 U.S.C. 3501-3520), the Securities and Exchange
Commission (the ``Commission'') is soliciting comments on the
collection of information summarized below. The Commission plans to
submit this existing collection of information to the Office of
Management and Budget for extension and approval.
    Section 18(f)(1) \1\ of the Investment Company Act of 1940 \2\ (the
``Investment Company Act'' or ``Act'') prohibits registered open-end
management investment companies (``funds'') from issuing any senior
security. Rule 18f-3 under the Act \3\ exempts from section 18(f)(1) a
fund that issues multiple classes of shares representing interests in
the same portfolio of securities (a ``multiple class fund'') if the
fund satisfies the conditions of the rule. In general, each class must
differ in its arrangement for shareholder services or distribution or
both, and must pay the related expenses of that different arrangement.
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    \1\ 15 U.S.C. 80a-18(f)(1).
    \2\ 15 U.S.C. 80a.
    \3\ 17 CFR 270.18f-3.
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    The rule includes one requirement for the collection of
information. A multiple class fund must prepare, and

fund directors must approve, a written plan setting forth the separate
arrangement and expense allocation of each class, and any related
conversion features or exchange privileges (``rule 18f-3 plan'').\4\
Approval of the plan must occur before the fund issues any shares of
multiple classes and whenever the fund materially amends the plan. In
approving the plan, a majority of the fund board, including a majority
of the fund's independent directors, must determine that the plan is in
the best interests of each class and the fund as a whole.
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    \4\ Rule 18f-3(d).
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    The requirement that the fund prepare and directors approve a
written rule 18f-3 plan is intended to ensure that the fund compiles
information relevant to the fairness of the separate arrangement and
expense allocation for each class, and that directors review and
approve the information. Without a blueprint that highlights material
differences among classes, directors might not perceive potential
conflicts of interests when they determine whether the plan is in the
best interests of each class and the fund. In addition, the plan may be
useful to Commission staff in reviewing the fund's compliance with the
rule.
    There are approximately 5,300 multiple class funds offered by 1,120
registrants.\5\ Based on a review of typical rule 18f-3 plans, the
Commission's staff estimates that the 1,120 registrants together make
an average of 560 responses each year to prepare and approve a written
rule 18f-3 plan, requiring approximately 10 hours per response and a
total of 5,600 burden hours per year in the aggregate.\6\ The staff
estimates that preparation of the rule 18f-3 plan may require 6 hours
of the services of an attorney employed by the fund, at a cost of
approximately $295 per hour for professional time,\7\ and approval of
the plan may require 4 hours of the services of the board of directors,
at a cost of approximately $2000 per hour.\8\ The staff therefore
estimates that the aggregate annual cost of complying with the
paperwork requirements of the rule is approximately $5,471,200 ((6
hours x 560 responses x $295 = $991,200) + (4 hours x 560 responses x
$2000 = $4,480,000)).
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    \5\ This estimate is based on data from Form N-SAR, the semi-
annual report that funds file with the Commission. In previous
years, the staff estimated that each multiple class fund prepared
and approved a rule 18f-3 plan. However, the staff has revised this
estimate to reflect its belief that most registrants prepare and
approve a single rule 18f-3 plan for all series funds offered by the
registrants.
    \6\ The estimate reflects the assumption that each registrant
prepares and approves a rule 18f-3 plan every two years when issuing
a new fund or new class or amending a plan (or that 560 of all 1,120
registrants prepare and approve a plan each year). The estimate
assumes that the time required to prepare a plan is 6 hours per plan
(or 3360 hours for 560 registrants annually), and the time required
to approve a plan is an additional 4 hours per plan (or 2240 hours
for 560 registrants annually).
    \7\ This hourly rate estimate is derived from annual salaries
reported in: Securities Industry and Financial Markets Association,
Management and Professional Earnings in the Securities Industry
(2007), modified to account for an 1800-hour work year and
multiplied by 5.35 to account for bonuses, firm size, employee
benefits and overhead.
    \8\ This hourly rate estimate is derived from fund
representatives.
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    The estimated annual burden of 5,600 hours represents a decrease of
110 hours over the prior estimate of 5,710 hours. The decrease in
burden hours is attributable to a change in the estimate of the number
of responses that are submitted pursuant to the rule.
    The estimate of average burden hours is made solely for the
purposes of the Paperwork Reduction Act. The estimate is not derived
from a comprehensive or even a representative survey or study of the
costs of Commission rules. Complying with this collection of
information requirement is mandatory. Responses will not be kept
confidential. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays
a currently valid control number.
    Written comments are invited on: (a) Whether the collections of
information are necessary for the proper performance of the functions
of the Commission, including whether the information has practical
utility; (b) the accuracy of the Commission's estimate of the burdens
of the collections of information; (c) ways to enhance the quality,
utility, and clarity of the information collected; and (d) ways to
minimize the burdens of the collections of information on respondents,
including through the use of automated collection techniques or other
forms of information technology. Consideration will be given to
comments and suggestions submitted in writing within 60 days of this
publication.
    Please direct your written comments to Lewis W. Walker, Acting
Director/CIO, Securities and Exchange Commission, C/O Shirley
Martinson, 6432 General Green Way, Alexandria, VA 22312; or send an e-
mail to<EMAIL_ADDRESS>
    Dated: October 30, 2008.
Florence E. Harmon,
Acting Secretary.
 [FR Doc. E8-26572 Filed 11-6-08; 8:45 am]

BILLING CODE 8011-01-P


[Federal Register Volume 79, Number 3 (Monday, January 6, 2014)]
[Rules and Regulations]
[Pages 543-545]
[FR Doc No: 2013-31313]

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DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

14 CFR Part 39

[Docket No. FAA-2013-0467; Directorate Identifier 2013-NM-023-AD;
Amendment 39-17716; AD 2013-26-07]
RIN 2120-AA64

Airworthiness Directives; Airbus Airplanes

AGENCY: Federal Aviation Administration (FAA), Department of
Transportation (DOT).

ACTION: Final rule.

-----------------------------------------------------------------------

SUMMARY: We are adopting a new airworthiness directive (AD) for all
Airbus Model A318, A319, A320, and A321 series airplanes. This AD was
prompted by reports of certain sliding windows that were difficult to
operate after landing. This AD requires a detailed inspection to
identify part numbers of sliding windows and sliding window seals, and
modification if necessary. This AD also includes an optional
replacement. We are issuing this AD to detect and correct incorrect
seals, which could lead to the functional loss of the sliding window as
an exit, possibly preventing the flightcrew from safely evacuating the
airplane during an emergency.

DATES: This AD becomes effective February 10, 2014.
    The Director of the Federal Register approved the incorporation by
reference of certain publications listed in this AD as of February 10,
2014.

ADDRESSES: You may examine the AD on the Internet at http://www.regulations.gov/#!docketDetail;D=FAA-2013-0467; or in person at the
U.S. Department of Transportation, Docket Operations, M-30, West
Building Ground Floor, Room W12-140, 1200 New Jersey Avenue SE.,
Washington, DC.
    For Airbus service information identified in this AD, contact
Airbus, Airworthiness Office--EIAS, 1 Rond Point Maurice Bellonte,
31707 Blagnac Cedex, France; telephone +33 5 61 93 36 96; fax +33 5 61
93 44 51; email<EMAIL_ADDRESS>Internet http://www.airbus.com. For PPG Aerospace service information identified in
this AD, contact PPG Aerospace, 12780 San Fernando Road, Sylmar, CA
91342; telephone<PHONE_NUMBER>; fax<PHONE_NUMBER>; Internet http://corporateportal.ppg.com/na/aerospace. You may view this referenced
service information at the FAA, Transport Airplane Directorate, 1601
Lind Avenue SW., Renton, WA. For information on the availability of
this material at the FAA, call<PHONE_NUMBER>.

FOR FURTHER INFORMATION CONTACT: Sanjay Ralhan, Aerospace Engineer,
International Branch, ANM-116, Transport Airplane Directorate, FAA,
1601 Lind Avenue SW., Renton, WA 98057-3356; telephone<PHONE_NUMBER>;
fax<PHONE_NUMBER>.

SUPPLEMENTARY INFORMATION:

Discussion

    We issued a notice of proposed rulemaking (NPRM) to amend 14 CFR
part 39 to include an AD that would apply to the specified products.
The NPRM published in the Federal Register on July 3, 2013 (78 FR
40057). The NPRM proposed to correct an unsafe condition for the
specified products.
    The European Aviation Safety Agency (EASA), which is the Technical
Agent for the Member States of the European Community, has issued EASA
Airworthiness Directive 2013-0011, dated January 15, 2013 (referred to
after this as the Mandatory Continuing Airworthiness Information, or
``the MCAI''), to correct an unsafe condition for the specified
products. The MCAI states:

    Several occurrences have been reported on A320 family aeroplanes
of PPG sliding windows that were difficult to operate after landing.
    The investigation results revealed that when a seal having Part
Number (P/N) 22-17-7640-1 or P/N 22-17-7640-2 is installed on a
sliding window, closure of the window can create a vacuum between
the 2 tubes of the pressure seal, leading to the window remaining
stuck to the frame on the fuselage side, due to suction effect.
    This condition, if not detected and corrected, could lead to the
functional loss of the sliding window as an exit, possibly
preventing the flight crew from safely evacuating the aeroplane
during an emergency.
    For the reasons described above, this [EASA] AD requires a one-
time detailed inspection (DI) of the sliding windows and its seal to
identify the affected sliding window seals and, depending on
findings, accomplishment of the applicable corrective actions
[corrective action includes a modification or replacement].

    The subject area on certain Airbus Model A318, A319, and A321
series airplanes is almost identical to that on the affected Model A320
series airplanes. Therefore, those Model A318, A319, and A321 series
airplanes may be subject to the unsafe condition revealed on the Model
A320 series airplanes. You may examine the MCAI in the AD docket on the
Internet at http://www.regulations.gov/#!documentDetail;D=FAA-2013-
0467-0002.

Comments

    We gave the public the opportunity to participate in developing
this AD. We considered the comment received.

Request for Identification Change

    United Airlines (UAL) requested that the modification be recorded
at the part number level, instead of the serial number level. UAL
explained that re-identifying the post-modification window at the
serial number level only will potentially lead to de-modification of
the window, which could result in the unsafe condition identified in
the NPRM (78 FR 40057, July 3, 2013). UAL reasoned that re-identifying
the window at the part number level would better allow operators to
manage the post-AD configuration.
    UAL provided further substantiation to add the ``M'' to the part
number instead of the serial number during a teleconference with us
during the week of September 23, 2013. UAL's reason for adding the
``M'' to the part number is related to the convenience/preference of
UAL maintenance practices.
    We disagree with the request to require recording the modification
at the part number level. After coordinating with Airbus, we have
determined that adding ``M'' to the serial number will prevent
installation of unsafe sliding window part numbers without changing the
part number configuration and associated administrative processes to
change part numbers. However, we have revised paragraph (h) of this
final rule to include phrasing to clarify and to allow for modification
to be recorded at the serial number level of the affected part number.

Conclusion

    We reviewed the available data, including the comment received, and
determined that air safety and the public interest require adopting
this AD with the change described previously and minor editorial
changes. We have determined that these changes:
     Are consistent with the intent that was proposed in the
NPRM (78 FR 40057, July 3, 2013) for correcting the unsafe condition;
and
     Do not add any additional burden upon the public than was
already proposed in the NPRM (78 FR 40057, July 3, 2013).

Costs of Compliance

    Based on the service information, we estimate that this AD affects
about 851 products of U.S. registry. We also estimate that it will take
about 3 work-

hours per product to comply with the basic requirements of this AD. The
average labor rate is $85 per work-hour. Based on these figures, we
estimate the cost of this AD on U.S. operators to be $217,005, or $255
per product.
    In addition, we estimate that any necessary follow-on actions will
take about 1 work-hour and require parts costing $0, for a cost of $85
per product. We have no way of determining the number of products that
may need these actions.

Authority for This Rulemaking

    Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. ``Subtitle VII: Aviation
Programs,'' describes in more detail the scope of the Agency's
authority.
    We are issuing this rulemaking under the authority described in
``Subtitle VII, Part A, Subpart III, Section 44701: General
requirements.'' Under that section, Congress charges the FAA with
promoting safe flight of civil aircraft in air commerce by prescribing
regulations for practices, methods, and procedures the Administrator
finds necessary for safety in air commerce. This regulation is within
the scope of that authority because it addresses an unsafe condition
that is likely to exist or develop on products identified in this
rulemaking action.

Regulatory Findings

    We determined that this AD will not have federalism implications
under Executive Order 13132. This AD will not have a substantial direct
effect on the States, on the relationship between the national
government and the States, or on the distribution of power and
responsibilities among the various levels of government.
    For the reasons discussed above, I certify that this AD:
    1. Is not a ``significant regulatory action'' under Executive Order
12866;
    2. Is not a ``significant rule'' under the DOT Regulatory Policies
and Procedures (44 FR 11034, February 26, 1979);
    3. Will not affect intrastate aviation in Alaska; and
    4. Will not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.

Examining the AD Docket

    You may examine the MCAI in the AD docket on the Internet at http://www.regulations.gov/#!documentDetail;D=FAA-2013-0467-0002; or in
person at the Docket Operations office between 9 a.m. and 5 p.m.,
Monday through Friday, except Federal holidays. The AD docket contains
this AD, the regulatory evaluation, any comments received, and other
information. The street address for the Docket Operations office
(telephone<PHONE_NUMBER>) is in the ADDRESSES section.

List of Subjects in 14 CFR Part 39

    Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.

Adoption of the Amendment

    Accordingly, under the authority delegated to me by the
Administrator, the FAA amends 14 CFR part 39 as follows:

PART 39--AIRWORTHINESS DIRECTIVES

0
1. The authority citation for part 39 continues to read as follows:

    Authority:  49 U.S.C. 106(g), 40113, 44701.

Sec.  39.13  [Amended]

0
2. The FAA amends Sec.  39.13 by adding the following new AD:

2013-26-07 Airbus: Amendment 39-17716. Docket No. FAA-2013-0467;
Directorate Identifier 2013-NM-023-AD.

(a) Effective Date

    This airworthiness directive (AD) becomes effective February 10,
2014.

(b) Affected ADs

    None.

(c) Applicability

    This AD applies to Airbus Model A318-111, -112, -121, and -122
airplanes; Model A319-111, -112, -113, -114, -115, -131, -132, and -
133 airplanes; Model A320-111, -211, -212, -214, -231, -232, and -
233 airplanes; and Model A321-111, -112, -131, -211, -212, -213, -
231, and -232 airplanes; certificated in any category; all
manufacturer serial numbers.

(d) Subject

    Air Transport Association (ATA) of America Code 56, Windows.

(e) Reason

    This AD was prompted by reports of certain sliding windows that
were difficult to operate after landing. We are issuing this AD to
detect and correct incorrect seals, which could lead to the
functional loss of the sliding window as an exit, possibly
preventing the flightcrew from safely evacuating the airplane during
an emergency.

(f) Compliance

    You are responsible for having the actions required by this AD
performed within the compliance times specified, unless the actions
have already been done.

(g) Inspection

    Within 750 flight cycles or 750 flight hours or 4 months after
the effective date of this AD, whichever occurs first: Do a detailed
inspection to identify part numbers (P/Ns) of each window and seal
of the left-hand (LH) and right-hand (RH) sliding windows and
sliding window seals, in accordance with the Accomplishment
Instructions of Airbus Service Bulletin A320-56-1016, including
Appendices 01 and 02, dated September 14, 2012. A review of airplane
maintenance records is acceptable in lieu of this inspection if the
part number of the window and seal of the LH and RH sliding windows
and sliding window seals can be conclusively determined from that
review.

 (h) Modification

    If a sliding window part number identified in table 1 to
paragraph (h) of this AD is found during the inspection required by
paragraph (g) of this AD; and the serial number of the part does not
have the modification amendment letter ``M,'' and does have sliding
window seals having P/N 22-17-7640-1 or P/N 22-17-7640-2 installed:
Within the compliance time specified in paragraph (g) of this AD,
modify the sliding window seal (which includes adding the letter
``M'' to serial number of the affected part), in accordance with the
Accomplishment Instructions of Airbus Service Bulletin A320-56-1015,
dated September 14, 2012.

   Table 1 to Paragraph (h) of This AD--Affected PPG Aerospace Sliding
                           Window Part Numbers
------------------------------------------------------------------------
             Left-hand                            Right-hand
------------------------------------------------------------------------
NP165312-1                           NP165312-2
NP165312-3                           NP165312-4
NP165312-5                           NP165312-6
NP165312-7                           NP165312-8
NP165312-9                           NP165312-10
NP165312-11                          NP165312-12
------------------------------------------------------------------------

 (i) Optional Replacement

    For sliding windows identified as affected in paragraph (h) of
this AD, replacement of a sliding window seal having P/N 22-17-7640-
1 L/H or P/N 22-17-7640-2 R/H with a seal having P/N 22-17-7640-3 L/
H or P/N 22-17-7640-4 R/H, respectively, in accordance with a method
approved by either the Manager, International Branch, ANM-116,
Transport Airplane Directorate, FAA, or the European Aviation Safety
Agency (EASA) (or its delegated agent), is an acceptable alternative
method of compliance with the modification required by paragraph (h)
of this AD.

    Note 1 to paragraph (i) of this AD: Guidance for replacement of
a sliding window seal can be found in Page Block 401 of Sub-section
56-12-11 of the Airbus A318/A319/A320/A321 Aircraft Maintenance
Manual.

(j) Exceptions to Requirements of Paragraphs (g) and (h) of This AD

    (1) Airplanes on which Airbus Modification 153512 (installation
of sliding

window with P/N NP165312-13 and P/N NP165312-14 with improved seal)
or Modification 153534 (installation of sliding window with P/N
NP165312-11 and P/N NP165312-12 with amendment M) has been embodied
in production are not affected by the requirements of paragraphs (g)
and (h) of this AD, provided that no sliding window or sliding
window seal has been replaced since first flight.
    (2) Airplanes on which Airbus Modification 39587 (installation
of affected seal on PPG Aerospace sliding windows) has not been
embodied in production are not affected by the requirements of
paragraphs (g) and (h) of this AD, provided that no sliding window
or sliding window seal has been replaced since first flight.

 (k) Parts Installation Limitation

    As of the effective date of this AD, no person may install on
any airplane any PPG Aerospace sliding window with a part number
listed in table 1 to paragraph (h) of this AD with a seal having P/N
22-17-7640-1 or P/N 22-17-7640-2, unless the seal has been modified
in accordance with the Accomplishment Instructions of Airbus Service
Bulletin A320-56-1015, dated September 14, 2012; or PPG Aerospace
Service Bulletin 165312-56-001, dated February 29, 2012.

 (l) Other FAA AD Provisions

    The following provisions also apply to this AD:
    (1) Alternative Methods of Compliance (AMOCs): The Manager,
International Branch, ANM-116, Transport Airplane Directorate, FAA,
has the authority to approve AMOCs for this AD, if requested using
the procedures found in 14 CFR 39.19. In accordance with 14 CFR
39.19, send your request to your principal inspector or local Flight
Standards District Office, as appropriate. If sending information
directly to the International Branch, send it to ATTN: Sanjay
Ralhan, Aerospace Engineer, International Branch, ANM-116, Transport
Airplane Directorate, FAA, 1601 Lind Avenue SW., Renton, WA 98057-
3356; telephone<PHONE_NUMBER>; fax<PHONE_NUMBER>. Information may
be emailed to<EMAIL_ADDRESS>Before using any
approved AMOC, notify your appropriate principal inspector, or
lacking a principal inspector, the manager of the local flight
standards district office/certificate holding district office. The
AMOC approval letter must specifically reference this AD.
    (2) Airworthy Product: For any requirement in this AD to obtain
corrective actions from a manufacturer or other source, use these
actions if they are FAA-approved. Corrective actions are considered
FAA-approved if they are approved by the State of Design Authority
(or their delegated agent). You are required to assure the product
is airworthy before it is returned to service.

(m) Related Information

    Refer to Mandatory Continuing Airworthiness Information (MCAI)
EASA Airworthiness Directive 2013-0011, dated January 15, 2013, for
related information. This MCAI may be found in the AD docket on the
Internet at http://www.regulations.gov/#!documentDetail;D=FAA-2013-
0467-0002.

(n) Material Incorporated by Reference

    (1) The Director of the Federal Register approved the
incorporation by reference (IBR) of the service information listed
in this paragraph under 5 U.S.C. 552(a) and 1 CFR part 51.
    (2) You must use this service information as applicable to do
the actions required by this AD, unless this AD specifies otherwise.
    (i) Airbus Service Bulletin A320-56-1015, dated September 14,
2012.
    (ii) Airbus Service Bulletin A320-56-1016, including Appendices
01 and 02, dated September 14, 2012.
    (iii) PPG Aerospace Service Bulletin 165312-56-001, dated
February 29, 2012.
    (3) For Airbus service information identified in this AD,
contact Airbus, Airworthiness Office--EIAS, 1 Rond Point Maurice
Bellonte, 31707 Blagnac Cedex, France; telephone +33 5 61 93 36 96;
fax +33 5 61 93 44 51; email<EMAIL_ADDRESS>
Internet http://www.airbus.com.
    (4) For PPG Aerospace service information identified in this AD,
contact PPG Aerospace, 12780 San Fernando Road, Sylmar, CA 91342;
telephone<PHONE_NUMBER>; fax<PHONE_NUMBER>; Internet http://corporateportal.ppg.com/na/aerospace.
    (5) You may view this service information at the FAA, Transport
Airplane Directorate, 1601 Lind Avenue SW., Renton, WA. For
information on the availability of this material at the FAA, call
425-227-1221.
    (6) You may view this service information that is incorporated
by reference at the National Archives and Records Administration
(NARA). For information on the availability of this material at
NARA, call<PHONE_NUMBER>, or go to: http://www.archives.gov/federal-register/cfr/ibr-locations.html.

    Issued in Renton, Washington, on December 20, 2013.
Jeffrey E. Duven,
Manager, Transport Airplane Directorate, Aircraft Certification
Service.
[FR Doc. 2013-31313 Filed 1-3-14; 8:45 am]
BILLING CODE 4910-13-P


FDMS DOCKET MATERIALS

for

Sewage Treatment Technology—Type Approval of Marine Sanitation Devices

Notice of meeting (  HYPERLINK
"https://www.gpo.gov/fdsys/pkg/FR-2015-10-16/pdf/2015-26363.pdf"  80 FR
62551, October 16, 2015 )

Docket Number:  USCG-2015-0950

Document ID*	Title**	Type***	From^	# of pages

USCG-2015-0950-xxxx	Federal Register Notice of Meeting (80 FR 62551)
Notice

2

USCG-2015-0950-xxxx	Public Workshop Agenda	SUPPORTING & RELATED
MATERIALS

4

USCG-2015-0950-xxxx	Presentation on Black Water & Greywater by Dr. Wei
Chen	SUPPORTING & RELATED MATERIALS	Dr. Wei Chen,

Wartsila Water Systems, LTD.	25

USCG-2015-0950-xxxx	Presentation on Sewage & Greywater Treatment
Technologies – an Overview by Dr. Wei Chen	SUPPORTING & RELATED
MATERIALS	Dr. Wei Chen,

Wartsila Water Systems, LTD.	22

USCG-2015-0950-xxxx	Presentation on Sewage & Greywater Treatment
Technologies by Asgeir Wien, Scanship 	SUPPORTING & RELATED MATERIALS
Asgeir Wien,

Scanship	13

USCG-2015-0950-xxxx	Presentation on Passenger Vessel Wastewater
Requirements by State of Alaska	SUPPORTING & RELATED MATERIALS	Ed White,
Alaska Department of Environmental Conservation	37

USCG-2015-0950-xxxx	Presentation on Sewage Treatment Plant Testing and
Type Approval Process by Matt MacGregor, Tei-Testing Services	SUPPORTING
& RELATED MATERIALS	Matt MacGregor, Tei-Testing Services	14

USCG-2015-0950-xxxx	Presentation on On board simple checks for verifying
performance of marine sanitation devices by Matt MacGregor, Tei-Testing
Services	SUPPORTING & RELATED MATERIALS	Matt MacGregor, Tei-Testing
Services	6

USCG-2015-0950-xxxx	Presentation on Type Approval Process and Technology
Testing by Dr. Elmar Dorgeloh and Markus Joswig, PIA	SUPPORTING &
RELATED MATERIALS	Dr. Elmar Dorgeloh and Markus Joswig, PIA	25

USCG-2015-0950-xxxx	Presentation on Regulatory Program Overview of  both
Domestic & International Requirements by Wayne Lundy, U.S. Coast Guard
SUPPORTING & RELATED MATERIALS

18

USCG-2015-0950-xxxx	List of Participants with e-mail information
SUPPORTING & RELATED MATERIALS

1

USCG-2015-0950-xxxx	International Maritime Organization resolution
MEPC.227(64) – 2012 Guidelines on implementation of Effluent Standards
and Performance Tests for Sewage Treatment Plants	SUPPORTING & RELATED
MATERIALS

17

*If you want documents to have a specific written submission entry
number, insert it in this column but this only works for new dockets.
If the docket has been opened for comments, you won’t be able to
control which number is assigned; in which case, ignore this column.
Generally the document you are soliciting comments on – the one
published in the Federal Register -- will be assigned as the first entry
(USCG-xxxx-xxxx-0001), so you would generally start your list with
USCG-xxxx-xxxx-0002.

**Try to keep the title short.

***This column describes the type of document – one of six categories
(Notice, Proposed Rule, Rule, Supporting & Related Material, Other, or
Public Submission).

^If this submission is coming from a specific person or organization
outside the USCG, use this column to identify who the document is coming
from.  Be sure the person or organization knows you will be uploading
this material into the docket, particularly if you received the material
via email.  Don’t upload copyrighted material.

CG-xxx

Xx Dec 20xx

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CALIFORNIA Methyl Bromide $ 83,367 $ 33,127 Page 50 Metam Sodium ( 15%) $ 70,862 $ 24,509 Metam Sodium ( 20%) $ 66,694 $ 22,068 MICHIGAN Methyl Bromide $ 39,996 $ 9,438 1,3   D + Chloropicrin $ 32,880 $ 3,325 Metam Sodium $ 34,931 $ 5,192 Chloropicrin $ 32,880 $ 3,325 SOUTHEASTERN US Methyl Bromide $ 40,914 $ 14,533 1,3   D + Chloropicrin $ 33,772 $ 8,825 MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA METHYL BROMIDE METAM SODIUM PRODUCTION LOSS (%) 0% 15% 20%

PRODUCTION PER HECTARE 11,532 9,802 9,225 * PRICE PER UNIT ( US$) $ 7.17 $ 7.17 $ 7.17 = GROSS REVENUE PER HECTARE ( US$) $ 82,719 $ 70,311 $ 66,175  OPERATING COSTS PER HECTARE ( US$)** $ 57,004 $ 49,990 $ 48,197 = NET REVENUE PER HECTARE ( US$) $ 25,712 $ 20,321 $ 17,978 FIVE LOSS MEASURES * 1. LOSS PER HECTARE ( US$) $  $ 5,391 $ 7,733 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $  $ 22 $ 32 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 7% 9%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 21% 30%

5. OPERATING PROFIT MARGIN (%) 40% 29% 27%

** Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. Page 51 MICHIGAN  TABLE E. 2: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN METHYL BROMIDE 1,3 D + PIC METAM SODIUM CHLOROPICRIN PRODUCTION LOSS (%) 0% 6% 13% 6%

PRODUCTION PER HECTARE 4,414 4,132 3,845 4,132 * PRICE PER UNIT ( US$) $ 9.44 $ 9.44 $ 9.44 $ 9.448 = GROSS REVENUE PER HECTARE ( US$) $ 41,652 $ 38986 $ 36,279 $ 38986  OPERATING COSTS PER HECTARE ( US$)** $ 37,055 $ 32453 $ 31,170 $ 32,453 = NET REVENUE PER HECTARE ( US$) $ 4596 $ 6,533 $ 5,109 $ 6,533 FIVE LOSS MEASURES *

1. LOSS PER HECTARE ( US$) $  $ 1,937 $ 512 $ 1,937 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $  $ 16 $ 4 $ 16 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 5% 1% 5%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 42% 11% 42%

5. OPERATING PROFIT MARGIN (%) 11% 17% 14% 17%

** Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. Page 52 SOUTHEASTERN US  TABLE E. 3: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES SOUTHEASTERN US METHYL BROMIDE 1,3 D + PIC PRODUCTION LOSS (%) 0% 6%

PRODUCTION PER HECTARE 4,551 4,269 * PRICE PER UNIT ( US$) $ 10 $ 10 = GROSS REVENUE PER HECTARE ( US$) $ 46,986 $ 44,073  OPERATING COSTS PER HECTARE ( US$)** $ 26,660 $ 29,860 = NET REVENUE PER HECTARE ( US$) $ 20,326 14,212 FIVE LOSS MEASURES *

1. LOSS PER HECTARE ( US$) $  $ 6,113 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $  $ 36 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 13%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 30%

5. OPERATING PROFIT MARGIN (%) 43% 32%

** Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs.

Summary of Economic Feasibility The economic analysis of the tomato application compared data on yields, crop prices, revenues and costs using methyl bromide and using alternative pest control regimens in order to estimate the loss of methyl bromide availability. The alternatives identified as technically feasible  in cases of low pest infestation  by the U. S. are: ( a) 1,3 Dichloropropene and Chloropicrin; ( b) Metam sodium; and ( c) Chloropicrin. Changes in pest control costs for tomatoes are less than 4 percent of total variable costs therefore they would have little impact on any of the economic measures used in the analysis.

The economic factors that really drives the feasibility analysis for fresh market tomato uses of methyl bromide are: ( 1) yield losses, referring to reductions in the quantity produced, ( 2) increased production costs, which may be due to the higher cost of using an alternative, additional pest control requirements, and/ or resulting shifts in other production or harvesting practices ( 3) quality losses, which generally affect the quantity and price received for the goods, and ( 4) missed market windows due to plant back time restrictions, which also affect the quantity and price received for the goods.

The economic reviewers then analyzed crop budgets for pre plant sectors to determine the likely economic impact if methyl bromide were unavailable. Various measures were used to quantify the impacts, including the following:

( 1) Loss per Hectare. For crops, this measure is closely tied to income. It is relatively easy to measure, but may be difficult to interpret in isolation. Page 53 ( 2) Loss per Kilogram of Methyl Bromide. This measure indicates the value of methyl bromide to crop production.

( 3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usually easy to measure, at least over some unit, e. g., a hectare of land or a storage operation. However, high value commodities or crops may provide high revenues but may also entail high costs. Losses of even a small percentage of gross revenues could have important impacts on the profitability of the activity.

( 4) Loss as a Percentage of Net Operating Revenue. We define net cash revenues as gross revenues minus operating costs. This is a very good indicator as to the direct losses of income that may be suffered by the owners or operators of an enterprise. However, operating costs can often be difficult to measure and verify.

( 5) Operating Profit Margin. We define operating profit margin to be net operating revenue divided by gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be difficult to measure and fixed costs even more difficult, therefore fixed costs were not included in the analysis.

These measures represent different ways to assess the economic feasibility of methyl bromide alternatives for methyl bromide users, who are tomato producers in this case. Because producers ( suppliers) represent an integral part of any definition of a market, we interpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using methyl bromide. The economic measures provide the basis for making that determination.

California We conclude that, at present, no economically feasible alternatives to MeBr exist for use in California tomato production. We have quantified the economic conditions of tomato growers as best as possible but, primarily due to limited data availability, are unable to capture every aspect of the economic picture in our numeric analysis. Factors not accounted for in this analysis are distribution of yield loss across individual growers and the yield risk associated with using MeBr alternatives.

Michigan We conclude that, at present, no economically feasible alternatives to MeBr exist for use in Michigan tomato production. Three factors have proven most important in our conclusion. These are yield loss, quality loss, and missed market windows.

Our analysis of this effect is based on the fact that prices farmers receive for their tomatoes vary widely over the course of the growing season. Driving these fluctuations are the forces of supply and demand. Early in the growing season, when relatively few tomatoes are harvested, the supply is at is lowest and the market price is at its highest. As harvested quantities increase, the price declines. In order to maximize their revenues, tomato growers manage their production systems with the goal of harvesting the largest Page 54 possible quantity of tomatoes when the prices are at their highs. The ability to sell produce at these higher prices makes a significant contribution toward the profitability of tomato operations.

To describe these conditions in Michigan tomato production, we used daily tomato sales data from the U. S. Department of Agriculture for the previous year to gauge the impact of early season price fluctuations on gross revenues. Though data availability is limiting, we assume that if tomato growers adjust the timing of their production system, as required when using 1,3 D + Chloropicrin or Metam Sodium or Chloropicrin, that they will, over the course of the growing season, accumulate gross revenues reduced by approximately 4~ 11%. We reduced the season average price by 4~ 11% in our analysis of the alternatives to reflect this. Based on currently available information, we believe this reduction in gross revenues serves as a reasonable indicator of the typical effect of planting delays resulting when MeBr alternatives are used in Michigan.

Southeastern US We conclude that, at present, no economically feasible alternatives to MeBr exist for use in Southeastern US tomato production. Two factors have proven most important in our conclusion. These are yield loss and missed market windows.

Our analysis of this effect is based on the fact that prices farmers receive for their tomatoes vary widely over the course of the growing season. Driving these fluctuations are the forces of supply and demand. Early in the growing season, when relatively few tomatoes are harvested, the supply is at is lowest and the market price is at its highest. As harvested quantities increase, the price declines. In order to maximize their revenues, tomato growers manage their production systems with the goal of harvesting the largest possible quantity of tomatoes when the prices are at their highs. The ability to sell produce at these higher prices makes a significant contribution toward the profitability of tomato operations.

To describe these conditions in Southeastern US tomato production, we used weekly tomato sales data from the U. S. Department of Agriculture for the previous three years to gauge the impact of early season price fluctuations on gross revenues. Though data availability is limiting, we assume that if tomato growers adjust the timing of their production system, as required when using 1,3 D + Chloropicrin, that they will, over the course of the growing season, accumulate gross revenues reduced by approximately 12%. We reduced the season average price by 12% in our analysis of the alternatives to reflect this. Based on currently available information, we believe this reduction in gross revenues serves as a reasonable indicator of the typical effect of planting delays resulting when MeBr alternatives are used in Southeastern US.

Question 34. In Michigan, the key pests are Phytophthora capsici and Verticillium. The Party states that 1,3 Dichloropicrin may be an effective alternative but growers will miss the optimal market window. The Party is requested to clarify why this problem cannot be overcome by scheduling fumigations in autumn prior to the crop.

ANSWER: The proposal by MBTOC to obviate the use of methyl bromide in Michigan by applying some alternative ( specifically a combination of 1,3 D and chloropicrin) in the autumn preceding crop planting will not work on tomatoes. In Michigan, the predominant agricultural treatment that uses methyl bromide is one where methyl bromide is applied in strips of raised beds. Areas between the Page 55 raised beds are not treated. In addition to the risk that the harsh winter conditions ( prolonged periods of below freezing weather with snow, sleet, and high winds) will tear the plastic barrier, there is significant risk of flooding and concomitant recontamination of the treated areas. The length and severity of the winter means 4 5 months of precipitation is ` stored' in frozen form and released over the short period of thaw in the spring. This thaw based flooding can be exacerbated by heavy rainfalls ( in excess of 25 mm/ event) that occur throughout the spring and summer in Michigan. Because Phytophthora and Verticillium diseases are endemic in the areas of Michigan for which methyl bromide is being requested, flooding will transfer spores from the untreated to treated areas, resulting in additional infected plants and severe crop losses.

There are two additional problems which prevent a fall application of a methyl bromide alternative from being a viable alternative to the current practice. Deer walk across the fields, making holes in the plastic. Mice also burrow under the plastic. Once underneath they chew the drip tapes, rendering them inoperative and make burrows where they are in an ideal position to eat the newly planted material in the spring.

Question 35. In the Southeast, including Florida, nematodes, soil borne fungi and nutsedge are the key pests. The Party states that a combination of 1,3D + chloropicrin + herbicides ( trifluralin, napropamide, halosulfuron, S metolachlor) is the best alternative strategy, but further testing is required. However, the Party estimates yield losses of 6.2% and market window losses of 14% due to delays in plant back after treatment. This combination is not available to areas with karst topography ( 32 % of the production). The Party is requested to provide yield and market window data for other alternatives.

ANSWER: Please see the answer to question 33 above Question 36. Owing to the lack of data from recent trials in the south east region provided with the nomination, MBTOC cannot fully evaluate the effectiveness of alternatives for moderate to heavy nutgrass infestations. New technical review and economic data based on the yields from recent studies is requested.

ANSWER: In Florida Gilreath et al 2003 looked at methyl bromide plus chloropicrin ( 350 lb per acre of 67: 33) versus 1,3 D 35% Pic/ trifluralin/ napropamide/ chloropicrin ( 28 gal/ 0.5 lb/ 2 lb/ 125 lb) for pepper yield. While the yields were not significantly different there was a 14 to 13 percent yield loss compared to methyl bromide plus chloropicrin. In addition this alternative treatment with additional chemicals will require extra time to apply the other pesticides and allow the second application of chloropicrin to off gas so that the transplants are not killed. This additional time delay would lead to impacts in terms of the key market windows.

Table 22. Tomato yields are not significantly different but percent yield loss can be large Bradenton Immokalee Treatment Marketable % Yield Marketable % Yield Page 56 Yield ( pound per 10 plants) Change versus MeBr Yield ( pound per 10 plants) Change versus MeBr Untreated 51  56% 108  16% Methyl bromide: chloropicrin ( 350 lb of 67: 33) 117 0% 128 0%

1,3 D 35% Pic + trifluralin + napropamide + chloropicrin ( 28 gal/ 0.5 lb/ 2 lb/ 125 lb) 101  14% 112  13%

Footnote: From Gilreath et al. 2003. Proc. Fla. State Hort. Soc.

One of the studies that MBTOC cites is from Florida ( Gilreath et al, 2005a), which looked at the impact of reduced rates of MB on pest control and pepper yield. In that study, which had high Cyperus spp. pressure, there were no significant differences in yield between any of the rates of methyl bromide with the different types of films. However, an examination of the change in yield with VIF treatments, compared to the standard MB treatments, suggests significant variability within treatments, which led to the lack of statistical significance in yield despite the large numerical differences in yield between treatments. Trials such as those conducted by Gilreath et al ( 2005 a) with peppers, need to be conducted over several seasons, and preferably with different crops. The reality of the use of VIF for the 2007 season is its current prohibitive cost in the U. S., and even more significant, its lack of availability for use on a commercial scale. The Party does not anticipate these issues can be adequately resolved before the critical use season of 2007.

Table 23. Pepper yields are not significantly different but percent yield loss can be large. Treatment App Rate kg/ ha Yield t/ ha % Change 1 Untreated 9.5  31% 2 MeBr + Pic LDPE 392 13.8 0% 3 MeBr + Pic VIFP 196 10.8  22% 4 MeBr + Pic VIFP 98 13.6 1% 5 MeBr + Pic VIFV 196 11.4  17% 6 MeBr + Pic VIFV 98 11.9  14% Footnote: From Gilreath et al. 2005. Crop Protection 24: 285 287. LDPE is low density polyethylene, VIFP and VIFV are virtually impermeable film by Plastopil and Vikase respectively.

The research plots that several MBTOC members visited in Florida in 2005 clearly demonstrated that chloropicrin will not control sedges such as Cyperus esculentus or C. rotundus . Research by Gilreath and communications with him indicate that chloropicrin enhances nutsedge germination ( this research has yet to be repeated for other pest species). Therefore, increasing the amount of chloropicrin applied can increase pest pressure and yield loss.

Another study by Gilreath, Santos, Motis, Noling and Mirusso ( 2005) looks at nematode and Cyperus control in bell pepper ( Capsicum annum). In that study the authors state " For bell pepper Page 57 yield, the application of metam sodium and metam sodium + chloropicrin provided similar fruit weight as for methyl bromide + chloropicrin in two of the three seasons." However, in that one year ( Fall 2002) the yields went from 18.8 t/ ha for methyl bromide + chloropicrin to 13.7 t/ ha for metam sodium + chloropicrin or a 27% drop in yield. This level of yield loss could have severe economic impacts for a grower. Because of the inconsistency of some of the alternative treatments the U. S. does not consider them to be a replacement for methyl bromide. The work of Johnson and Webster ( 2001) as described in Question 12 above indicated that for metam sodium the time of application before transplanting, rate, and type of incorporation equipment can all have a significant impact on the chemicals performance.

Question 37. Recent references available to MBTOC demonstrate effective alternatives ( metham sodium, with and without Pic) for moderate to heavy nutgrass control in similar regions to the nomination and for non karst and karst areas ( Johnson and Webster, 2001 ; Gilreath et a12005 b, c). As yields were similar to methyl bromide, further clarification is required on their suitability for commercial use,

ANSWER: The work of Johnson and Webster ( 2001) published in Weed Technology describes a modification to a power tiller for improved metham application. In this study across the control of yellow nutsedge was evaluated with the untreated control areas averaging 88 plants/ m2 and across all tillage treatments and cultivars, there was an average of 2.7 nutsedge plants/ m2 . See also the description of the Gilreath et al 2005 research in question 36 above.

Question 38. For all areas the dosage range is close to or below MBTOC guideline rates: Growers may be able to reduce dosages to about 100 kg/ ha under strips by adoption of low permeability barrier films ( VIF or equivalent) and by adopting formulations of MB/ Pic with less MB ( e. g. 50: 50). Recent trials are evaluating use of these products and an update of these is requested to further assist assessment of this nomination.

ANSWER: One of the studies that MBTOC cites is from Florida ( Gilreath et al, 2005a), which looked at the impact of reduced rates of MB on pest control and pepper yield. In that study, which had high Cyperus spp. pressure, there were no significant differences in yield between any of the rates of methyl bromide with the different types of films. However, an examination of the change in yield with VIF treatments, compared to the standard MB treatments, suggests significant variability within treatments, which led to the lack of statistical significance in yield despite the large numerical differences in yield between treatments. Trials such as those conducted by Gilreath et al ( 2005a) with peppers, need to be conducted over several seasons, and preferably with different crops. The reality of the use of VIF for the 2007 season is its current prohibitive cost in the U. S., and even more significant, its lack of availability for use on a commercial scale. The Party does not anticipate these issues can be adequately resolved before the critical use season of 2007. Page 58 Table 24. Pepper yields are not significantly different but percent yield loss can be large. Treatment App Rate kg/ ha Yield t/ ha % Change 1 Untreated 9.5  31% 2 MeBr + Pic LDPE 392 13.8 0% 3 MeBr + Pic VIFP 196 10.8  22% 4 MeBr + Pic VIFP 98 13.6 1% 5 MeBr + Pic VIFV 196 11.4  17% 6 MeBr + Pic VIFV 98 11.9  14% Footnote: From Gilreath et al. 2005. Crop Protection 24: 285 287. LDPE is low density polyethylene, VIFP and VIFV are virtually impermeable film by Plastopil and Vikase respectively.

The research plots that several MBTOC members visited in Florida in 2005 clearly demonstrated that chloropicrin will not control sedges such as Cyperus esculentus or C. rotundus . Research by Gilreath and communications with him indicate that chloropicrin enhances nutsedge germination ( this research has yet to be repeated for other pest species). Therefore, increasing the amount of chloropicrin applied can increase pest pressure and yield loss. Page 59 REFERENCES Culpepper, A. S. and D. B. Langston. 2004. Potential impact of methyl bromide alternatives on Georgia's pepper industry. Department of Crop and Soil Sciences and Department of Plant Pathology, University of Georgia, Tifton, GA 31793. E mail message.

Culpepper, A. S., T. M. Webster, D. Langston. 2004 & 2005. E mail from W. T. Kelley. August 15, 2005. Univ. of Georgia Gilreath, J. P. and P. R. Gilreath. 2005. Successful use of reduced rates of methyl bromide in vegetable crops. Citrus and Vegetable Magazine. August 2005.

Gilreath, J. P., J. P. Jones, T. N. Motis, B. M. Santos, J. W. Noling, and E. R. Rosskopp. 2003. Evaluation of various chemical treatment for potential as methyl bromide replacements for disinfestations of soilborne pests in polyethylene mulched tomato. Proc. Fla. State Hort. Soc. 116: 151 158.

Gilreath, J. P., T. N. Motis, and B. M. Santos. 2005. Cyperus spp. Control with reduced methyl bromide plus chloropicrin doses under virtually impermeable films in pepper. Crop Prot. 24: 285 287.

Gilreath, J. P. B. M. Santos, T. M. Motis, J. W. Noling, and J. M. Mirusso. ( 2005) Methyl bromide alternatives for nematode and Cyperus control in bell pepper ( Capsicum annul). Crop Prot. 24: in press.

Grey, T. L., A. S. Culpepper, and T. M. Webster. 2003. Fall vegetable response to halosulfuron, metolachlor, and sulfentrazone spring applied under plastic. Proc. Southern Weed Science Society. Volt 56: 116 117.

Hamill, J. E., Dickson, D. W., T Our, L., Allen, L. H., Burrell, N. K., and Mendes, M. L. 2004. Reduced rates of MBR and C35 under LDPE and VIF for control of soil pests and pathogens. 2004 Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. Available online at http:// www. mbao. org/ 2004/ Proceedings04/ 002% 20HamillJ% 20MBr% 20alternatives% 20abstr_ 04. pdf].

Johnson III, W. C. and T. M. Webster. 2001. A Modified Power Tiller for Metham Application on Cucurbit Crops Transplanted to Polyethylene Covered Seedbeds. Weed Technology: Vol. 15, No. 2, pp. 387   395 Johnson III, W. C. 2003. Yellow nutsedge control with metham sodium in transplanted cantaloupe. Proc. Southern Weed Science Society. Volt 56: 109. Page 60 Noling, J. W. and Gilreath, J. P. 2004. Use of virtually impermeable plastic mulches ( VIF) in Florida strawberries. 2004 Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. Available online at http:// www. mbao. org/ 2004/ Proceedings04/ 001% 20Noling% 20paper. pdf Rosskopf, E. N., Chillum, D. O., Kokalis Burelle, N., and Church, G. T. 2005. Alternatives to methyl bromide: A Florida perspective. American Phytopathological Society. APSnet Feature, June, 2005. Available online at: http:// www. apsnet. org/ online/ feature/ methylbromide/ Page 61 Appendix I Summary of Weyerhaeser Company Research Summary of recent ( 2002 2005) Weyerhaeuser Company research studies concerning MB, fumigation efficacy, herbicides and alternatives to methyl bromide studies that pertain to the submitted questions.

2002 Weyerhaeuser R& D Activities on Fumigation, Disease and Trials 2003 25 Fumigation Alternative Trial ( Mima, WA). MBC 67: 33 ( 350lbs/ ac) was tested against Triform 35( 400lbs/ ac Telone 61.1% PIC 35% : no Metam Sodium applied due to lack of application equipment) in the fall 2000. Post fumigation testing ( Study 2001 25) spring 2001 showed no significant difference in soil Fusarium populations. Soil testing in the fall of 2002, again showed very low levels of soil Fusarium. Root infection was analyzed several months into 1+ 1 transplant growing season ( August 2002). Root infection by Fusarium was low and not significantly different between treatments ( 1.9% versus 2.5% MBC and Triform respectively). Root infection by Cylindrocarpon was significantly lower in Triform ( 1.5%) than in MBC ( 25.1%) treated plots.

Interpretations: Soil pathogen assays are used to estimate the need for and assess the efficacy of soil fumigation chemicals. Based on this and previous tests, these two fumigants appear to be equal in efficacy. Clearly, this study indicates that reliance on a single bioassay organism ( Fusarium) can lead to this conclusion, while tests for another root pathogen yield somewhat different results. Reliance on a single fumigant agent could potentially result in development of resistant strains or selection for another pathogen agent.

2003 25 Fumigation Alternative Trial ( GHW, NC). MBC 98: 2, Telone PIC, and PIC fall 2001 fumigation efficacy was tested on previous soils left bare fallow for 6 months. Soils and seedlings were analyzed for pathogen levels in the fall of 2002. There was no significant difference in soil Fusarium levels detected at lift ( 128, 156, and 98 CFU/ g respectively). Seedling root infection severity was also low ( 6%, 6.8%, 8.6% respectively) and not significantly different between treatments. No Pythium was detected in soil or seedling assays.

Interpretations: Under these ideal fall fumigation conditions, low pre fumigation pathogen populations, low weed pressure, and methods of application, MBC, Telone PIC and PIC are acceptable alternatives as soil fumigants. Page 62 2002 5,6,7,8 Pre Sow Pathogen Testing ( N. C., AR., S. C., AL). Soil pathogen testing shows variable spring 2002 Fusarium populations prior to sowing at four facilities. Samples were compared against the fumigation management threshold of < 1000 CFU/ g soil). Pine Hill nursery shows 5/ 18 samples within the threshold ( top range 508 1142 CFU/ g soil). GHW samples ( n= 6) all tested below the threshold ( all samples < 417 CFU/ g soil). Aiken had 3/ 13 areas test within the threshold ( range 700 1500 CFU/ g soil). Magnolia reported with 8/ 10 within the threshold ( range 595 3825 CFU/ g soil).

Interpretations: Sow ground should be managed below 1000 CFU/ g Fusarium in the spring to achieve a healthy pine crop. Soil testing of potential crop areas can help to identify areas that should be further tested for pathogen uniformity or left fallow. Disease avoidance is another mechanism of preventative action when sow acreage is not limited, too little time remains for safe and effective fumigation, or areas of unexpected disease develop 2002 15 Post Fumigation Testing ( S. C). Soil pathogen testing in the spring following fall application of MBC 98: 2 shows detectable Fusarium levels in 8/ 12 sample locations ( range CFU/ g 27 365 ).

Interpretations: Re invasion of fumigated soil can occur from above and below the fumigation treatment profile. Good soil sanitation processes are needed to limit cross contamination of treated and non treated fields by equipment, overland water and soil movement, and incorporation of nontreated edge soils into treated areas.

2002 20 Alternative Fumigant Testing ( AR). Continuation of Studies ( 2000 47, 54, Study 2002 31) Soil pathogen testing following fall 2000 application of MBC ( 98: 2), PIC ( 100%) and Telone PIC ( 70: 30) showed no significant difference in post treatment efficacy in areas that contained low threshold levels of soil Fusarium ( pre treatment levels; MBC 272 1170 CFU/ g; PIC 0 798 CFU/ g; and Telone PIC 0 506 CFU/ g soil respectively). At pre sow 2001, Fusarium was detected in 3/ 10, 1/ 10, and 1/ 10 sample locations for MBC, PIC, and Telone PIC respectively ( levels 44 431 CFU/ g soil). Sampling resumed spring 2002 following the 2001 pine crop cycle. Soil Fusarium levels were similar in all three treatment areas ( MBC 243 CFU/ g, PIC 140 CFU/ g, and Telone PIC 261 CFU/ g soil). Seedling root infection by Fusarium was not significantly different between treatments, but a trend towards higher root infection occurred between MBC ( 19% root infection), PIC ( 17%) and Telone PIC ( 10%).

Interpretations: MBC, PIC and Telone PIC produce equivalent fumigation results across management blocks with low threshold levels of Fusarium as the target organism. The longer term crop to crop rotation length based on soil Fusarium population dynamics appears similar when these agents are used in the prescribed manner. Page 63 2002 49 Fumigation Efficacy ( GHW, NC). Routine sampling post fumigation soil pathogen analysis was done to test the efficacy of contractor applied MBC 98: 2. Some 40% of the samples returned detectable levels of Fusarium ( 43 362 CFU/ g) one month post fumigation. These soils were retested again in March 2003 as part of Study 2003 1. These results also confirmed some residual Fusarium populations post fumigation.

Interpretations: Complete control of soil pathogen populations is essential to initiation of the next 3 4 seedling crop cycles. The detected pathogen pattern might reflect under treated areas, overlaps zones of tarping, fumigation strips, edge effects, and or soil and water movement post fumigation ( wind, water, mechanical). These issues will be more critical with less effective fumigants and potentially result in larger " under treated" areas.

2002 50 Fumigation Efficacy ( S. C.). Routine sampling post fumigation soil pathogen analysis was done to test the efficacy of contractor applied MBC 98: 2 in two management units. Pivot 1 5 showed ½ of the area with a post treatment efficacy of 65 80% and 100% in the remaining areas. Pivot 1 6 showed 53 84% efficacy on ½ of the area with the remaining sample at 100%.

Interpretations: Incomplete efficacy of MBC is often linked to failure to achieve label rates due to penetration or retention issues. The cause was not investigated at the time of the fumigation, but appears to be a common practice with the fumigation being done in any given year.

2002 51 Pathogen Testing ( Pine Hill AL). Routine pre fumigation soil pathogen analysis was done to test crop areas in three production blocks. Block 1 ( 909 CFU/ g soil) and Block 2 ( 668 CFU/ g) showed much elevated Fusarium levels than Block 4 at 173 CFU/ g.

Interpretations: Variation in soil Fusarium populations increase following the period since last fumigation. Historical data along with new specific sampling information from specific nursery blocks are the best management tool to decide on when and where to fumigate.

2003 25 Fumigation Versus Bare Fallow ( Mima, WA). Block 8 was spring fumigated with 350lb/ ac MBC ( 67: 33) following 1 year in bare fallow ( Roundup Treated Spring 2002). The field had been previously cropped for 1 year following MBC fumigation, then allowed to remain fallow through the next crop year and brought back into crop rotation in the spring of 2002. Roundup ( Glyphosate) was applied 30 days prior to fumigation to kill surface weeds. Soil and root residual pathogen analysis ( Fusarium, Pythium, Cylindrocarpon) was conducted prior to fumigation planning. These results showed no detectable pathogen population on 2/ 3rd of the field, but some elevated levels on a normally wet end, some 150 feet in length. MBC 67: 33 was applied to the wet area and tarped. Douglas fir 1 year old seedlings were transplanted in spring 2002 to grow 1+ 1 regeneration stock. Page 64 Severe stem and needle stunt symptoms began to develop in late June and into July in the nonfumigated portions of the field. Soil and foliar analysis did not detect any nutrient based causal factors. Root necrosis associated with elevated levels of Cylindrocarpon didymum and Fusarium oxysporum on transplants were determined to be the most likely pathogen agents. All attempts to correct seedling growth and development with fertilizers, fungicides, and irrigation failed. Substantial portions of the field seedlings did not meet regeneration standards, and had to be destroyed. The fumigation portion was nearly 90+% packable.

Interpretations: 1 year bare fallow was insufficient to reduce disease levels below thresholds for disease development. Glyphosate, although an effective herbicide on surface weeds may also play a synergistic role in plant disease development, by interfering with normal plant phenolic metabolism. Soil and root residual pathogen testing is not always a reliable measure of soil disease potential. Page 65 2003 Weyerhaeuser R& D Activities on Fumigation, Disease and Trials 2003 2 Fumigation Threshold Testing ( AR). Areas of Blocks 7, 8, and 10 were sampled for Fusarium levels to indicate the need for fumigation. Two units within Block 10 contained sufficient Fusarium ( 800 1400 CFU/ g soil) to justify soil fumigation.

Interpretations: Soil pathogen assays are used to estimate the need for and assess the efficacy of soil fumigation chemicals. Based on this sample, much of the crop area would not benefit from soil fumigation at this time.

2003 12 Fumigation Threshold Testing ( S. C.). Soil sampling across portions of Pivot 3 show variable levels of soil Fusarium. Three of 18 areas tested greater than 400 CFU/ g soil, where the decision to fumigation can sometimes begin.

Interpretations: The soil sampling method and testing allows for the planning for most effective use of MBC in the nursery. This pivot area needs to be resampled to determine the validity of high soil Fusarium levels detected in portions of a production field, while other areas appear to be safe for cropping.

2003 18 Fumigation Threshold Testing ( AL). Soil sampling across portions of Blocks 10 and 19 show low levels of soil Fusarium ( 0 220 CFU/ g soil). These soils are well within the safe zone for pine seedbed production.

Interpretations: The soil sampling method and testing allows for the effective soil management decision making.

2003 25 Pathogen Contributions Packing Room ( Turner, OR). Soil sampling across fumigated and non fumigated portions of Block1, 2 and 3 show low levels of soil Fusarium ( 0 223 CFU/ g soil). Variation was minimal within blocks and even in immediately adjacent non fumigated areas. These soils are well within the safe zone for Douglas fir transplant production. Soil and the roots from the packing room was collected and tested for Fusarium, Pythium, and Cylindrocarpon. Direct isolation from sample root fragments was compared with levels of each fungus " baited" using sterile autoclaved Douglas fir roots.

Roughly 10% of the root residues from fumigated and non fumigated areas yielded Pythium, although fewer roots could be recovered from the non fumigated areas ( previous crop residuals). Pack room root residuals yielded Pythium from 17% of the isolation attempts. Attempts to bait it from soil was only successful in one fumigated sample, but several non fumigated samples and more so from the soil in the packing room.

Fusarium was isolated from about 3% of the root residuals and did not show any pattern to fumigation or packing room samples. Baiting reduced the isolation frequency to about 1.5%. Page 66 Cylindrocarpon represented some 4% of the root fragment isolates and there was no pattern to root residual source. Attempts to bait this fungus yielded low results.

Interpretations: Seedling harvest activities yields many pounds of soil and root fragments as a consequence of lifting and storing regeneration stock. It is common practice to return these residues to fields that will be fallow or fumigated during the next crop cycle, but some facilities will compost the residues prior to land application. These residue potentially harbor considerable reservoirs of pathogens, especially if the field is further into the fumigation rotation. In this example, even though the fields show low levels of all three pathogens they might still be expected to increase once applied to soils. Proper sanitation procedures dictate not returning these soils or roots to production fields.

2003 34 Alternative Fumigation Testing ( AR). Soil sampling in June following fall fumigation at Magnolia with MBC ( 98: 2), Telone PIC and PIC show no significant differences in soil Fusarium levels ( 158 CFU/ g, 91 CFU/ g, and 82 CFU/ g respectively).

Interpretations: The replication of tests between facilities is needed to fully understand the potential for alternative agents to serve as replacements for MB. This test confirms previous data on the efficacy of Telone PIC and PIC as soil fumigants under normative prescriptions for soil fumigation. Page 67 2004 Weyerhaeuser R& D Activities on Fumigation, Disease and Trials 2004 15 Fumigation Skip Investigation ( Mima, WA). Soil sampling in spring in Blk 14 was initiated after a circular weedy patch ( roughly 100 sq ft) developed in a field treated with MBC 67: 33 the previous fall. Sampling and around the weedy area turned up no significant pathogen ( Fusarium, Cylindrocarpon) population.

Interpretations: The sampling satisfies concerns over a fumigation skip. Weed invasion is more likely associated with equipment or soil movement.

2004 16 Nursery Pathogen Management ( AL). Soil sampling in spring across 18 Pine Hill nursery growing blocks shows the within facility variation in pathogen occurrence by field management and past fumigation history. In eight fields ( 44%) pathogen levels were categorized as low to not detectable (< 100 CFU/ g soil). Seven fields ( 39%) tested within the low to moderate range ( 100 400 CFU/ g soil). Three fields were within the target threshold for cropping ( 600 1205 CFU/ g soil), and would most likely be in need of fumigation after the next crop cycle.

Interpretations: Block management is an important factor in achieving consistent crop production. Fall fumigation has been proven to be more effective than spring fumigation owing to optimal chemical, climatic and cultural aspects. It is prudent for a facility to maintain a large percentage of its production ground in a state of " disease free" growing, represented here by pathogen population estimates. This allows for better identification, timing and optimal fumigation on the nursery areas outside the normative prescription for pathogens.

2004 38; 2004 62, 2004 64 Alternative Fumigation Testing ( Aurora, OR). Soil sampling in June following fall fumigation at MBC ( 67: 33), Telone PIC and PIC show no significant differences in soil Fusarium levels in Douglas fir seedbeds ( 0 CFU/ g, 93 CFU/ g, and 34 CFU/ g respectively). Samples were taken in December of 2004 ( Study 2004 62) to determine Fusarium levels at the end the growing season. These results show that after 1 year in crop the soil levels had raised to 315 CFU/ g soil ( MBC), 167 CRU/ g ( Telone PIC); and 176 CFU/ g ( PIC). Seedling infection levels ( Study 2004 64) pathogen and non pathogen fungal groups were determined. Differences between fumigation treatments were not significant. Isolation of Fusarium oxysporum from roots declined from 4.6% ( PIC), 5.1% ( Telone PIC) to 9.7% with MBC 67: 33. Isolation frequency of Fusarium roseum ( 1.6 2.3%), Phoma sp. ( 19 22.6%), and Cylindrocarpon ( 0 0.3%) varied little by treatment.

Interpretations: Fumigation with MBC, Telone PIC or PIC demonstrates similar pathogen control in soils of widely varying texture and composition. Under these culture conditions the build up post treatment and infections levels that result appear similar for all three fumigants. Page 68 2004 63 Alternative Fumigation Testing ( Mima, WA). Soil sampling in December from soils treated with MBC ( 67: 33), PIC ( 350lbs/ ac) or Metam Sodium ( 100 gal/ ac) showed varied results to pathogen abundance. Fusarium was not detected in plots taken in MBC fumigated ground, while C350 contained background levels ( 55 CFU/ g soil) and slightly higher for Metam ( 181 CFU/ g soil). Phoma was far more common as a soil isolate in Metam treated soil ( 2173 CFU/ g) than C350 ( 1403 CFU/ g) or MBC ( 667 CFU/ g). Cylindrocarpon was only detected in 3 plots all treated with MBC ( 18 CFU/ g soil).

Interpretations: Most testing for fumigation efficacy has been done with a specific " target" pathogen, in most examples, Fusarium oxysporum. This study provides some evidence that this technique may be a technology shortcoming, and that not all pathogenic fungi are controlled in the same manner. This also provides some clues as to the appearance and dominance of Cylindrocarpon in some nursery production blocks, where it seemingly had not existed before. These results might further support the need for rotation of fumigants, rates, or fumigant mixtures, not merely selection of the " next" best fumigant. Further testing is needed to understand the shortcomings of a particular fumigant and the conditions which facilitate pathogen escape.

2004 71 Alternative Fumigation Test ( Mima, WA). Soil sampling was conducted in Blk 12 during the late fall after being treated with MBC ( 67: 33) or with increasing levels of PIC ( 150lbs/ ac, 250 lbs/ ac, and 350 labs/ ac). Post treatment soil Fusarium was very low ( 11 43 CFU/ g) and not significantly different between treatment plots. In contrast, Phoma was very high ( 1790 4675 CFU/ g) and not consistent with increasing fumigation rates. Cylindrocarpon was low ( 0 27 CFU/ g soil) in all treatments.

Interpretations: The information provided in this analysis shows that pathogen response to various fumigants, and rates of application may be more variable than previously thought. Control for one target organism may fit the expectation of the sanitation process, while another organism is not controlled to any degree. The long term interactions of differential pathogen control remains to be examined and understood. Page 69 Appendix II Economic information for Michigan Herbaceous Perennials REGION H  MICHIGAN HERBACEOUS PERENNIALS  TABLE E. 8: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES Region H  Michigan Herbaceous Perennials Methyl Bromide Various Alternatives** Yield Loss (%) 0% 5% Yield per Hectare Conifer Seedlings 144,920 137,674 * Price per Unit ( U. S. $/ seedling) $ 0.97 $ 0.97 = Gross Revenue per Proportion ( 60%) $ 140,956 $ 133,908  Operating Cost per Hectare ( U. S. $) $ 37,311 $ 58,414 = Net Revenue per Hectare ( U. S. $) $ 103,645 $ 75,494 Loss Measures 1. Loss per Hectare ( U. S. $) $ 0 $ 28,151 2. Loss per Kilogram of Methyl Bromide ( U. S. $) $ 0 $ 143.52 3. Loss as a Percentage of Gross Revenue (%) 0% 21%

4. Loss as a Percentage of Net Revenue (%) 0% 37% ** The category Various Alternatives includes physical removal and sanitation, the use of artificial media, and soil treatment with 1,3 D + chloropicrin. Page 70 Alternative:

A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2)

Operation or Input Quantity used per acre Units ( lbs,

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

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 768.00 Fumigation product application Irrigation Bulb crates and media 11,293 crates $ 2.50 28,233.00 Seedlings 67,760 plants $ 0.80 67,760.00 Cultural Operations Fertilizer/ soil amendments 450 lbs $ 1.00 498.00 450 lbs $ 1.00 498.00 Pesticides Insecticide Herbicide Fungicide Nematicide Irrigation 32 man hours $ 15.00 480.00 32 man hours $ 15.00 480.00 Interest on Land Prep Charges 11,525 7.00% 807.00 11,525 7.00% 807.00 Interest on Operating Capital 98,950 6.00% 1,989.00 16,278 6.00% 488.00 Hand Weeding 96 man hours $ 12.00 1,152.00 96 man hours $ 12.00 1,152.00 Dept of Ag Inspection 20.00 20 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Labor and Hauling 1,440.00 Storage Cost 3,750.00 Processing 0.03 271040 8,131.00 EPA Form # 7620 18a 16,766.00 $ 118,474.00 $ Year 1 & 2 Total Cost Per Acre 101,707.00 $ OMB Control # 2060 0482 Worksheet 3 B2 ( 3). Alternatives  Changes in Operating Costs for Perennial Crops PRE PRODUCTION YEAR 1 Harvest Year 2 Grown In Artificial Media on Acreage Prepared as Container Field ( Soiless culture/ plugs substrates) Page 71 Economists Comments for worksheet 3 B2( 3)   Artificial media on Acreage Prepared as Container Field Soiless culture/ plugs substrates)

Year 1   Land preparation: Container field preparation  $ 10,000 for leveling, draining, gravel roads, etc. and $ 0.05 per square foot ( 70% of acreage) for ground mat depreciated over 15 years.

  Bulb crates and media: $ 1 per crate and $ 1.50 for soil in crate   a crate is 2.7 sq ft and they cover 70% of the sq ft in an acre.

  Field clean up: Labor to pick up plastic, plastic disposal fee and tractor & trailer use ( custom rate).

  Seedlings: Plants and planting costs. Takes 5 seconds per plant to put into bulb crates.

  Fertilizer/ soil amendments: Includes material and application cost ( 1 hr/ ac @ $ 12 4x).

  Irrigation: Labor to water about 2 " per week June 1 Sept 30.

  Interest on Operating Capital: Assume grower borrows half of variable expenses for 8 months in Year 1 and 12 months in Year 2.

Year 2   Labor and Handling: Includes loading crates, hauling on trailer to polyhouse and unloading ( 120 person hrs/ ac). Page 72 A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2)

Operation or Input Quantity used per acre Units ( lbs,

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

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 170.00 Fumigation product $ 312.50 lbs MB/ ch $ 3.35 1,047.00 application 809.00 Irrigation Seed and Seeding 287.00 Other costs 63.00 63.00 Cultural Operations Fertilizer/ soil amendments 73.00 60.00 Pesticides Insecticide Herbicide 12.00 Fungicide 356.00 Custom application of fungicide $ 12.00 application $ 15.00 180.00 Irrigation 70.00 Hand hoeing & Trimming $ 120 hrs $ 12.00 1440.00 Fuel/ machine labor 115.00 Interst on Operting Capital $ 2,194 6.00% 33.00 $ 7,409 6.00% 167.00 Dept of Ag Inspection 20.00 20.00 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Digging & Transporting 1007 Grading/ packing 1495 Cold Storage 997 Shipping 1329 2,227.00 7,586.00 9,813.00 Year 1 & 2 Total Cost/ Ac EPA Form # 7620 18a Pre Plant Worksheet 2 D( 2a). Methyl Bromide  Baseline  Operating Costs for Perennial Crops  2 Year Seeded INITIAL PRODUCTION YEARS _____

PRE PRODUCTION YEARS _______ Page 73 A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2)

Operation or Input Quantity used per acre Units ( lbs,

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

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 112.00 Fumigation product $ 350.00 lbs MB/ ch $ 3.35 1,173.00 application 632.00 Cover Crops 100.00 Seedlings 38,000 divisions $ 0.03 1,241.00 Other costs 1,624.00 7.00 Cultural Operations Fertilizer/ soil amendments 42.00 150.00 Pesticides Insecticide & Fungicide 150.00 600.00 Custom application of fungicide 3 applic $ 15.00 45.00 $ 15.00 application $ 15.00 225.00 Hand weeding 10 hrs $ 12.00 120.00 $ 40.00 hrs $ 12.00 480.00 Irrigation Labor & Operations 1.5 hrs $ 15.00 23.00 3.5 hrs $ 15.00 53.00 Labor ( manual)

Mechanical Cultivation 10 hrs $ 15.00 173.00 Interest on Operting Capital $ 5,288 6.00% 159.00 $ 7,409 6.00% 405.00 Dept of Ag Inspection 20.00 20.00 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Cutting ( Mechanical Operations) 2.7 hr/ ac $ 15.00 41 Cutting & Packing ( Labor) 522 hrs 12 6,261.00 Equipment Rental Hi Los 435 Truck 495 Trailers 275 Packing Materials 20,000.00 flats 0.21 4305 5,447.00 13,917.00 19,364.00 Year 1 & 2 Total Cost/ Ac EPA Form # 7620 18a Pre Plant Worksheet 2 D( 2b). Methyl Bromide  Baseline  Operating Costs for Perennial Crops  3 Year Transplanted INITIAL PRODUCTION YEARS _____

PRE PRODUCTION YEARS _______ Page 74 A B ( 1) C ( 1) D ( 1) E ( 1) B ( 2) C ( 2) D ( 2) E ( 2)

Operation or Input Quantity used per acre Units ( lbs,

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

hours, etc) Unit Cost Total Cost per Acre Establishment Operations Land preparation 167.00 Fumigation product 400 lbs MB/ ch $ 3.35 1,340.00 application 409.00 Field clean up 135.00 Irrigation Seedlings 50000 plants $ 0.08 40,833.00 Cultural Operations Fertilizer/ soil amendments 450 lbs $ 0.50 243.00 450 lbs $ 0.50 243.00 Pesticides Insecticide Herbicide Fungicide Custom application of fungicide Irrigation 16 man hrs $ 15.00 240.00 Hand hoeing & Trimming 192 man hrs $ 12.00 2,304.00 $ 192 man hrs $ 12.00 2304.00 Fuel/ machine labor Interest on Operating Capital $ 45,691 6.00% 918.00 $ 11,740 6.00% 352.00 Dept of Ag Inspection 20.00 20.00 Harvest Operations Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Constant Cost per Acre Cost per Unit of Yield Yield Total Cost Digging Labor 600 Digging Equipment 633 Storage Cost 1700 Processing 6000 46,609.00 12,092.00 58,701.00 Year 1 & 2 Total Cost/ Ac Worksheet 2 D( 2c). Methyl Bromide  Baseline  Operating Costs for Perennial Crops  2 Year Transplanted Harvest Year 2 PRE PRODUCTION YEAR 1 Page 75 Economist's comments for worksheet 2 D ( 2a)  2 Year Seeded Year 1   Land preparation: Includes soil test, disk, plow, drag, float, apply fert., drag, apply herbicide, disk, drag, float   priced as custom rates so includes some fixed costs.

  Application: Includes custom application, tarp removal, and tarp disposal.

  Other costs: Post planting field prep. And cover crop   cover crop is certified seed to minimize weed contamination   Fertilizer/ soil amendments: Lime and potassium.

  Irrigation: Labor Solid set and hand hose   includes some fixed expense.

  Hand hoeing & Trimming: Includes hoeing ( 1x per month @ ½ ac per hour with 15 people) and trimming.

  Fuel/ machine labor: Field maintenance   cultivation and driveway and ditch maintenance   includes some fixed cost.

  Interest on Operating Capital: Assume grower borrows half of variable expenses for 6 months in Year 1 and 9 months in Year 2.

  Cold Storage: $ 0.90 per sq ft   90 d on # 1 and 50 d on Liners Year 2   Fertilizer/ soil amendments: 28% Nitrogen.

Economist's comments for worksheet 2 D ( 2b) 3 Year Transplant Year 1   Land preparation: Includes soil test, disk, subsoil, plant & disc cover crop, disc, plow, drag.

  Application: Includes custom application cost ( less materials) and plastic disposal and clean up.

  Cover crop: Cover crop seed is certified to minimize weed contamination.

  Planting labor: Includes splitting plants into divisions, transplanting into field and transport to field.

  Equipment Operation ( Planting): Fuel and Maintenance on transplanter.

  Irrigation Labor and Operation: Includes labor ( calculated) plus $ 0.10 per application in electricity & maintenance cost.

  Interest on Operating Capital: Assume grower borrows half of variable expenses for 12 months in Year 1 and 12 months in Year 2.

Year 2   Cutting & Packaging Labor: 150 people per crew for an 8 hour day doing 2.3 ac per day   Equipment rental: 10 hi los, truck rental ( 4 trucks) plus truck mileage to and from field, Trailer rental ( 3 trailers) plus mileage to and from field Economist's comments for worksheet 2 D ( 2c)  2 Year Transplanted Year 1   Land preparation: Includes chisel plow 3X and rotofill once before and once after fertilization.

  Application: Includes 2 people on hand at application to bury ends of plastic and assist custom operators.

  Field Clean Up: Labor to pick up plastic, plastic disposal fee and tractor & trailer use ( custom rate)

  Seedling: Plants and planting costs.

  Fertilizer/ soil amendments: Includes material and application cost.

  Irrigation: Labor to water about 1" per week June1   Sept 30.

  Interest on Operating Capital: Assume grower borrows half of variable expenses for 8 months in Year 1 and 12 months in Year 2.

Year 2   Digging Equipment: Includes custom rates for 2 tractors   1 for digger and 1 for trailer   potato digger and trailer.

  Storage Cost: Includes mulch to cover in polyhouse and polyhouse rental ($ 0.50 per sq ft * 3,000 sq ft necessary for 1 acre hosta yield Page 76   Processing: Splitting divisions. Page 77 Methyl Bromide Critical Use Exemption Process 2001 & 2002 Average Requested %

Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha)

10,952 47 235 2,100 7 280 17,962 57 314 31,014 111 279 94% 74% 76%

Low EPA High Low High Low High Low High Low High Low High Low HIGH LOW 235 235 0 0 0 0 100 100 0 0 0 0 0 0 100% 100%

280 280 0 0 0 0 100 100 44 31 0 0 0 0 100% 100%

314 314 0 0 0 0 100 100 0 0 0 0 0 0 100% 100%

Strip Bed Treatment Currently Use Alternatives? Research /

Transition Plans Tarps /

Deep Injection Used Pest

free Cert.

Requirement Change from Prior CUE Request (+/) Verified Historic MeBr Use /

State Loss per Hectare (

US$/

ha) Loss per Kilogram of MeBr (

US$/

kg) Loss as a %

of Gross Revenue Loss as a %

of Net Revenue No No Yes Tarp Yes + Yes No Yes Yes Tarp Yes  Yes No No Yes Tarp Yes 0 Yes Conversion Units: 1 Pound = Kilograms Hectare Most Likely Impact Value: High 24% Low 77%

* CA Deciduous Fruit & Nut Tree Growers have a new QPS % of 92% instead of their previous 100%.

* Raspberry was recalculated using original QPS% of 60% instead of 90% based on communications with Dave Riggs.

*** Recalculation of QPS based on conversation with Jim Wells on 8/ 5/ 2005. QPS should be calculated as 99and 92% of their total methyl bromide usage.

* USEPA has recently been informed that a larger proportion of methyl bromide use falls under QPS therefore EPA has reduced the request to adjust for this new information.

Date: 8/ 10/ 2005 Average Hectares in the US:

2007 Amount of Request 2001 & 2002 Average Use* Quarantine and Pre Shipment Hectares ( ha)

2007 Methyl Bromide Usage Numerical Index ( BUNI) Sector: FRUIT, NUT, & FLOWER NURSERY Hectares ( ha) Use Rate ( kg/ ha)

REGION 117 235 Kilograms ( kgs) Use Rate ( kg/ ha) Kilograms ( kgs) 27,379 Western Raspberry Nursery Consortium 53,416 212 252 209,975 81 2,594 208,217 616 338 99%

642 314 92%

224,528 134 1,681 201,678 TOTAL OR AVERAGE 487,919 426 1,145 437,274 1,374 318 2007 Nomination Options Subtractions from Requested Amounts ( kgs) Combined Impacts Adjustment ( kgs)

() QPS HIGH LOW 2007 Request () Double Counting () Growth () Use Rate Adjustment 53,416  26,037  16,427 10,952 10,952 209,975    207,875 2,100 2,100 206,566 17,962 17,962 224,528

Nomination Amount 487,919 487,919 461,882 94%

461,882 31,014 31,014 % Reduction from Initial Request 0% 0% 5%

Use Rate ( kg/ ha) (%) Karst ( Telone) (%) 100 ft Buffer Zones (%) Key Pest Distribution Western Raspberry Nursery Consortium CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers Dichotomous Variables ( Y/ N)

CA Rose Growers ***

CA Assoc.  Fruit & Nut Tree Growers***

REGION REGION Western Raspberry Nursery Consortium CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers Other Considerations Adjustments to Requested Amounts REGION Western Raspberry Nursery Consortium CA Rose Growers CA Assoc.  Fruit & Nut Tree Growers 3 5x/ 1yr 0.453592 1 Acre = 0.404686 Frequency of Treatment 2 3x/ 1yr 3 5x/ 1yr Not included as there is no technically feasible alternative.

Marginal Strategy Quality/ Time/ Market Window/ Yield Loss (%)

Other Issues MOST LIKELY IMPACT VALUE Regulatory Issues (%) Unsuitable Terrain (%)

Economic Analysis 94%

5% Combined Impacts (%)

Cold Soil Temp (%)

94% not available % of Average Hectares Requested:

31,014 60% Not Available Regional Hectares** Research Amount ( kgs)

1,506 Page 78 Appendix III Revised BUNI for Strawberry nurseries 2001 & 2002 Average Requested %

Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha)

4,434 17 263 2,654 8 350 7,089 24 290 99% 96% 63%

Low EPA High Low High Low High Low High Low High Low High Low HIGH LOW 263 263 0 0 0 0 100 100 0 0 0 0 0 0 100% 100%

413 350 0 0 0 0 100 100 0 0 0 0 0 0 100% 100%

Strip B ed T reatm ent C urrently U se A lternatives? R esearch /

T ransition P lans Tarps /

D eep Injection U s ed P est

free C ert.

R equirem ent C hange from Prior C U E R equest (+/) V erified H istoric M eBr U s e /

S tate F requency of T reatm ent Loss per H ec tare (

U S$/

ha) Los s per Kilogram of M eB r (

U S $/

kg) Los s as a %

of G ross R evenue Los s as a %

of N et R evenue No Yes Yes Tarp Yes + Yes 2~ 5 years 4,606 $ 17 $ 10% 46%

No Yes Yes Tarp Yes + Yes 2~ 5 years 5,469 $ 13 $ 13% 46%

* Growth calculated after subtracting QPS Conversion Units: 1 Pound = Kilograms Hectare High 24% Low 77%

*** Recalculation of QPS based on conversation with Jim Wells on 8/ 5/ 2005. QPS should be calculated as 99and 92% of their total methyl bromide usage. Not Available Regional Hectares**

Not Available Research Amount ( kgs)

454 Use Rate ( kg/ ha) (%) Karst ( Telone) Unsuitable Terrain (%)

(%) Key Pest Distribution Regulatory Issues (%)

(%) 100 ft Buffer Zones CALIFORNIA SOUTHEASTERN US Economic Analysis Dichotomous Variables ( Y/ N) Other Issues REGION SOUTHEASTERN US CALIFORNIA SOUTHEASTERN US Other Considerations Nomination Amount Adjustments to Requested Amounts % Reduction from Initial Request 0% 0%

REGION CALIFORNIA*** SOUTHEASTERN US CALIFORNIA 2007 Nomination Options REGION 486,723 486,723 3% 7,089 7,089 Cold Soil Temp (%)

99% 99%

4% 99%

471,930 467,561 4,434 43,292  14,793 4,370 21,475 2,654 2,654 438,997  () Growth* 7,089 4,434

Subtractions from Requested Amounts ( kgs) Combined Impacts Adjustment ( kgs)

393,544 1,455 270 94%

TOTAL OR AVERAGE 486,723 627 776 1,386 263 99%

43,292 105 413 28,499 69 413 89%

443,432 522 263 365,045 2007 Amount of Request 2001 & 2002 Average Use* Quarantine and Pre Shipment Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha) Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha)

REGION Sector: STRAWBERRY NURSERY 2007 Methyl Bromide Usage Numerical Index ( BUNI) % of Average Hectares Requested:

Date: 8/ 10/ 2005 Methyl Bromide Critical Use Exemption Process Average Hectares in the US:

Most Likely Impact Value: Quality/ Time/ Market Window/

Yield Loss (%) Marginal Strategy 10% 10% 1,3 D + Pic 1,3 D + Pic 1 Acre = 0.404686 443,432 2007 Request 0.453592 MOST LIKELY IMPACT VALUE Combined Impacts (%)

() Use Rate Adjustment () QPS HIGH LOW () Double Counting Page 79