5900-136 Application for Critical Use Exemption Methyl Bromide

OMB Control# 2060-0482
Expires 6/30/15

For EPA Use Only ID # _____________
SECTOR ________________________

UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Application for Critical Use Exemption of Methyl Bromide
for Pre Plant Use in the United States
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 was 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.
WHY IS THIS
INFORMATION
NEEDED?

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

The information contained in this application is critical to process and assess the need for
methyl bromide. Filling out this application in its entirety will bolster the U.S.
government's ability to strengthen the nomination package for the international review
boards.
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 38
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.

EPA Form # 5900-136

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INSTRUCTIONS
The information provided by you in this application will be used to evaluate the requested methyl bromide use. The
U.S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer
decided that: "a use of methyl bromide should qualify as "critical" only if the nominating Party determines that:
(i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a
significant market disruption; and
(ii) There are no technically and economically feasible alternatives available to the user that are acceptable from
the standpoint of environment and health and are suitable to the crops and circumstances of the nomination …"

WHO
APPLIES?

If you anticipate that you will need methyl bromide because you believe there are no
technically and economically feasible alternatives, then you should apply for the critical use
exemption. This application may be submitted either by a consortium representing multiple
users or by individual users. We encourage users with similar circumstances of use to submit
a single application (for example, any number of pre plant users with similar soil, pest, and
climactic conditions can submit a single application.)
If a consortium is applying for multiple methyl bromide users, the economic data should be for
a representative or typical user within the consortium unless otherwise noted. If economic or
technical factors (such as size of the farm) affecting the ability of this "representative user" to
use alternatives are significantly different than other users in the consortium, more than one
application should be submitted to reflect these differences.
Please contact your local, state, regional or national commodity association and/or state
representative agency to find out if they plan on submitting an application on behalf of your
commodity group.

WHAT
INFORMATION IS
REQUIRED?

Critical use exemptions are valid for only one year and do not renew automatically. Users
desiring to obtain an exemption must apply annually to EPA. Because of the latest changes
in registrations, costs, and economic aspects for producing critical use crops and
commodities, all applicants will be required to fill out the application form completely. If these
Worksheets are not submitted, EPA will not include the application in the U.S. nomination
submitted for international consideration.

HOW DO
I APPLY?

You may either complete an electronic (Microsoft Word or Excel) or a printed version of the
application. Please fill out each section 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.

IS MY
INFORMATION
CONFIDENTIAL?

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, and 50 FR 51661. If
no claim of confidentiality accompanies the information when it is received by EPA, it may be
made available to the public by EPA without further notice to the applicant.
Applicants submitting their application via e-mail assume responsibility for the confidentiality
of the electronic message transmission.

WHEN IS THE
INFORMATION
NEEDED?

EPA Form # 5900-136

This application must be postmarked to the EPA address below no later than September 15.

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Electronic Address for applications: [email protected]
When submitting an application electronically, you should also sign Worksheet 1
and email or fax it to 202-343-2338

WHERE DO I
SUBMIT THE
APPLICATION?

HOW CAN I
RECEIVE
ADDITIONAL
INFORMATION?

EPA Form # 5900-136

Mailing Address for applications
being submitted by mail directly to
the EPA:

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

US Environmental Protection Agency
Methyl Bromide Critical Use Exemption
Office of Air and Radiation
Stratospheric Protection Division
(6205T)
1200 Pennsylvania Ave, NW
Washington, DC 20460

US Environmental Protection Agency
Methyl Bromide Critical Use Exemption
Office of Air and Radiation
Stratospheric Protection Division
1201 Constitution Ave, NW
Room 4355RR
Washington, DC 20004

For general questions about this application:
Stratospheric Ozone Information Inbox at [email protected]
More information is also at http://www.epa.gov/ozone/mbr

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WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST
INFORMATION
The following information will be used to determine the amount of methyl bromide requested and the
contact person for this request. It is important that we know whom to contact in case we need additional
information during the review of the application.
Is this information Confidential Business Information:
Yes ___
No ___
If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.
Applicant Name:
Primary Contact:
Contact Name:
Address:
Daytime Phone:
Cell:
Fax:
Email Address:
Specialty: (check one) Agronomic ___
Alternate Contact:
Contact Name:
Address:
Daytime Phone:
Cell:
Fax:
Email Address:
Specialty: (check one) Agronomic ___

Economic ___

Economic ___

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

Date: _______

Print Name: _____________________________________________

Title: _______

Information in this application may be aggregated with information from other applications and used by
the United States government to justify claims in the national nomination package that a particular use of
methyl bromide be considered "critical" and authorized for an exemption beyond the 2005 phaseout. By
signing below, you agree now to assert any claim of confidentiality that would affect the disclosure by
EPA of aggregate information based in part on information contained in this application.
Signature: ______________________________________________

Date: _______

Print Name: _____________________________________________

Title: _______

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 38 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.

EPA Form # 5900-136

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OMB Control# 2060-0482
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WORKSHEET 1: CONTACT AND METHYL BROMIDE REQUEST
INFORMATION (continued)
1. Location: Enter the state, region, or county.

2. Crop/Crop Grouping: Include all crops/crop groupings that benefit from an application of methyl
bromide in a fumigation cycle. For a definition of fumigation cycle, see Definitions page at end of
application.

3. Summary of Crop System: Enter the type of crop system used, e.g., open field [including tunnels
added after treatment], permanent glasshouses (enclosed), open ended polyhouses, others (please
describe).

4. Range of acres farmed by growers included in this application: Insert number or percentage of
users in each category.
0 - 25 acres

100 - 200 acres

25 - 50 acres

200 - 400 acres

50 - 100 acres

over 400 acres

5. Climate Zone: Indicate the climate zone designation by reviewing the U.S. climate zone map located
at the end of this application or online at http://planthardiness.ars.usda.gov/PHZMWeb/. Please check all
that apply.
1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____
7b____ 8a____ 8b____ 9a____ 9b ____ 10a____ 10b____ 11a____ 11b____

6. Soil Type & Organic Matter: Indicate the soil type and percent organic matter where methyl bromide
would be applied. Please check all that apply.
Soil Type:
Light ___
Medium ___
Heavy ___
Organic Matter:
0 to 2% ___
2 to 5% ___
over 5% ___

7. Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methyl bromide:
Yes ___
No ___
If yes, indicate amount: ____ pounds

8. Has this applicant previously applied for Critical Use Exemption of methyl bromide:
Yes ___
No ___
If yes, indicate CUE #: ________

EPA Form # 5900-136

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9. What is the amount of methyl bromide being requested by this application? (Do NOT include
QPS amounts.)
If a consortium is submitting this application, the data should be the total for the consortium.
Year:______
A

Total Pounds Active Ingredient (a.i.) of
Methyl Bromide

B

Use: Broadcast or Strip/Bed Treatment

C

D

Year:______

If strip, then what percentage is treated
with strip formulation? (E.g., If 30 inches
out of a total of 60 inches are treated with
strip, the percent is 50%)
Formulation (Ratio of MB/Pic Mixture) to
be Used for the CUE

E

Total Area to be Treated with the Methyl
Bromide or MB/Pic Formulation

F

Use Rate (lbs a.i./acre)

10. Please explain why there may be variations in the pounds or acres treated from year to year,
especially if the request is higher this year than in previous years:

11. Please explain why methyl bromide is being requested:

12. For the region where methyl bromide is being requested, if only part of the crop area is treated
with methyl bromide, indicate the reason why methyl bromide is not used in the other area.
Additionally, identify what alternative strategies are used to control the target pathogens and
weeds without methyl bromide in that area:

12a. Would it be feasible to expand the use of these methods to cover at least part of the crop that
has requested use of methyl bromide? What changes would be necessary to enable this:

13. Do you anticipate that you will have any methyl bromide in storage?
Yes ___
No ___
If yes, please specify amount: _______ lbs

14. Have you adjusted the request for the following issues?:
Regulatory Issues:
Yes ___No ___
Disease Pressure:
Yes ___No ___
Soils Issues:
Yes ___No ___
Other (Please Explain): Yes ___No ___
_______________________________________________________________________

EPA Form # 5900-136

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OMB Control# 2060-0482
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WORKSHEET 2: METHYL BROMIDE
Purpose of Data: To establish a baseline estimate of crop/crop grouping yields, gross revenue and
costs using methyl bromide.
Instructions specific to each worksheet are located at the top of each sheet.
Worksheet
2-A

Title
Methyl Bromide - Crop & Pest Information
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.

2-B

The purpose of this worksheet is to determine pest infestation and crop information
where methyl bromide is used. This forms the baseline for evaluating the impacts of
using an alternative to replace methyl bromide.
Methyl Bromide - Historical Use
If a consortium is submitting this application, all data should reflect the actual data for
the consortium.

2-C

This worksheet provides data in actual usage for the last five years.
Methyl Bromide - Crop/Crop grouping Yield and Gross Revenue
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
This worksheet provides crop/crop grouping yield and gross revenue for the last five
years.

2-D(1 & 2)

The purpose of this worksheet is to determine past gross revenues when methyl
bromide is used. This forms the baseline for evaluating the revenue impacts of using an
alternative to replace methyl bromide.
Methyl Bromide - Baseline - Operating Costs
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
This data is needed to estimate a baseline for operating costs in order to estimate
changes in costs and the impact on operating profit and short-run economic viability as
a result of not using methyl bromide and to provide required information to the
international review board.
The purpose of this worksheet is to determine operating expenses when methyl bromide
is used. This forms the baseline for evaluating the cost impacts of using an alternative
to replace methyl bromide. The data requested are designed to help you identify how
your operation would change if methyl bromide were unavailable, which will be shown in
Worksheet 3-B. Worksheet 2-D(1) is for users with a fumigation cycle of less than 5
years. Worksheet 2-D(2) is for users growing perennial crops following a single
fumigation at establishment.
EPA will estimate fixed and overhead costs across crops and regions to ensure
consistency within the U.S. nomination.

EPA Form # 5900-136

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OMB Control# 2060-0482
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WORKSHEET 2-A: METHYL BROMIDE – CROP & PEST INFORMATION
1. Crop/Crop Grouping or Consortium:

2. Which month does your fumigation cycle start: Please check only one.
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept

Oct

Nov

Dec

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

Time Interval (e.g. MONTH/YEAR/SEASON)
Month Month Month Month Month Month Month Month Month Month Month Month
1
2
3
4
5
6
7
8
9
10
11
12

Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other Key
Crop Steps
Other Key
Pest Steps
Continuation
of Fumigation
Cycle (if
needed)

Time Interval (e.g. MONTH/YEAR/SEASON)
Month Month Month Month Month Month Month Month Month Month Month Month
13
14
15
16
17
18
19
20
21
22
23
24

Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other Key
Crop Steps
Other Key
Pest Steps

4. What is the typical soil temperature range during methyl bromide: ______ to ______ °F
Comments:

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5. Target Pest(s) or Pest Problem(s): Please identify the key target pests or pest problems for which
methyl bromide is requested. Provide at least common name and genus and species if possible.
Additional pests or pest problems can be provided as an attachment. Please also explain the specific
reasons why methyl bromide is being requested for each pest [e.g., effective herbicide is available, but
not registered for this crop; mandatory requirement to meet certification for disease tolerance].
Common Name

Genus

Specific Reasons Why Methyl Bromide Is Needed

Pest 1
Pest 2
Pest 3
Pest 4
Pest 5
6. Pest Economic Threshold: Please provide the economic threshold information for each pest.
Describe year and source of information such as survey or expert estimate.
Units (e.g.
Threshold
Year
Source
pests/sq ft)
Pest 1
Pest 2
Pest 3
Pest 4
Pest 5
7. Target Pest Infestation: Please estimate the percentage of the consortia's total growing area with a
moderate to severe problem with these pests. Describe source of information such as a survey or expert
estimate.
Percentage of Total Growing Area
Pest 1

Source

%

Pest 2

%

Pest 3

%

Pest 4

%

Pest 5

%

8. Representative User: Please provide descriptive factors regarding your operation.
Average farm size: _________ acres
Average acres in this crop: _________ acres
Average area treated with methyl bromide: _________ acres
Describe a few crops that could follow this crop:
Other descriptive factors regarding representative user:

EPA Form # 5900-136

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WORKSHEET 2-B: METHYL BROMIDE – HISTORICAL USE
Row A:

Row B:

Row C:
Row D:

Row E:
Row F:
Row G:

Year
Enter dates for the last five years. For example, for applications filled out in 2015, provide data
from 2010-2014.
Total Pounds Active Ingredient (a.i.) of Methyl Bromide
Enter the total actual pounds active ingredient (a.i.) of methyl bromide applied. Note: This
number should be the total pounds a.i. applied by the individual user or the entire consortium, for
the year indicated. Include only the pounds active ingredient of methyl bromide. Do not include
the pounds of chloropicrin that may be part of the same product.
Use: Broadcast or Strip Bed Treatment
Indicate whether broadcast or strip bed treatment is used.
If strip, then what percentage is treated with strip formulation?
If strip treatments are used, enter the percentage treated with strip formulation (e.g., if 30 inches
out of a total of 60 inches are treated with strip, the percent is 50%).
Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE
Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic 70:30).
Total Area to be Treated with the Methyl Bromide or MB/Pic Formulation
Enter the total area to be treated with methyl bromide or MB/Pic Formulation.
Use Rate (lbs a.i/acre)
Enter the use rate in pounds a.i. of methyl bromide per area.

A.

Year

B.

Total Pounds Active Ingredient (a.i.) of
Methyl Bromide

C.

Use: Broadcast or Strip Bed Treatment

D.

E.
F.
G.

If strip, then what percentage is treated
with strip formulation? (E.g., if 30 inches
out of a total of 60 inches are treated with
strip, the percent is 50%)
Formulation (Ratio of MB/Pic Mixture) to
be Used for the CUE
Total Area to be Treated with the Methyl
Bromide or MB/Pic Formulation
Use Rate (lbs a.i/acre)

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

Comments:

EPA Form # 5900-136

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WORKSHEET 2-C: METHYL BROMIDE – CROP/SPECIES YIELD &
GROSS REVENUE
Column A:

Year
Be sure to enter the year. Use as many rows as needed for each year for all the crops/crop groupings in
the fumigation cycles for the last five years. If a fumigation cycle overlaps more than one calendar year,
then the year of the fumigation cycle is the year methyl bromide was applied.

Column B:

Crops/Crop Groupings
Enter all crops/crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple
crops/crop groupings are grown during the interval between fumigations (e.g. tomatoes followed by
peppers in a single growing season, or strawberries followed by lettuce over 2 or 3 years) include all of
the crops/crop groupings during the entire interval.
If someone other than the applicant benefits from the application of methyl bromide in the fumigation
cycle and you do not have the quantitative data for the crops/crop groupings grown on the same land,
please indicate so in the comments section below.

Column C:

Market Categories
Enter marketing categories that determine prices received, for example, grade (size, color), timeliness
(early season, late season), or end use (fresh, processing). Itemize or aggregate these factors to the
extent appropriate if lack of methyl bromide would affect the yields in each category.

Column D:

Yield
Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops,
please enter yields at full production. Be sure to indicate yields at other stages in the timeline in
Worksheet 2-A.

Column E:

Units of Measurement
Enter the unit of measurement for each crop/species (lbs, cwt, carton, bin). If not by weight, specify in
the comments section the average weight of the measure.

Column F:

Price
Enter average prices received by the users for that crop/crop grouping and market category. Average
price over all categories can be calculated separately, if needed.

Column G:

Gross Revenue
Gross revenue per acre for each market category and or each crop/crop grouping may be calculated
using the data you entered as price times yield. If revenue is not equal to price times yield, you may
enter a different revenue amount, but please explain the difference in the comments section below.

A

B

C

D

E

F

G

Year

Crops/Crop
Groupings

Market
Category

Yield

Unit of
Measurement

Price ($)

Gross Revenue
per Acre ($)

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

EPA Form # 5900-136

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WORKSHEET 2-D (1&2): METHYL BROMIDE – BASELINE –
OPERATING COSTS
Enter all operating costs incurred during a fumigation cycle. Users with a relatively short fumigation cycle
(less than five years) should use Worksheet 2-D(1); users cultivating perennial crops should use
Worksheet 2-D(2). Users with multiple crops, either on the same area in a single fumigation cycle or on
different areas treated separately, should copy this sheet or provide costs for each crop. If multiple crops
are cultivated sequentially following a single fumigation, replace fumigation costs in Pre-plant Operations
with any additional pest control costs used prior to the following crops. If a fallow season is an important
part of the fumigation cycle, include costs incurred (for example, cultivating a cover crop) as a separate
line or as a separate sheet, if costs are extensive. Please fill in the unshaded areas. The shaded
areas can be used if the information is known.
Column A: Operation / Input
The operations/inputs listed here are not meant to be exhaustive or representative of your
specific production system. They are meant to provide suggestions and to help you identify
how your operation would change if methyl bromide were unavailable. Be as precise as
necessary otherwise you may aggregate operations or inputs. For example, specify herbicide
costs if additional treatments would become necessary with the use of a methyl bromide
alternative, otherwise you may simply specify total pesticide costs. Please specify only
variable operating costs.
Operation / Input for Perennial Crops
For perennial crops in Worksheet 2-D(2), we have divided the lifespan into three basic periods:
pre-production (including establishment), initial production, and full production. Please ensure
that the timeline in Worksheet 2-A indicates the years of each period. Operating costs should
be an average of costs incurred during each period. Please consider expected replanting rates
and indicate which year dead or poorly performing young trees would be replaced. You may
copy columns/rows as needed if these periods need to be refined for your situation.
Column B: Quantity Used per Acre
This field is required only for methyl bromide. However, you may include specific amounts of
other inputs or operations if you believe it helps to document the additional costs you would
incur by using an alternative fumigant.
Constant Cost per Acre
For harvest operations, specify costs that depend on land area, for example, picking costs, per
acre of land.
Column C: Units
For all inputs and operations detailed in Column B, please specify the units of measurement.
Cost per Unit of Yield
For harvest operations, specify costs that depend on amount of product harvested, for example,
packing material, per unit of produce.
Column D: Unit Costs
For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate
all costs of applying methyl bromide, including any material costs, for example, tarps. If custom
applied and separate costs are unavailable, write 'custom' and enter total cost in Column E.
Yield
For harvest operations, indicate average yields or representative yields from Worksheet 2-C
Column E: Total Cost per Acre
For inputs and operations detailed in Columns B and D, total costs can be calculated as
Column B times Column D. Otherwise, enter total cost of the input or operation. As a check,
you may add up Column E to obtain an estimate of total variable operating costs. These
will not include fixed and overhead costs, nor a return to the owners' labor. It should,
therefore, be less than gross revenues calculated in Question #2. If it is not, please
explain any variations in yields and prices. For perennial crops, Column E should only be
totaled for the years at full production.
Harvest costs may likewise be calculated as costs per acre (Column B) plus variable costs per
unit of yield (Column C) times yield (Column D).

EPA Form # 5900-136

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WORKSHEET 2-D(1): METHYL BROMIDE – BASELINE – OPERATING
COSTS FOR 2013
A

B

C

D

E

Operation / Input

Quantity Used
per Acre

Units
(lbs, hours, etc)

Unit Cost ($)

Total Cost
per Acre ($)

Constant Cost
per Acre ($)

Cost per Unit of
Yield ($)

Yield

Total Cost
per Acre ($)

Pre-plant Operations
Land preparation
Fumigation
product (MeBr)
application
Irrigation
Other costs

Cultural Operations
Seed / Seedlings
Fertilizer / Soil Amendments
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
Labor (manual)
Fuel / Machine Labor
Other Costs

Harvest Operations
Labor
Hauling
Material
Grading / Packing / Storage
Other Costs

EPA Form # 5900-136

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OMB Control# 2060-0482
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WORKSHEET 2-D(2): METHYL BROMIDE – BASELINE – OPERATING COSTS FOR PERENNIAL
CROPS
A

B (1)

C (1)

D (1)

E (1)

PRE PRODUCTION YEARS
Operation or Input

B (2)

C (2)

D (2)

E (2)

INITIAL PRODUCTION YEARS

B (3)

C (3)

D (3)

E (3)

FULL PRODUCTION YEARS

Quantity
used per
acre

Units
(lbs,
hours,
etc)

Unit
Cost

Total
Cost
per
Acre

Quantity
used per
acre

Units
(lbs,
hours,
etc)

Unit
Cost

Total
Cost
per
Acre

Quantity
used per
acre

Units
(lbs,
hours,
etc)

Unit
Cost

Total
Cost
per
Acre

Constant
Cost per
Acre

Cost per
Unit of
Yield

Yield

Total
Cost

Constant
Cost per
Acre

Cost per
Unit of
Yield

Yield

Total
Cost

Constant
Cost per
Acre

Cost
per Unit
of Yield

Yield

Total
Cost

Establishment Operations
Land preparation
Fumigation
product
application
Irrigation
Seedlings
Other costs
Cultural Operations
Fertilizer/soil amendments
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
Labor (manual)
Fuel/machine labor
Other costs
Harvest Operations
Picking/hauling
Material
Grading/packing
Other costs
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WORKSHEET 3: ALTERNATIVES – FEASIBILITY OF ALTERNATIVE
PEST CONTROL REGIMENS
Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to
compare data (yields, crop/species prices, gross revenues and costs) on the use of methyl bromide and
alternative pest control regimens.
Complete Worksheet 3-A for each alternative pest control regimen. Please indicate the name of the
specific alternative pest control regimen addressed and add additional pages as required.
Enter all alternative pesticides and pest control methods (and associated cost and yield data) that would
replace one treatment of methyl bromide throughout the fumigation cycle. See the Definition page for a
comprehensive definition on fumigation cycles.
Worksheet
3-A

Title
Alternatives - Technical Feasibility of Alternatives to Methyl Bromide
You must complete one worksheet for each alternative. Please inset the name of the
alternative in the area on top of the page. If you prefer, you may provide the
information requested in this worksheet in a narrative review. However, you must fill
in the information in Question #1 and #3 or we will assume no yield or quality loss.

3-B

Alternatives - Changes in Operating Costs
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
This data is needed to estimate changes in costs and the impact on operating profit
and short-run economic viability as a result of not using methyl bromide and to
provide required information to the international review board.
Please fill out this worksheet for each alternative for which the economic
evaluation would bolster the case that methyl bromide is needed.
The purpose of this worksheet is to determine operating expenses when alternatives
are used for evaluating the cost impacts of using an alternative to replace methyl
bromide. The data requested are designed to help you identify how your operation
would change if methyl bromide were unavailable. Worksheet 3-B(1) is for users with
a fumigation cycle of less than 5 years. Worksheet 3-B(2) is for users growing
perennial crops following a single fumigation at establishment.
EPA will estimate fixed and overhead costs across crops and regions to ensure
consistency within the U.S. nomination.

3-C

Alternatives - Economic Feasibility of Alternatives to Methyl Bromide
If a consortium is submitting this application, the data for this table should reflect the
representative user for the consortium.
Please include in this worksheet data for each alternative included in
worksheets 3-A and 3-B.

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WORKSHEET 3-A: ALTERNATIVES – TECHNICAL FEASIBILITY OF
ALTERNATIVES TO METHYL BROMIDE
Name of Alternative: _______________
1. Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide: Provide
numerical estimates where possible. Please add additional rows if necessary.
Study # (list
Pest Being Tested % Yield Loss * % Pest Control *
below)

Details

1
2
3
4
5
Enter Average Loss
* If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality
loss information is not available.
+Please report Quality Loss in Table 3.

2. Study Information: For the information in #1 above list: the study name, authors, publication, date,
and if a copy is attached. Please add additional rows if necessary.
Study #
1
2
3
4
5

Attached?

Details

3. Quality Loss*+: Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants,
crop damage, disease vector, etc.
Market
Category

Yield with Methyl
Bromide

Units

Yield With
Alternative

Units

Quality Impact
Description

4. Are there any production delays (planting/ harvesting) associated with this alternative:
Yes ___
No ___
If yes, please explain:

5. Are there any variety or cultivar issues associated with this alternative:
Yes ___
No ___
If yes, please explain:

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6. Restrictions on Alternative Use: This information will be used to determine the amount of methyl
bromide needed.
% of Area

Details

Regulatory Restriction
- Label Restriction
- Township Caps
Soil Restriction
Pest Resistant To Alternative
Organic Matter Restriction
Off Site Damage (outgassing)
Other Restrictions (Describe)

7. Use Rate of Chemical Alternative:
Active
Ingredient
(a.i.)

Name of Product
and Formulation

Quantity a.i.
per Acre

Units
(gals, lbs. Etc.)

# of Acres
Treated

Number of
Applications per Year

8. Non-Chemical Pest Control: Please describe.

9. Alternative Timeline: Indicate when fumigation, major crop and pest management practices typically
occur by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If the
fumigation cycle is longer than one year, change the months to the appropriate interval. These tables are
for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application
covers multiple crops/crop groupings not grown sequentially, they will need to provide this information for
all crops/crop groupings. Please adjust timeline as necessary. Please provide additional comments or
description below or on a separate page. Please begin the timeline with the first land preparation. For
perennials, please begin with the year of land preparation and fumigation and indicate the years of
production by yield or percentage of full production.
Beginning
Time Interval (e.g. MONTH/YEAR/SEASON)
Fumigation
Month Month Month Month Month Month Month Month Month Month Month
Month
Cycle
1

2

3

4

5

6

7

8

9

10

11

Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other Key
Crop Steps
Other Key
Pest Steps

EPA Form # 5900-136

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12

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Continuation
of Alternative
Cycle (if
needed)

Time Interval (e.g. MONTH/YEAR/SEASON)
Month
1

Month
2

Month
3

Month
4

Month
5

Month
6

Month
7

Month
8

Month
9

Month
10

Month
11

Land
Preparation
Fumigation
Planting
Harvest
Fallow
Other Key
Crop Steps
Other Key
Pest Steps

Comments:

EPA Form # 5900-136

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Month
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WORKSHEET 3-B: ALTERNATIVES – CHANGES IN OPERATING
COSTS
Name of Alternative: ________________
Column A:

Column B:

Column C:

Column D:

Column E:

Operation / Input
The operations/inputs listed here are not meant to be exhaustive or representative of your
specific production system. They are meant to provide suggestions and to help you identify
how your operation would change if methyl bromide were unavailable. Be as precise as
necessary otherwise you may aggregate operations or inputs. For example, specify herbicide
costs if additional treatments would become necessary with the use of a methyl bromide
alternative, otherwise you may simply specify total pesticide costs. Please specify only
variable operating costs.
Operation / Input for Perennial Crops
For perennial crops (Worksheet 3-B(2)) we have divided the lifespan into three basic periods:
pre-production (including establishment), initial production, and full production. Please ensure
that the timeline in Worksheet 3-A indicates the years of each period. Operating costs should
be an average of costs incurred during each period. Please consider expected replanting
rates and indicate which year dead or poorly performing young trees would be replaced. You
may copy columns/rows as needed if these periods need to be refined for your situation.
Quantity Used per Acre
This field is required only for methyl bromide. However, you may include specific amounts of
other inputs or operations if you believe it helps to document the additional costs you would
incur by using an alternative fumigant.
Constant Cost per Acre
For harvest operations, specify costs that depend on land area, for example, picking costs,
per acre of land.
Units
For all inputs and operations detailed in Column B, please specify the units of measurement.
Cost per Unit of Yield
For harvest operations, specify costs that depend on amount of product harvested, for
example, packing material, per unit of produce.
Unit Costs
For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate
all costs of applying methyl bromide, including any material costs, for example, tarps. If
custom applied and separate costs are unavailable, write 'custom' and enter total cost in
Column E.
Yield
For harvest operations, indicate average yields or representative yields from Worksheet 3-A.
Total Cost per Acre
For inputs and operations detailed in Columns B and D, total costs can be calculated as
Column B times Column D. Otherwise, enter total cost of the input or operation. As a check,
you may add up Column E to obtain an estimate of total variable operating costs. These will
not include fixed and overhead costs, nor a return to the owners' labor. It should, therefore,
be less than gross revenues calculated in Worksheet 2-C. If it is not, please explain any
variations in yields and prices. For perennial crops, Column E should only be totaled for the
years at full production.
Harvest costs may likewise be calculated as costs per acre (Column B) plus variable costs
per unit of yield (Column C) times yield (Column D).

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WORKSHEET 3-B(1): ALTERNATIVES – CHANGES IN OPERATING
COSTS
Name of Alternative:
A

B

C

D

E

Operation / Input

Quantity Used
per Acre

Units
(lbs, hours, etc)

Unit
Cost ($)

Total Cost
per Acre ($)

Constant Cost
per Acre ($)

Cost per Unit of
Yield ($)

Yield

Total Cost
per Acre ($)

Pre-plant Operations
Land preparation
Fumigation
product (methyl bromide)
application
Irrigation
Other costs

Cultural Operations
Seed / Seedlings
Fertilizer / Soil Amendments
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
Labor (manual)
Fuel / Machine Labor
Other Costs

Harvest Operations
Labor
Hauling
Material
Grading / Packing / Storage
Other Costs

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WORKSHEET 3-B(2): ALTERNATIVES – CHANGES IN OPERATING COSTS FOR PERENNIAL
CROPS
A

B (1)

Operation or Input

Quantity
used per
acre

C (1)

D (1)

E (1)

PRE PRODUCTION YEARS
Units (lbs,
hours, etc)

Unit
Cost

Total Cost
per Acre

B (2)

C (2)

D (2)

E (2)

INITIAL PRODUCTION YEARS
Quantity
used per
acre

Units (lbs,
hours, etc)

Unit
Cost

Total
Cost
per Acre

B (3)

C (3)

D (3)

E (3)

FULL PRODUCTION YEARS
Quantity
used per
acre

Units (lbs,
hours,
etc)

Unit
Cost

Total
Cost
per Acre

Establishment Operations
Land preparation
Fumigation
product
application
Irrigation
Seedlings
Other costs
Cultural Operations
Fertilizer/soil amendments
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
Labor (manual)
Fuel/machine labor
Other costs
Harvest Operations

Constant
Cost per
Acre

Cost per
Unit of Yield

Yield

Total Cost

Constant
Cost per
Acre

Cost per
Unit of Yield

Yield

Picking/hauling
Material
Grading/packing
Other costs

EPA Form # 5900-136

Pre-Plant

Total
Cost

Constant
Cost per
Acre

Cost per
Unit of
Yield

Yield

Total
Cost

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WORKSHEET 4: EMISSION CONTROL
1. How do you currently minimize use and/or emissions of methyl bromide, and how do you plan
to further reduce use and/or emissions in the future? For all use/emissions reduction technique that
you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.
What use/emission reduction methods are
What further use/emission reduction
you currently using?
methods will be used for critical uses?
Please state the emission reduction
Please project the reduction amounts
amounts.
for the year being requested.
Methyl
_____ lbs/acre
_____ lbs/acre
Bromide Rate
Reduction
_____ lbs/acre
_____ lbs/acre
Less Frequent
Application
Formulation
Changes
(please
specify)

____ times per____
____ times per____

____ times per____
____ times per____

_____% MeBr, _____% Pic

_____% MeBr, _____% Pic

_____% MeBr, _____% Pic

_____% MeBr, _____% Pic

Tarpaulin
(High Density
Polyethylene)
High Barrier
Films
Virtually
Impermeable
Film (VIF)
Cultural
Practices
(please
specify)
Other
Pesticides
(please
specify)
Non-Chemical
Methods
(please
specify)
Other
Measures
(please
specify)
2. If methyl bromide emission reduction techniques are not being used, or are not planned for the
future, state reasons:

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WORKSHEET 5: FUTURE RESEARCH PLANS
1. Identify the top 3 to 5 target pests for your research:
1.
2.
3.
4.
5.
2. Provide a list of alternative chemicals or cultural practices that have been tested:
1.
2.
3.
4.
5.
3. Prioritize the alternative chemicals or cultural practices to be tested:
1.
2.
3.
4.
5.
4. What would be the best currently available alternative if methyl bromide were not available:

5. Are there any other potential alternatives under development which are being considered to
replace methyl bromide:
Yes ___
No ___
If yes, please describe:

6. Are there technologies being used to produce the crop which avoid the need for methyl
bromide? Please explain whether such technologies could replace a proportion of proposed
methyl bromide use:
Yes ___
No ___
If yes, please describe:

7. Please provide an overview/timeline of the plan to transition away from using methyl bromide:

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8. Please describe the management strategies that are in place or proposed to eliminate the use of
methyl bromide for the nominated critical use, e.g., measures to avoid any increase in methyl
bromide consumption, measure to encourage the use of alternatives, information on the market
penetration of newly deployed alternatives and alternatives that may be used in the near future:

9. Will yield/quality loss be measured:

Yes ___

No ___

10. Will economic impacts be measured:

Yes ___

No ___

11. What is the cumulative amount spent and the types of contributions this consortium has made
to fund research to develop alternatives to methyl bromide since 1992, e.g. consortium dues,
direct research funding, etc.: Please add additional rows if necessary.
Years
Name of Organization / Research Institution
Amount ($)

12. Other total investments, if any, made to reduce your reliance on methyl bromide: $ _______
Describe each investment and its associated costs (e.g. specialized machinery, etc.). Please add
additional rows if necessary.
Investment
Cost

13. Grant requests made to USDA, EPA, state, or other funding group:

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For EPA Use Only ID # ___________
SECTOR _______________________

WORKSHEET 6: APPLICATION SUMMARY
This section will be posted on the web to notify the public of requests for critical use exemptions
beyond the 2005 phaseout for methyl bromide. Therefore, this section cannot be claimed as CBI.
1. Consortium Name:

2. Location:

3. Crop:

4. Year:

5. Pounds of Methyl Bromide Requested:

________ lbs.

6. Acres Treated with Methyl Bromide:

________ acres

7. Summary of Alternatives Not Feasible: 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. Please add additional rows if necessary.
Not
Not
Potential
Technically
Economically
Reasons
Alternative
Feasible
Feasible

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Definitions:
Fumigation cycle:
Year:

Comparable data:

2-year example:

Other beneficiary example:

Crop cycle change example:

Crop Grouping

EPA Form # 5900-136

The period of time between methyl bromide fumigations.
If a fumigation cycle overlaps more than one calendar year, "year"
refers to the calendar year when methyl bromide is applied (or the
beginning of the cycle).
In order to compare revenues and costs with and without methyl
bromide, data on alternatives for pest control, yields, revenues, and
costs must be for the same time interval as the methyl bromide
fumigation cycle. If, however, quantitative data, is not available for
the entire fumigation cycle, then to be comparable, the quantitative
data for the alternatives should cover the same portion of the
fumigation cycle as the quantitative data for methyl bromide, and the
rest of the cycle should be discussed in the comments sections.
If a methyl bromide fumigation is made every 2 years, then the 2003
fumigation cycle began in 2003 and would end in 2005. The data
should cover the methyl bromide costs and usage for the methyl
bromide fumigation made in 2003, 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 at the same time of year when a methyl bromide
fumigation would be made. The data should cover all methyl
bromide alternatives used, and all yields and revenues received
during that 2-year interval. Other pest control and other costs would
only need to be provided for that interval if they would change from
what they were with methyl bromide.
If someone other than the applicant benefits from a methyl bromide
fumigation, you should comment on these benefits if you do not have
quantitative data for the entire fumigation cycle. For example, if a
rotational crop in the second year benefits from a methyl bromide
fumigation a year earlier, but there is quantitative data only on the
first crop, then the data on the alternatives should cover only the first
crop, and the benefits of methyl bromide and the additional
pesticides that would have to be used on the rotational crop should
be discussed in the comments sections.
If in a one year interval, methyl bromide is applied, tomatoes are
grown and harvested followed by peppers, then the fumigation cycle
would be one year including the tomatoes and peppers. If, however,
without methyl bromide, it is not possible to follow tomatoes with
peppers in the same one year interval, then the alternative data on
pesticides, costs, yields, and revenues should just cover tomatoes.
The loss of profit from not being able to grow peppers with the
alternatives would be part of the loss from not having methyl
bromide.
The applicant can group similar crops together if:
(i) Crops would experience similar yield and quality losses in the
absence of methyl bromide; and
(ii) Crops are grown on the same fumigation and cultivation cycle
with similar operating costs.
For example, nursery crops including various flower or tree species
can be aggregated, with average yields per acre and prices.
However, if crops are distinctly different in revenues and operating
costs, or the cycles, the applicant may want to present yield, price
and operating costs for each crop separately and also indicate the
proportion of land area allocated to each crop.

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EPA Form # 5900-136

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