# SAN JOAQUIN VALLEY UNIFIED

AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT AND

RECOMMENDATIONS ON AGRICULTURAL BURNING

May 20, 2010 (Revised July 21, 2010)

Prepared by:

Koshoua Thao, Senior Air Quality Specialist Anna Myers, Air Quality Specialist Dennis Roberts, Senior Air Quality Engineer David Nunes, Senior Air Quality Specialist Joven R. Nazareno, Senior Air Quality Engineer David Garner, Senior Air Quality Specialist Yu Vu, Air Quality Specialist Dr. David Lighthall, Health Science Advisor Nichole Corless, Air Quality Specialist

Reviewed By:

Daniel Martinez, Supervising Air Quality Inspector Leland Villalvazo, Supervising Air Quality Speciali st George Heinen, Rule Development Supervisor Scott Nester, Senior Project Manager Errol Villegas, Planning Manager Morgan Lambert, Director of Compliance Samir Sheikh, Director of Strategy and Incentives

Rick McVaigh, Deputy APCOACKNOWLEDGMENTS

The District would like to take the opportunity to acknowledge those individuals and associations who assisted the District througho ut the process of compiling this report. We thank you for your efforts, your o pen communication, your willingness to share data, and for working collabor atively with us in carrying out

the District’s mission.

Agricultural Industry Representatives Applied Development Economics Biomass Industry Representatives

California Air Resources Board Chipping and Shredding Operators/Vendors

County Ag Commisioners County Farm Bureau Environmental Protection Agency Other SJVAB Agencies and Districts

Other SJVAB Growers

May 20, 2010 (Revised July 21, 2010)San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

i Table of Contents Final Staff Report and Recommendations On Agricultural Burning 

### Table of Contents

Executive Summary

State Law Requirements Summary of Proposed Recommendations Contained in th is Report Summary of Methodology for Determining Proposed Rec ommendations Governing Board Approval of this Report Satisfies t he Determinations Required by State Law

Chapter 1 Background

1.1 Reasons for this Report 1.1.1 State Law Requires Determinations by the Dist rict, with Concurrence by ARB 1.1.2 Description of Affected Categories

1.2 Overview of the Methodology for Alternatives to Ope n Burning for Making the Determinations 1.2.1 Is There a Technologically Feasible Non-Burni ng Alternative for Disposing of the Specific Crop Type ? 1.2.2 Does the Cost Analysis Show an Economically

Feasible Non-Burn Alternative?

1.2.3 Do Biomass Power Plants or Other Facilities i n the Valley Have Capacity? 1.2.4 Does ARB Concur With the Analysis?

1.3 Process and Schedule for 2010 Determinations

Chapter 2 Agricultural Burning Requirements of Rule 4103 and CH&SC

2.1 Current District Rule

2.2 CH&SC Burning Prohibitions

Chapter 3 Technical and Economic Analysis of Affect ed Crop Categories

and Recommendations

3.1 Vineyard Removal Materials 3.2 Orchard Removal Matter From Citrus, Apple, Pear , Quince and Fig Crops and Orchard Removal Matter from a Total o f 20

Acres or Less

3.2.1 Orchard Removal Matter from a Total of 20 Acr es or Less 3.2.2 Fig Crops Orchard Removal Matter 3.2.3 Citrus Crops Orchard Removal MatterSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

ii Table of Contents Final Staff Report and Recommendations On Agricultural Burning 3.2.4 Apple, Pear, and Quince Orchard Removal Matte r 3.3 Weed Abatement Activities Affecting Surface Wat erways, Including Ponding and Levee Banks

3.4 Other Materials 3.4.1 Brooder Paper

3.4.2 Deceased Goats

3.4.3 Diseased Bee Hives 3.5 Rice Stubble (Straw) 3.6 Prunings From Apple, Pear, Quince, and Fig Crop s 3.6.1 Prunings from Apple, Pear and Quince Crops 3.6.2 Prunings from Fig Crops 3.7 Surface Harvested Prunings 3.7.1 Prunings from Grape Vines and Grape Canes 3.7.2 Raisin Tray 3.7.3 Almond, Walnut, and Pecan Prunings

Chapter 4 Technological Feasibility of Alternatives to Burning

4.1 Vegetative and Related Material

4.1.1 Biomass Power Plants 4.1.2 Land Application / Soil Incorporation 4.1.3 Anaerobic Digestion 4.1.4 Composting

4.1.5 Landfill

4.1.6 Cellulosic Ethanol Production 4.1.7 Gasification for Liquid Fuel 4.1.8 Pyrolysis

4.1.9 Mulch

4.1.10 Hand Crews for Removal of Materials 4.1.11 Overseas Shipment of Raisin Trays 4.1.12 Water Decomposition for Rice Stubble (Straw) 4.1.13 Baling Rice Stubble (Straw)

4.2 Animal-Related Material

4.2.1 Burial

4.2.2 Incineration 4.2.3 Rendering

4.2.4 Sterilization

Chapter 5 Emissions From Agricultural Burning and A lternatives to

Burning and Health Considerations

5.1 Distribution of Agricultural Open Burning Emissions

5.2 Current Emissions Inventory from Agricultural Burni ng

5.3 Expected Emissions From Alternatives

5.4 Emission Reduction AnalysisSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

iii Table of Contents Final Staff Report and Recommendations On Agricultural Burning 5.4.1 Introduction 5.4.2 Methodology and Calculations

5.5 Health Benefits from Reduced Open Burning

5.6 Health Risk Assessment of Open Burning and Alternat ives 5.6.1 Methodology and Calculations

5.6.2 Health Risk Assessment Results

Chapter 6 Cost Impacts of Alternatives to Burning

6.1 Costs for Open Burning 6.1.1 Costs for Orchard and Vineyard Removal by Ope n Burning 6.1.2 Costs for Disposal of Orchard Prunings by Ope n Burning

6.2 Costs of Alternatives to Burning 6.2.1 Costs for Orchard and Vineyard Removal for fu el at

Biomass Power Plants 6.2.2 Costs for Disposal of Orchard Prunings by Chi pping

6.3 Cost Effectiveness of Alternatives to Open Burning 6.3.1 Approach 6.3.2 Emissions Due to Open Burning 6.3.3 Emissions Due to Grinding and Conversion of

Material to Biomass Fuel

6.3.4 Per Acre Costs and Per Acre Emissions

6.4 Additional Impacts of New ARB Regulations on Trucks and

Equipment

Chapter 7 Biomass Power Plants

7.1 Current Biomass Power Plants

7.1.1 Locations 7.1.2 Fuel Use and Storage Capacities 7.1.3 Historical Fuel Usage

7.1.4 Emissions and Emission Controls 7.1.5 Economics-Agricultural Fuel Vs. Urban Fuel

7.2 Outlook 7.2.1 How Much More Agricultural Material Do We Anticipate? 7.2.2 Could the Current Biomass Facilities Physical ly

Handle the Increase in Materials? 7.2.3 Policies for Renewable Energy

7.2.4 Contracts with Utilities 7.2.5 Legislative Platform

7.2.6 New FacilitiesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

iv Table of Contents Final Staff Report and Recommendations On Agricultural Burning 7.3 State and Federal Commitments for Continued Operati on 7.3.1 Renewable Electricity Production Tax Credit 7.3.2 Existing Renewables Facilities Program 7.3.3 Biomass-to-Energy Incentive Grant Program

7.4 Discussion

Chapter 8 Air Quality Impacts of Continued Open Bur ning and

Alternatives

8.1 Smoke Management System

8.2 2007 Ozone Plan

8.3 2008 PM2.5 Plan

8.3.1 Annual PM2.5 Standard

8.3.2 24-Hour PM2.5 Standard

8.4 Open Burning Emissions Inventory

Chapter 9 Determinations Required by State Law

9.1 Economic Feasibility

9.2 Federal and State Commitments for Biomass Facilitie s

9.3 Air Quality Impacts

9.4 ARB Concurrence

Chapter 10 ReferencesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

v Table of Contents Final Staff Report and Recommendations On Agricultural Burning 

### Appendices

Appendix A: Amended Rule 4103

Appendix B: Table of Crop Categories

Appendix C: Initial Study and Negative Declaration

Appendix D: Summary of Significant Comments and Dis trict Responses

Appendix E: Economic Feasibility Analysis Methodolo gy

Appendix F: Summarized Information from CH&SC Secti on 41855.5

Category Definitions List Open Burn Prohibition Schedule

Appendix G: Cost Effectiveness Analysis

Appendix H: Ag Burn Information Provided by the Agr icultural Industry

Wine Grapes Table Grapes Raisin Grapes

Citrus Nut Crops Diseased Crops Raisin Trays Porter-Cologne Water Quality Control ActSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

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