Final Staff Report and 

Recommendations on Agricultural Burning 

Chapter 3 

Technical and Economic 

Analysis of Affected Crop 

Categories and Recommendations 
Final Staff Report and 

Recommendations on Agricultural Burning 

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Chapter 3: Technical and Economic Analysis of Affected Crop 

Categories and Recommendations

In 2005 and 2007, District staff evaluated several alternatives to open burning for 

the crop categories identified in the CH&SC. While most of those crops and 

materials are already subject to the requirements of Rule 4103 and are prohibited 

from being burned, there were no technologically or economically feasible 

alternatives available for some crops and materials at the time. District staff has 

reviewed the technologically feasible alternatives for each of the affected 

agricultural crop in the SJVAB. From those alternatives, District staff has 

evaluated what appears to be the most viable and likely method to open burning 

for many of the affected crops in the SJVAB. Further discussion on emissions 

and costs for open burning and the alternatives for these crops are presented in 

the following chapters of this report. This chapter analyzes the crop categories 

that are allowed to be burned until June 1, 2010 and presents the findings for 

those crops. 

During the research process, District staff has worked closely with the ag industry 

representatives and other agencies to address the burn prohibition requirements 

for various crops. The ag industry representatives have conducted extensive 

research and effort to provide District staff with key information to help move this 

project forward. The information used for further analysis include economic data, 

costs for chipping and burning, descriptions of operations, and other related 

documents. The ag industry has made significant progress over the years in 

reducing emissions from open burning through research, development, and 

implementation of viable alternative methods. However, there are concerns for 

some crops where growers have not been able to identify technologically or 

economically feasible alternatives. 

The basis of the economic feasibility analysis is a comparison of compliance 

costs of the likely non-burning alternative to profit rates (Return on Sales, or 

ROS) of the industry sector. To evaluate the economic feasibility of burn 

prohibitions on orchard pruning/removal operations for subject crops, the District 

engaged their regulatory economic consultant, Applied Development Economics, 

Inc. (ADE). ADE has familiarity with and constant access to comprehensive and 

applicable profitability and revenue data. Compliance costs for non-burning 

disposal alternatives were estimated by District engineers and ag industry 

representatives using a variety of data sources and methodologies. The 

development of compliance cost estimates is presented in Chapter 6. 

Profits for subject industry sectors were estimated by ADE by applying published 

profitability rates for crops to estimated revenues. Profit rates, production, 
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acreage, and prices were taken from the USDA Ag Census 2007, University of 

California Cooperative Extension, and California Agricultural Commissioners’ 

Annual Report, as well as data compiled commercially by Dun and Bradstreet. 

While the profitability rates used in the analysis below are long-term averages 

from Dun and Bradstreet, it should be noted that industry stakeholders engaged 

in extensive effort and provided significant input regarding the recent profitability 

of certain crops. These data are presented in Appendix E and confirm the 

District’s conclusions on the significance of economic impacts (i.e., greater or 

less than 10% of profit) on each crop operation. 

The analysis was conducted for each crop/operation (nut orchard prunings, citrus 

orchard removals, vineyard removals, and removal of other orchards such as 

stone fruit). The calculations are shown on the tables in Appendix E, and the 

results of the analysis are shown below. 

Summary of Results, Economic Feasibility 

Crop 

Operation Farm Scale, 

Acres Cost/Profit, % 

Vineyard – Wine Grapes <100 55.2% – 82.0% 

Vineyard – Wine Grapes ≥100 46.9% – 69.6% 

Vineyard – Raisin & Table Grapes <100 22.6% – 33.6%

Vineyard – Raisin & Table Grapes ≥100 19.2% – 28.6% 

Vineyard – Kiwi <100 11.1% – 16.6% 

Vineyard – Kiwi 

Vineyard 

Removal 

≥100 9.5% – 14.1% 

Citrus <100 10.9% – 11.9% 

Citrus 

Orchard

Removal ≥100 9.4% - 10.3% 

Other orchards <100 7.0% 

Other orchards 

Orchard

Removal ≥100 5.9% 

Almond, Pecan, Walnut <100 10.0% 

Almond, Pecan, Walnut Pruning ≥100 8.5% 
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3.1 VINEYARD REMOVAL MATERIALS 

Summary and Recommendation

Table 3-1 Summary of Analysis 

Vineyard 

Removal 

Materials 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Grapes (wine grapes only) 

Farms Less 

than100 acres

Possibly 

Biomass 

No. Wire 

Issues. 

$762 - 

$1,132 

55.2%-82.0% No 

 Farms 100 

acres or more

Possibly 

Biomass 

No. Wire 

Issues. 

$762 - 

$1,132 

46.9%-69.6% No 

Grapes (raisin and table grapes) 

Farms Less 

than100 acres

Possibly 

Biomass 

No. Wire 

Issues. 

$762 - 

$1,132 

22.6%-33.6% No 

 Farms 100 

acres or more

Possibly 

Biomass 

No. Wire 

Issues. 

$762 - 

$1,132 

19.2%-28.6% No 

Kiwi 

Farms Less 

than100 acres

Possibly 

Biomass 

No. Wire 

Issues. 

$762 - 

$1,132 

11.1%-16.6% No 

 Farms 100 

acres or more

Possibly 

Biomass 

No. Wire 

Issues. 

$762 - 

$1,132 

9.5%-14.1% No 

*Biomass power plants can accept vineyard removals given that wires are removed from the 

vines. 

Recommendation: 

District staff evaluated biomass power plants as an alternative to open burning of 

vineyard removal materials and other factors. The economic feasibility analysis 

is presented in Section E-1 of Appendix E. At this time, District staff 

recommends that vineyard removal materials continue to be allowed to be open 

burned based on the following reasons: 

• There is currently no economically feasible alternative to remove 

the wire that is embedded in the cordon and canes to prevent 

damage to the chipping equipment or prevent the wires from going 

to the biomass power plants. Wire removal adds a significant cost 

to the growers. Increasing the amount of materials going into 

landfills is not considered a viable alternative as landfills are 

required to divert wood and green materials. 

• Most chipping operators are not willing to chip and haul away the 

vineyard removal materials or would charge a higher fee. 
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Description and Findings

Vineyards include both grape vines and kiwi vines because both crops require 

support, such as the trellis systems to help keep the fruits off the ground. Grape 

vines are used to produce table grapes, wine grapes or raisin grapes. The 

cultural practices and the type of trellis system used at a vineyard are based on 

the intended use of the grapes (table, wine, or raisins) and other factors. In 

addition to the vine and trellis wire, a vineyard may contain cross arms, as well 

as metal or wooden stakes and posts. Treated stakes (sometimes with metal 

braces) cannot be chipped and must be taken to a landfill. The posts currently 

being used are predominantly made out of steel. Metal stakes are removed 

before chipping and taken to a steel plant. The end posts can also be made out 

of redwood which can be burned. 

According to ag representatives, disposal methods for vineyard removal 

materials are the same for table, wine and raisins grapes. A grower will generally 

grow a crop to produce specifically table grapes, wine grapes or raisin grapes. 

However, some vineyards provide the grower some flexibility so that based on 

several factors, including market prices, a grower can determine well into the 

production year whether the grape crop will end up as table grapes, wine grapes 

or raisin grapes. 

Depending on the disposal method with the vineyard removal materials, the 

materials that help support the vine can pose several issues for the grower 

during the removal process. In many cases, most of the foreign material can be 

removed from the vine. However, there are some situations where complete 

removal of the material, such as wire, can be difficult and expensive for the 

grower. When too much wire is embedded into the vines, chippers can refuse to 

chip the agricultural materials. If the wires were to be chipped along with the 

wood, the number of power plant operators that will accept such agricultural 

materials can be limited. 

According to biomass power plant operators, vineyard removal materials are 

accepted. The only restriction with vineyard removal materials is that wire is 

removed and treated posts are taken out. Substantial amount of wire in the 

chipped material can cause problems for the biomass power plant. Other 

contamination (as long as not excessive) in the material, such as dirt, need to be 

controlled but is not a major concern to the operators since some amount of dirt 

is expected of all agricultural fuel. It is generally not an issue if the chipped 

materials are clean. 

While growers can hire laborers to remove most of the wires that connect the 

vines, it is not practical to remove the wire that is embedded into the cordon or 
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the canes. Ag representatives indicated that the raisin vineyards are pruned in 

such a way that the remaining canes are wrapped around the vineyard wire to 

support the crop. In order to chip the materials for fuel use at biomass power 

plants, ag representatives indicated that the wire must be cut more times 

(compare to open burn) and be removed completely from the vineyard or must 

be present only in very short lengths before it can be chipped. This presents an 

issue for vineyards where a cordon is created by wrapping the vine around the 

wire in the second year. As the vine grows, the wire becomes more and more 

embedded in the vine, making it impossible to remove. In some trellis systems, 

there may be as many as four wires embedded in the cordon. Ag 

representatives also indicated that chipping operators have reported the wire 

causing problems and getting wrapped around the moving parts of their 

machinery, and that biomass facilities prefer not to receive material with wire 

because the wire causes havoc with their equipment.

Ag representatives have also indicated that getting the materials chipped 

according to the grower’s schedule has been an issue because it could take 

weeks or months to have a field chipped, which may be too late to plant for the 

next season. 

3.2 ORCHARD REMOVAL MATTER FROM CITRUS, APPLE, PEAR, 

QUINCE, AND FIG CROPS AND ORCHARD REMOVAL MATTER FROM 

A TOTAL OF 20 ACRES OR LESS 

In 2007, ARB concurred with the District’s limited postponement to allow for the 

burning of orchard removal matter from 20 acres or less and other type of 

orchard removals. Rule 4103 defines "Orchard Removal Matter" as agricultural 

material generated by the removal of orchards. This includes leaves, branches, 

trunks, roots, stumps and untreated branch support sticks. The rule prohibits 

burning of orchard removal material generated as a result of land use conversion 

from agricultural to nonagricultural purposes. 

Since 2002, the Natural Resources Conservation Service (NRCS) has 

encouraged growers to chip debris left from orchard or vineyard removals by 

providing a cost-share basis through the Environmental Quality Incentives 

Program (EQIP), which help reduce NOx, VOC, PM10, and PM2.5 emissions 

generated from open burning. The program also includes chipping of almond 

and walnut pruning, which will be discussed in Section 3.7.3 of this chapter. 

According to NRCS staff, the payment rate has increased from $100 per acre to 

$150 per acre. In order for the growers to replant the field, the chipped orchard 

removal materials are typically removed from the farm to a biomass power plant 

or a composting facility. The chips could also be deposited on unpaved roads for 

dust control purposes. Based on NRCS data, the amount of chipped materials 
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from the orchard and vineyard removal category averaged about 270 acres in the 

SJVAB per year, from 2007 to 2009. 

3.2.1 Orchard Removal Matter from a Total of 20 Acres or Less 

Summary and Recommendation

Table 3-2 Summary of Analysis 

Orchard 

Removal 

Matter 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Orchard Removal Matter from 20 Acres or Less Category* 

Farms Less 

than100 acres Biomass Yes $161 7.0% Yes 

 Farms 100 

acres or more 

Biomass Yes $161 5.9% Yes 

*Reduce Burn allowance to 15 acres per location per year. No case by case determinations for 

additional acreage. 

Recommendation: 

District staff has completed the review process for the technologically feasible 

alternatives to open burning of orchard removal matter from a total of 20 acres or 

less. The economic feasibility analysis is presented in Section E-2 in Appendix 

E. Biomass power plants appear to be the most technologically feasible 

alternative to open burning of orchard removal matter; however, due to the 

limiting factor of increased cost per acre for smaller acreage and availability of 

chipping operators, District staff believes that open burning be allowed to 

continue for small orchard removals. District staff recommends that the current 

open burning limit be reduced to 15 acres or less of orchard removal at a single 

location, per calendar year. District staff also recommends that there be no case 

by case determinations for additional acreage since the cost analysis shows that 

it becomes more expensive as the acreage becomes smaller regardless of the 

total size of the farm. 

In addition chipping operator typically refuses small jobs, making it difficult for 

many growers to remove small acreages of orchard removals. The District has 

increasingly refused most requests for burns that are over 15 acres. The 

District’s Compliance Department has indicated that several requests above 15 

acres have been denied because the costs to chip and remove the orchards 

were determined to be economically feasible.

District staff has found that limiting the acreage amount to 15 acres would be 

feasible based on the District’s cost analysis to chip and haul the orchard 

removal materials to the biomass power plants, where the cost per acre appears 
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to level out at about 15 acres or more. Further information on cost analysis can 

be found in the Costs section of this report. According to the burn applications, 

burn permits that were approved for less than 15 acres make up for most of the 

burns, over 84%. According to some growers and chipping operators, the cost 

per acre could level out to as low as 10 acres for some growers; however, District 

staff believes that 15 acres is a reasonable limit based on the cost analysis and 

considering fluctuations in cost caused by location, fuel costs, and materials, and 

other factors. 

Description and Findings

Since June 2007, the District has provided limited burning allocation for orchard 

removal matter from 20 acres or less and has required a case-by-case economic 

justification of the open burning alternatives from growers before evaluating and 

determining whether a burn permit may be issued for farms burning less than 20 

acres but are greater than 100 cumulative acres. ARB concluded that the 

postponements will not substantially contribute to the violation of an applicable 

federal air quality standard, and discussed the important role of the District’s 

comprehensive smoke management program in preventing impacts to nearby 

communities. However, ARB noted that orchard removal of 20 acres or less from 

all other crop types must be implemented narrowly. This category includes all 

orchard type, except for citrus and pome fruits (apples, pears, and quince crops). 

As recommended above, figs would be considered as part of this category.

Growers typically need to remove some orchards every few years to keep the 

farm productive. Growers, ag representatives and chipping operators have 

expressed several concerns with the chipping of orchard removal matter from 

small acreage. Generally, small acreage growers are not a priority for chipping 

operators because of amount of materials generated compared to the time it 

takes to travel and move the equipment to the field. Biomass power plant 

operators have indicated that the large chippers are doing jobs less than twenty 

acres with an understanding that the cost of chipping has gone up. 

Chipping operators also charge a minimum fee (or move-in fee) to the grower. 

As a result of the minimum charge, the per acre cost for such small removals 

increases as the acreage becomes smaller. Based on the District’s cost analysis 

and information received from ag representatives, the cost per acre appears to 

level out at a certain acreage. The fee could vary among chipping operators and 

is dependent on the availability of chipping contractors, storage at biomass 

power plants, the crop type and density, topography, soil type, and location. 

Given these considerations and the fact that most growers are already chipping 

the orchard removals above 20 acres, District staff has used a conservative 

estimate for chipping costs for the analysis. 
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Ag representatives have indicated that when chipping operators work on small 

acreage jobs, growers are often forced to wait until the chipping operator plans to 

be in the area. This can cause significant delays in fumigation, land preparation, 

irrigation, and planting. Trees must be ordered a year in advance. When the 

land is not prepared in time for the trees to be planted, these young trees die, at 

a large cost to the grower. 

For farms greater than 100 cumulative acres in the SJVAB, the District has 

required a case-by-case economic justification of the open burning alternatives 

from growers before evaluating and determining whether a burn permit may be 

issued for less than 20 acres. District staff evaluated the economic feasibility of 

the alternatives based on the applications and copies of receipts, written bids, or 

supporting information for the economic justification. District staff has found that 

the case-by-case economic justification varies significantly, from net losses to the 

cost exceeding the ten-percent (10%) net profit threshold. Information provided 

by growers also supports the higher costs per acre for chipping of orchard 

removal for smaller acreages, which in the past has shown to be less 

economically feasible. 

From June 2007 to February 2010, the District received a total of 1088 

applications for orchard removals of 20 acres or less per year. Of those 

applications, the District issued burn permits for 964 applicants of various farm 

sizes, including those that are greater than 100 cumulative acres. However, 

based on the evaluation of the economic justifications, District staff issued burn 

permits for only 305 applications for farm over 100 cumulative acres. For the 

approved burn permits, the amount of acres burned relative to the amount of 

acres farmed is equivalent to four percent (4%), or about 8,200 acres burned 

from a total of 196,400 acres. Based on this analysis, the District has 

implemented narrowly the provisions for burning orchard removals of 20 acres or 

less. 
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3.2.2 Fig Crops Orchard Removal Matter 

Summary and Recommendation

Table 3-3 Summary of Analysis 

*Analysis of fig crop will be considered as part of “Other Fruit Orchards”. Reduce Burn allowance 

to 15 acres per location per year. No case by case determinations for additional acreage. 

Recommendation: 

District staff has considered the factors currently impacting the alternatives for 

disposing of fig orchards and recommends that open burning of fig orchard 

removals be reduced to less than 15 acres at a single location, per calendar year 

after June 1, 2010. The economic feasibility analysis is presented in Section E-2 

of Appendix E. Fig orchard removals would be considered as part of the small 

other orchard removals category. District staff also recommends that there be no 

case by case determinations for additional acreage.

Description and Findings

When fig orchards are removed, the trees are typically no longer productive and 

would be replaced with new fig orchards or are no longer an economical crop 

and would be replaced with other crops. There are no fire blight issues or other 

concerns for fig crops. In addition, the orchard materials would be acceptable at 

biomass power plants as an additional fuel source. 

Orchard 

Removal 

Matter 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

District 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS)

Fig Crop*

Farms Less 

than100 acres

Biomass Yes $161 7.0% Yes 

 Farms 100 

acres or more

Biomass Yes $161 5.9% Yes 
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3.2.3 Citrus Crops Orchard Removal Matter 

Summary and Recommendation

Table 3-4 Summary of Analysis 

Orchard 

Removal 

Matter 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

Percent of 

Return on 

Sales

Economically 

Feasible? (less 

than 10% ROS) 

Citrus Crop* 

Farms Less 

than100 acres Biomass Some 

operators $369 10.9%-11.9% No 

 Farms 100 

acres or more 

Biomass Some 

operators $369 9.4%-10.3% No 

*Biomass power plants are willing to take citrus crops; however, the materials are typically 

blended with other materials and are less desirable. 

Recommendation: 

District staff evaluated the factors currently impacting citrus crops and the 

proposed alternative for disposal. The economic feasibility analysis is presented 

in Section E-3 in Appendix E. For citrus crops, District staff has considered 

biomass power plants as the most technologically and viable alternative to open 

burning. Based on District staff’s analysis, it is not economically feasible to 

prohibit open burning for citrus crop. In addition, there appears to be uncertainty 

in whether all of the citrus materials could be accepted at biomass power plants 

at this time, due to the lack of future commitments to biomass plan operation. 

District staff recommends that citrus orchard removals continue to be allowed to 

be open burned. As recommended and supported by the industry, District staff 

also recommends that growers allow a drying time of between eight to ten weeks 

for citrus materials as a best management practice before burning. 

Description and Findings

The following citrus crops are all grown in the San Joaquin Valley: grapefruits, 

lemons, oranges (primarily Navels and Valencias), tangerines, and mandarins. 

According to the County Agricultural Commissioner’s Data for Calendar Year 

2008, oranges make up about 82% of the harvested acreage of citrus crops in 

the SJVAB. Growers typically remove old citrus orchards in the year prior to 

planting. Based on the District’s data, orchard removals from citrus crops are 

spread out through the year; however planting usually occurs between February 

and April. 

Citrus is often grown in clay-like soil that adheres to its roots. The extensive 

lifespan of citrus crops leads to the development of an extensive root structure 
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that is difficult to free of soil debris when the root is removed. Clay soil, common 

to citrus orchards, is difficult to remove from the roots. Separating the roots from 

the trunk and then processing the trunk and the stump or root separately for the 

purpose of multiple uses increase the costs of operations, such as chipping and 

grinding. Furthermore, screening of chipped materials to remove excessive clay 

from stumps increases the overall citrus orchard removal costs to growers. It 

takes about six to eight weeks of drying time for a typical non-citrus orchard; 

citrus takes longer to dry. Growers would need to dry the material long enough 

so that a biomass facility will take the material and ration it. 

In addition to the concerns noted above, growers, ag representatives and 

chipping operators have expressed several other concerns with the chipping of 

citrus crop orchard removal matter. Key concerns include 1) the reluctance or 

refusal of some power plants to accept citrus chips, 2) the additional processing 

and costs that are required to make the citrus chips acceptable by the power 

plants, and 3) whether biomass operators will take citrus once the economy 

improves and they start getting more construction material. 

Biomass power plant operators recognize that citrus has been a problem in the 

past, but feel that this no longer seems to be the case as there have been 

considerable changes in processing the citrus materials. Biomass power plant 

operators have indicated that mixing citrus chips with chips from other crops 

helps promote better flow of the chips through their equipment. In the past, one 

of the issues was that clay soil could become trapped in the rootballs and 

damage the power plant boiler refractories. The stringy nature of citrus tree 

chips could also clog conveyors and material handling equipment unless the 

chips were finely ground. Biomass power plant operators have indicated that 

from 2003 to 2005, the roots seemed to be a problem initially with citrus materials 

getting into the conveyor systems, but later it was determined that citrus needed 

a drying process of around six to eight weeks, maybe shorter in hotter 

temperatures. 

According to CBEA, all of the facilities have worked diligently with the orchard 

removal contractors to resolve the issues with citrus wood and as a result, higher 

percentage of citrus material could now be accepted. Biomass power plants 

continue to fall short of their goals for more citrus orchard materials and a number of 

plants continue to be extremely short of wood fuel. Many are currently curtailed or 

operating at reduced loads and are in need of more fuel at this time. The District 

looks forward to working with the biomass industry to achieve long-term 

commitments toward the extensive use of agricultural biomass. 

For more information on biomass facilities, please refer to Chapter Eight of this 

report. 
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3.2.4 Apple, Pear, and Quince Orchard Removal Matter 

Summary and Recommendation

Table 3-5 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff has considered the factors currently impacting the alternatives for 

disposing of orchard removals for apple crops, pear crops, and quince crops and 

has determined that there are currently no feasible alternatives that would 

substitute open burning of these crops. There are two factors for this 

consideration: 1) biomass operators will not accept treated materials and 2) 

requiring that these crops transport materials in closed containers is beyond what 

is required for other orchard removals and therefore, costs are expected to be 

greater. For the second factor, District staff is not aware of any chipping 

operators that have closed containers for this purpose. District staff recommends 

that open burning continue for these crops. 

Description and Findings

As mentioned above for prunings from pome fruits, crops such as apples, pears, 

and quince are susceptible to fire blight, a bacteriological disease that can 

spread through insects, wind, and mechanical devices and kills blossoms, 

shoots, limbs, and sometimes the entire tree. In most cases, the on-set of fire 

blight is unidentifiable and can be spread by contact or exposure to other healthy 

orchard material. For orchard removals, the equipments used to cut or remove 

the tree are also routinely sterilized with antibacterial agents to mitigate exposure 

to the disease or potential disease. 

Similar to pruning, orchard removals from apple, pear, and quince crops need to 

be burned to combat further spread of fire blight within orchards and to prevent 

potential infection of nearby orchards. As indicated by some operators and 

county ag commissioners, they are not aware of an effective treatment for fire 

blight. Growers have considered chipping the orchard removals and transporting 

the materials to biomass facilities. However, the primary concern with this 

Orchard 

Removal 

Matter 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

District 

Percent of 

Return on 

Sales 

Industry 

Stakeholder 

Percent Return 

on Sales 

Apple, Pear, & 

Quince Crops

None. 

Disease 

Issues. 

N/A N/A N/A N/A 
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alternative is potentially spreading the disease to other orchards during 

transportation. In addition, biomass operators prefer clean product and will not 

accept treated materials. As a result, burning is the preferred and most viable 

method used in the SJVAB to dispose of these crops in order to avoid potential 

exposure of the fire blight to healthy trees. 

3.3 WEED ABATEMENT ACTIVITIES AFFECTING SURFACE WATERWAYS, 

INCLUDING PONDING AND LEVEE BANKS 

Summary and Recommendation

Table 3-6 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff has considered the factors currently impacting the weed abatement 

activities affecting surface waterways, including ponding and levee banks and 

recommends that open burning be allowed to continue as part of weed 

abatement activities affecting surface waterways, including ponding and levee 

banks. While chemicals and mowing are available for weed control in many 

locations, these alternatives are not viable because of the slopes and remote 

locations. 

Description and Findings

It is noted in the May 19, 2005 Rule 4103 Final Staff Report, that although some 

weeds and locations lend themselves to Best Management Practices (see 

Attachment 1 in Rule 4103), there remains a need for limited burning of some 

weeds. As mentioned earlier, this analysis does not include the category for 

“other weeds and maintenance”. The CH&SC required the District to establish 

best management practices in 2005 for the control of other weeds and 

maintenance, which includes ditch bank work, canal bank work, dodder weed, 

star thistle, tumbleweeds, noxious weeds, pesticide sacks, and fertilizer sacks. 

Since the implementation, landowners and irrigation districts have continued to 

do their part to reduce burning by seeking alternative ways to manage weeds. 

Weed 

Abatement 

Activities 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Surface 

Waterways – 

Ponding and 

Levee Banks

None. 

Mowing 

and 

Herbicide 

Issues. 

N/A N/A N/A N/A 
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The best management practices in the rule were developed in collaboration with 

affected sources and are alternatives that must be considered prior to any open 

burning. Landowners and operators have also opted for more mechanical and 

chemical control of weeds and only burned at times when conditions, such as 

remote locations or other requirements, prevent other alternative practices. 

Since 2005, open burning is no longer allowed for weed abatement activities 

from berms, fence rows, pasture, grass and Bermuda grass. However, open 

burning is currently allowed for weed abatement activities affecting surface 

waterways, including ponding and levee banks. The following materials are not 

considered to be part of the burn allowance for weed abatement activities 

affecting surface waterways, ponding, and levee banks: 1) weeds that originate 

from outside and away from the surface waterways, ponding or levee banks and 

2) any other debris or materials that are gathered from surface waterways, 

ponding, or levee banks, such as tree limbs or foreign materials. 

According to comments and information received from ag representatives and 

several agencies, there are currently no feasible alternatives to burning all of the 

weeds along surface waterways, ponding and levee banks. Landowners and 

operators have considered using hand crews for removing weeds but found the 

alternative to be impractical. Landowners and operators typically mow and spray 

most of the weeds or use flame desiccation, for direct heating of residual weed 

foliage and over growth of weeds to assure the destruction of weed seeds. One 

operator discs specific sites as needed. In many remote locations along surface 

waterways, ponding, and levee banks, fire is the only option for effective control 

of weed seeds and for safety of workers. 

In addition, ag representatives and agencies have indicated that burning weeds 

is the most effective option to slope the banks to stabilize them and allow the 

water to flow easily, with less erosion. Rodents, such as gophers, have also 

been a concern around levees, including some ground squirrels that have bored 

through entire levees. Standing weeds make it nearly impossible to check the 

banks for rodents, which can cause ditch breaks or erosions and lead to flooding 

of surrounding areas. Complete prohibition to open burning in these areas could 

also increase additional use of other chemicals for pest control. 

The Federal EPA and the State and Regional Water Boards continue to push to 

eliminate the use of chemicals near any waterway. Recognizing these issues, 

many landowners and operators are controlling the use of chemicals along 

surface waterways, ponding, and levee banks due to concerns over runoff of 

chemicals from land to waterways. Ag representatives have provided a copy of 

the California’s Porter-Cologne Water Quality Act of 1969 and related information 

from the federal EPA (attached as part of Appendix B), which further explains the 
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water regulations. The California Porter-Cologne Water Quality Act regulates the 

discharge of waste into ambient waters, and authorizes Regional Boards to 

impose requirements on waste dischargers after consideration of several factors. 

Along with other responsibilities, the Regional Boards also regulate all pollutant 

or nuisance discharges that may affect either surface water or groundwater. One 

of the purposes of the federal Water Pollution Control Act (or Clean Water Act) is 

to restore and maintain the chemical, physical, and biological integrity of the 

nation's waters by preventing point and nonpoint pollution sources. 

One operator indicated that the ability to burn occasionally would reduce the 

amount of chemical needed. According to the operator, the area of the banks by 

the water line make up about 0.2% of the agency’s total acreage and only a 

portion of that is burned annually. 

3.4 OTHER MATERIALS 

Other materials include brooder paper, deceased goats and diseased bee hives. 

3.4.1 Brooder Paper 

Summary and Recommendation

Table 3-7 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff has found that the current and primary disposal method for brooder 

paper is landfilling. District staff considers landfills to be a viable alternative to 

open burning and will recommend that these materials be prohibited from being 

burned. The District’s SMS data also shows an insignificant amount of emissions 

from open burning of brooder paper in the SJVAB in the last few years. 

Description and Findings

 

A broad variety of fowl are raised in confined animal facilities in the SJVAB. 

Poultry operators use brooder paper to protect their young birds during 

transportation and the first few weeks of life. In general, the paper needs to 

easily absorb poultry droppings and disintegrate for easier disposal. District staff 

Other 

Materials 

Potentially feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres or 

more: 

Percent 

of Return 

on Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Brooder 

Paper

Landfill Yes N/A N/A N/A 
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contacted four operators that raise poultry. Three of the operators indicated that 

they do not burn their brooder paper but put it in a dumpster for delivery to a 

landfill. A large operator that raises turkeys and chickens indicated that he 

doesn't "...believe that burning brooder paper is a common practice in 

California." District staff also contacted an operator that burns the brooder paper 

used for raising ducks. The operator indicated that he has alternatives to burning 

the brooder paper including composting the brooder paper or taking it to a 

landfill. 

3.4.2 Deceased Goats 

Summary and Recommendation

Table 3-8 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff considers burial to be a viable alternative to open burning. District 

staff does not consider rendering to be a viable alternative to open burning due to 

the many issues noted for that technology. District staff recommends that these 

materials be prohibited from open burning. The District’s SMS data also shows 

an insignificant amount of emissions from deceased goats being burned in the 

SJVAB in the last few years.

Description and Findings

Several published articles have noted that meat goat production has been 

gaining in popularity in the United States in recent years. Some goat operators 

confirmed that there is increased demand for their products. 

The discussion below on deceased goats differentiates goats that expire from 

diseases (diseased) and goats that expire from other causes (not diseased). 

Deceased goats that were not diseased - Whether goats are raised for their milk, 

their meat or their fur, goats are subject to fatal injury due to accidents, predatory 

animals, exposure to the elements, and other causes. Operators have 

experienced several particular issues in the past few years with the disposal of 

goats that have died from causes other than diseases. Issues have included the 

Other 

Materials 

Potentially feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre at 

20 acres or 

more: 

Percent 

of Return 

on Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Deceased 

Goats

Burial Yes N/A N/A N/A 
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die off of goats due to high summer temperatures and the reluctance or refusal of 

rendering plants to accept goats due to concerns over the cost to collect the 

animals and possible diseases. Two goat operators noted that they did not know 

of any operators that used open burning to dispose of their goats. Instead, 

operators usually bury the goats on their property in as safe a manner as 

possible. 

Deceased goats that were diseased - In the interest of protecting public health, 

several regulatory agencies have regulations affecting the handling of diseased 

animals. Two diseases of particular concern are mad cow disease and scrapie. 

Bovine spongiform encephalopathy (BSE), also known as mad cow disease is a 

fatal disease that causes progressive neurological degeneration in cattle. 

Scrapie is a fatal, degenerative disease affecting the central nervous system of 

sheep and goats. 

The California Department of Food and Agriculture (CDFA) regulates on-site 

carcass disposal in the case of animals suspected of succumbing to contagious 

disease. The California Code of Regulations, California Food and Agriculture, 

Division 5, Part 1, Chapter 1, Section 9141 requires that "Any person that has the 

care or control of any animal that dies from any contagious disease shall 

immediately cremate or bury the animal." Section 9142 requires that "An animal 

which has died from any contagious disease shall not be transported, except to 

the nearest crematory." And Section 9143 requires that "An animal which has 

died from any contagious disease shall not be used for the food of any human 

being, domestic animal, or fowl." 

In addition, the Department of Resources Recycling and Recovery (CalRecycle) 

has prohibitions that impact the disposal of deceased goats. Section 17855.2 of 

California Code of Regulations Title 14, Natural Resources, Division 7, CIWMB, 

Chapter 3.1, Compostable Materials Handling Operations and Facilities 

Regulatory Requirements, prohibits the composting of unprocessed mammalian 

tissue except for certain specific instances. 

In 1997, FDA published a final regulation designed to prevent the spread of BSE 

through animal feed. The 1997 FDA rule prohibits the use of most mammalian 

protein in the manufacture of animal feeds given to ruminant animals, such as 

cows, sheep, and goats. The regulation also requires process and control 

systems to ensure that feed for ruminants do not contain the prohibited 

mammalian tissue. In 2008, FDA published a regulation that strengthened the 

1997 rule by prohibiting the tissues that have the highest risk for carrying the 

agent thought to cause BSE in animal feed. 
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When goats die from unknown causes, some operators will try to discover the 

cause of death by taking the carcass to a veterinarian for an examination in an 

effort to determine the cause of death. 

3.4.3 Diseased Bee Hives 

Summary and Recommendation

Table 3-9 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

Several key considerations for diseased bee hives are that the diseases could be 

dormant in the frames and used equipment, as well as develop resistance to 

chemicals used in the sterilization process. The CH&SC specifically identify this 

crop type as “diseased” bee hives. District staff believes that there are currently 

no technologically feasible alternatives to open burning of diseased bee hives at 

this time. District staff recommends that diseased bee hives be allowed to 

continue to be burned. 

Description and Findings

Bees are a key component in the growing of crops. The importance of bees was 

noted in an article in the U.S. Department of Agriculture's science magazine, 

"Agricultural Research." The author Kevin J. Hackett (ARS National Program 

Leader, Biological Control, Beltsville, Maryland) noted in the March 2004 issue of 

Agricultural Research magazine that "The value of honey bee pollination to U.S. 

agriculture is more than $14 billion annually, according to a Cornell University 

study. Crops from nuts to vegetables and as diverse as alfalfa, apple, 

cantaloupe, cranberry, pumpkin, and sunflower all require pollinating by honey 

bees. For fruit and nut crops, pollination can be a grower's only real chance to 

increase yield. The extent of pollination dictates the maximum number of fruits." 

In light of this, it is vitally important to growers that the supply and availability of 

bees are protected to the highest degree possible. 

Artificial bee hives serve two purposes: production of honey and pollination of 

crops. The hives are commonly transported so the bees can pollinate crops in 

Other 

Materials 

Potentially feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre at 

20 acres or 

more: 

Percent 

of Return 

on Sales 

Economically 

Feasible? 

(less than 10% 

ROS) 

Diseased 

Bee Hives

None. Disease 

Issues. 

N/A N/A N/A N/A 
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selected areas. Modern bee hives are usually constructed of wood and consist 

of several parts which include the following: 

• Bottom board - this has an entrance for the bees to get into the hive. 

• Brood box - is the most bottom box of the hive and is where the queen bee 

lays her eggs. 

• Honey Super - same as brood box, but is the upper-most box where honey is 

stored. 

• Frames and Foundation - wooden frame and plastic sheet with honey comb 

impression where bees build wax honey combs. 

• Inner and Outer Cover - As the name implies. 

Beekeepers have experienced several problems in the past few years. A recent 

development is the problem of colony collapse disorder (CCD), a phenomenon 

where bees mysteriously abandon their hives. The UC Davis Department of 

Entomology website contains an article dated Oct. 16, 2007, about a lecture 

presented by UC Davis honey bee specialist Eric Mussen. The article notes the 

following comment: "One-third of America's honey bees vanished this past year 

due to the mysterious CCD, characterized by almost total hive abandonment. 

Nearly all adult worker bees unexpectedly fly away from the hive, abandoning the 

stored honey, pollen, larvae and pupae. Usually they leave in less than a week, 

and only the queen and a few young workers remain".

Section 29208 of California Code of Regulations Title 3, Food and Agricultural 

Code, Division 13, Bee Management and Honey Production, requires that "If 

American foulbrood is found in an apiary, the abatement shall be by killing the 

bees in the infested colonies and disposing of the hives and their contents, 

together with any other infested comb, hives, and associated appliances which 

are found in the apiary, in one of the following ways: If abatement is by burning, 

the person abating shall act in accordance with applicable air pollution control 

district or air quality maintenance district regulations and state and local fire 

control laws. If the regulations or laws prohibit burning immediately, the diseased 

colonies shall be sealed and placed in an enclosed structure and thereafter 

burned on the first date allowed by the regulation or law. All the activities shall 

be reported to the inspector prior to burning, who may require that burning occur 

only under his or her supervision." 
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3.5 RICE STUBBLE (STRAW) 

Until June 1, 2010, permits may be issued for the burning of rice stubble up to 

70% per year of the total acreage of rice farmed by the operator. Permits may 

also be issued for the burning of residual rice stubble, spot burning of rice 

stubble, and burning of weeds and vegetative materials on rice field levees and 

banks. 

Summary and Recommendation

Table 3-10 Summary of Analysis 

 *N/A: not applicable 

Recommendation: 

District staff has considered the factors currently impacting the alternatives for 

disposing rice stubble. Due to the fluctuation in market demand for rice stubble, 

which impacts growers ability to effectively remove the material, and issues with 

water allocation, District staff recommends that open burning of rice stubble be 

allowed to continue for burns at 70% per year of the total acreage of rice farmed 

by the operator after June 1, 2010 and until June 1, 2015. District staff will 

review the feasibility of a complete burn prohibition for rice stubble in 2015. 

Description and Findings

Most of the rice grown in the SJVAB is grown in the northern part of the air basin. 

Rice is planted in the spring and harvested in the fall. Once the rice is harvested, 

the rice straw remains in the field for disposition. Reducing the amount of postharvest straw residue in the rice fields is important to the successful production of 

the next crop. Burning has been the historical cultural practice for removing 

straw and residues for the California rice industry. Burning rice straw helps 

prepare the field for the next rice crop as burning destroys any diseases in the 

rice straw of the current crop. 

The farming operations for rice growers in the SJVAB are different from 

Sacramento Valley growers, where significant acres of rice are also farmed. 

Rice growers in the Sacramento Valley typically dispose of their rice straw by 

Rice Stubble 

(Straw) 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Increment

al Cost, 

$/acre at 

20 acres 

or more: 

District 

Percent 

of Return 

on Sales 

Industry 

Stakeholder 

Percent 

Return on 

Sales 

Rice Stubble 

(Straw)

No. Market 

and Water 

Issues. 

N/A N/A N/A N/A 
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incorporating the rice straw into the soil. Unlike Sacramento Valley where water 

allocations allow post-season irrigating, water cannot be delivered to agricultural 

operations in the Northern SJVAB in the post-harvest season due to the annual 

distribution schedules designated by irrigation districts. Due to the lack of 

available water in the post-harvest season, rice growers in the SJVAB do not use 

soil incorporation to dispose of their rice straw because the residue may not 

breakdown by planting season. Most rice growers in the SJVAB do not have 

access to water wells for their rice fields. 

In 2007, District staff believed that rice growers could sell the rice straw to rice 

straw baling operators who would then sell it to their customers such as dairies. 

Therefore, the District prohibited open burning for 30% of rice stubble per year. 

In 2009, District staff attended a meeting held by several rice growers that farm in 

the Escalon area. According to the growers, the baling alternative worked well 

for the 2007 harvest as there was a market for the baled rice straw. However, 

rice growers stated that they were having difficulty in their efforts to comply with 

the 70% burn allowance for 2009. Specifically, they were having difficulty in 

getting their rice straw baled and removed from their farms. The rice growers 

and a rice straw baling operator indicated that they have conducted several 

searches on alternatives to burning the rice material and there is currently no 

market for baled rice straw. In November 2009, a variance was approved for a 

group of rice growers that farm in the Escalon area to allow them to burn the 

remaining 30% of their acreage. Growers noted in their variance application that 

there were no viable alternatives currently available for disposal of the rice 

stubble. 

According to the District’s burn data for rice stubble, the annual burn acreage 

have fluctuated since 2006. This change is primarily due to the market demand 

for rice stubble. However, open burning from rice stubble have been reduced by 

42% since 2005, base on a three-year average from 2007 to 2009. The market 

should continue to be assessed annually to ensure that rice stubble can continue 

to be used for other alternatives, such as dairies.
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3.6 Prunings from Apple, Pear, Quince, and Fig Crops 

3.6.1 Prunings from Apple, Pear and Quince Crops 

Summary and Recommendation

Table 3-11 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff has considered the factors currently impacting the alternatives for 

disposing prunings from apples, pears, and quince crops and do not believe that 

there are technologically feasible alternatives to open burning of these materials. 

Depending on the amount and size of materials, it may not be feasible to require 

that growers place the materials into plastic bags for burial. The chemicals are 

preventative measures to help control fire blight; however, chemicals are not the 

solution to ensure complete control since the bacterial disease may develop 

resistant strains. District staff recommends that prunings from apples, pears, and 

quince be allowed to be burned to help control the spread of fire blight. 

Description and Findings

Pome fruit including apple, pear, and quince crops are susceptible to a disease 

called fire blight. Fire blight is a destructive bacterial disease that kills blossoms, 

shoots, limbs, and sometimes the entire tree. Insects, wind, and mechanical 

devices can spread fire blight. According to the ag representatives and an 

agricultural commissioner, fire blight can destroy an entire orchard in a single 

season if left uncontrolled. The bacterium can be easily transmitted to 

susceptible tissue by contact. The equipments used to prune the tree are 

routinely sterilized with antibacterial agents when moving from one tree to the 

next to mitigate exposure to the disease or potential disease. The unrestricted 

movement of infected tissue will cause the disease to spread rapidly and under 

certain environmental conditions (hot and wet). Containment of the infected 

tissue is an essential element for control. 

Apple, pear, and quince prunings are burned to combat further spread of fire 

blight within orchards and to prevent potential infection of nearby orchards. 

Prunings 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre at 

20 acres or 

more: 

Percent 

of Return 

on Sales 

Economically 

Feasible? 

(less than 10% 

ROS) 

Apple, Pear, & 

Quince Crops

None. 

Disease 

Issues. 

N/A N/A N/A N/A 
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Some operators and county ag commissioners have indicated that they are not 

aware of an effective treatment for fire blight. Chemicals that are used to control 

the bacterial disease could prove ineffective if the disease becomes resistant 

over time. According to an agricultural commissioner, the options for controlling 

fire blight that is becoming resistant to chemical means of control with 

Streptomycin are burning on site or disposal by placing infected plant material in 

double plastic bags for burial.

3.6.2 Prunings from Fig Crops 

Summary and Recommendation

Table 3-12 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff has considered shredding as an alternative to open burning of 

prunings from fig crops and other factors currently impacting fig crops. 

Shredding the pruning materials on site appears to be a common practice and 

the most feasible alternative to open burning of prunings from fig crops. 

Shredding the fig prunings and allowing it to decompose should not be a 

significant fruit degradation concern for fig orchard removal as the chipped 

material should have decomposed or be reduced in size by the time of harvest. 

The current mowing and sorting practices would help reduce any excessive 

materials from the figs during harvest. As a result, District staff recommends that 

open burning be prohibited for prunings from fig crops.

Description and Findings

Most figs are harvested as a dried crop. Figs are dried on the tree and allowed 

to fall to the ground. Dried figs are mechanically swept into windrows and 

collected and harvests are repeated at two to three week intervals. This method 

of surface harvesting requires the orchard grounds to remain free of excess 

debris that will hinder the harvest. The harvested figs are then transported to a 

dry location to be sorted before being sold. 

According to ag representatives, there are no fire blight issues for figs and 

shredding the pruning material has become a common practice. Fig crops are 

typically pruned by hand during the winter. The pruning materials are placed in 

Prunings 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre at 

20 acres or 

more: 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Fig Crop Shredding Yes N/A N/A N/A 
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the aisle of the tree rows and shredded in place. Operators typically mow the 

center of the tree rows a few times a year to manage and maintain the orchard 

floor. 

3.7 SURFACE HARVESTED PRUNINGS 

3.7.1 Prunings from Grape Vines and Grape Canes 

Summary and Recommendation

Table 3-13 Summary of Analysis 

Surface 

Harvested 

Prunings – 

Vineyard 

Materials 

Potentially feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre at 

20 acres or 

more: 

Percent 

of Return 

on Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Grape Vines Soil Incorporation Yes N/A N/A N/A 

Grape Canes Soil Incorporation Yes N/A N/A N/A 

*N/A: not applicable 

Recommendation: 

As shredding and soil incorporation of prunings from grape vines and grape 

canes are already widely practiced, District staff considers soil incorporation to 

be a viable alternative to open burning and recommends that prunings from 

grape vines and grape canes be prohibited from open burning. 

Description and Findings

This category does not include grape attrition. According to the District’s policy, 

attrition is vegetative materials not associated with pruning (as defined in Rule 

4103) or orchard removals. Attrition materials include the incidental cuttings of 

dead or broken branches, tree mortality, water sprouts or suckers, or other 

damage to tree crops. Attrition materials may be burned provided that the 

materials are listed on a valid burn permit and daily burn authorization is granted. 

Grape vines are used to produce table grapes, wine grapes or raisin grapes. 

The grape canes and spurs from a grape vine are usually pruned once a year in 

the winter when the grape vine is dormant. Wine vineyards now have high 

tensile wire to withstand the machines that go through the rows during pruning. 

The pruned grape canes and any other pruned material, such as spurs, are 

positioned in the center of the grape vine rows and shredded. Many growers 

typically shred their grape vine pruning material using a tractor and a shredder. 

Grape canes and other materials from the grape vines do not include the 

prunings from kiwi crops, which are already subject to Rule 4103. 
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Figure 3-1 Illustration of Grape Vine and Cane 

A head-trained vine with cane pruning

Bilateral cordon training with spur pruning

http://www.ipm.ucdavis.edu/PMG/GARDEN/FRUIT/CULTURAL/grtrainprune.html 

According to ag representatives and growers, the shredding and soil 

incorporation of grape cane prunings and other pruning materials from a grape 

vine have been long time traditional practices of growers. According to ag 

representatives, growers and biomass power plant operators, they are not aware 

of anyone doing anything with grape canes and other pruning materials from 

vines, except for shredding them and incorporating the shredded material back 

into the soil. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

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3.7.2 Raisin Trays 

Summary and Recommendation

Table 3-14 Summary of Analysis 

*N/A: not applicable 

Recommendation: 

District staff has considered the factors currently impacting the alternatives for 

open burning of raisin trays and recommends that open burning of raisin trays be 

allowed to continue. There is currently not enough research information for using 

raisin trays as fuel at biomass power plants. In addition, District staff believes 

that the increase to 40% of mechanical harvest for raisin production in 2009 

alone has also significantly reduced the amount of emissions from these 

materials. As growers continue to switch to mechanical harvesting as an 

alternative to using raisin trays and open burning the material, District expects 

that open burning emissions from raisin trays will subside as well. According to 

the District’s burn data, growers have continued to reduce open burning of raisin 

trays. Since 2007, growers have reduced burning of raising trays by over 27%, 

or 0.11 tons. District staff recommends that growers implement the practices 

below to control open burning of raisin trays and that the District work with the ag 

industry to develop any additional measures. 

Description and Findings

Raisin trays are used in producing raisins. There are several types of drying 

trays used for sun-dried raisins. Wooden trays were used in the past, but have 

been replaced by paper trays. Due to changes in farming practices and other 

factors, several new paper trays have been developed. The types of paper trays 

available include regular paper, wet-strength paper and poly-coated paper. Both 

wet-strength paper and poly-coated paper trays are especially suited for 

protecting the raisin crop under wet conditions. 

The traditional paper tray is approximately 24 inches wide and 36 inches long 

although other sizes are available for certain situations. The continuous tray, 

which consists of tray material wound into rolls of specified widths, resulted from 

Surface 

Harvested 

Prunings – 

Vineyard 

Materials 

Potentially feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre at 

20 acres or 

more: 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Raisin Trays None. Polymer & 

Recycling Issues. 

N/A N/A N/A N/A 
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the development of mechanical harvest machines. The continuous paper is a 

heavier weight than individual trays. 

Once the raisins have cured adequately and the moisture in the rolls is 

acceptable, normally in late September, they are ready to be collected. Raisins 

must be at 16 percent or less moisture content to meet the industry’s incoming 

inspection requirements. There are several methods used for collecting the 

raisins and preparing them for the next step in their processing. After the raisins 

are collected, they are separated from the raisin trays for further processing and 

delivery to a raisin handler. Once the raisins are removed from the raisin trays, 

the raisin trays are ready for some other use or disposal. 

Growers have continued to pursue alternative ways to burning raisin trays for 

over 50 years. Ag representatives indicated that only about 50,000 acres of 

vineyards using raisin trays are expected by 2015 because growers are 

transitioning to mechanical harvesting, which does not include the use of raisin 

trays. It is expected that there will be a continual reduction in burning. The long 

term goal of the California raisin industry is to transition toward 100% 

mechanization of raisin harvest and drying5

. Based on information received from 

the ag representatives, the historical use of paper raisin trays has been 

significantly reduced by over 52% since 1990. The table below is a summary of 

information provided by ag representatives and shows the progress made in 

reducing the use and open burn of raisin trays. 

Table 3-15 Raisin Tray Paper Volume History 

Year 

Total Amount of 

Raisins in 

Production 

(tons) 

Percentage of 

Raisins 

Mechanized 

(%) 

Amount of 

Raisins 

Produced on 

Raisin Trays 

(tons) 

Number of Raisin 

Trays (four 

pounds of raisins 

per tray) 

1990 395,000 5 375,000 188,000,000 

2000 432,000 10 389,000 195,000,000 

2009 300,000 40 180,000 90,000,000 

According to ag representatives, some growers used recycling firms to dispose of 

their trays in the past. The trays were then shipped to China. The growers were 

typically charged a fee when the recycling firms picked up the trays at the 

growers site. However, China has cut off import of raisin trays because of the 

dollar’s value and the practice of sending raisin trays to China is no longer a 

feasible alternative. 

District staff has considered soil incorporation and biomass power plants as 

possible alternatives; however, the materials in the raisin trays create several 
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potential issues. Ag representatives have indicated that some growers grind and 

soil incorporate their raisin trays. The raisin trays contain polymer (5%) so that 

the moisture on the ground can not be absorb efficiently through the raisin trays. 

The trays that are ground up and soil incorporated into the soil can create 

problems because the materials are slow to decompose and some pieces will 

scatter around. Growers prefer clean fields for operations, which also help keep 

rodents and pests away. 

The raisin trays currently can not be recycled for use as fuel at biomass power 

plants due to the polymer in the material. According to biomass power plant 

operators, both Madera and Mendota power plants are permitted to burn paper. 

Power plant operators indicated that they are willing to work with the District to 

address these issues. Power plant operators are determining a way to 

incorporate raisin trays into their fuel and analysis is pending. Additional 

research is needed for the potential use of raisin trays as fuel for biomass power 

plants. 

In efforts to help reduce and control the burning of raisin trays, Ag 

representatives have developed and recommended the following practices for 

the burning of raisin trays: 

1) All burning locations must be attended at all times when the raisin trays 

are burning, by able bodied adults with adequate tools or equipment to 

control a fire from escaping. 

2) All burn locations must have adequate clearance to avoid escape. The 

burn area should be a “fire safety zone” away from dry fields, homes, 

shops, garages, utility poles or utility supply lines, and other buildings 

or equipment. A rule to remember is to remove all combustible 

materials from 30 or more feet around the burn area. 

3) Paper raisin trays must be burned in a container to avoid escape of 

burning embers or ash, such as a wire cage. A wire cage may be 

constructed out of hardware cloth or chicken wire provided that the 

mesh is no larger than a 1⁄2 inch opening. The cage should never be 

filled beyond half and should be placed in a “fire safe zone”. Using a 

burn barrel for burning anything is illegal. 

4) Don’t burn on windy days. 

5) Avoid burning near a highway or roadway. Ashes or heavy smoke can 

create a very dangerous situation for drivers and winds caused by 

vehicles could cause the fire to escape from the fire safety zone. 
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6) Don’t cause a smoke nuisance to your neighbors. 

District staff will work with the Ag stakeholders to implement the recommended 

practices when burning raisin trays. 

3.7.3 Almond, Walnut, and Pecan Prunings 

Summary and Recommendation

Table 3-16 – Summary of Analysis 

Recommendation: 

The economic feasibility analysis is presented in Section E-4 in Appendix E. 

Based on the considerations and analysis for prunings from almonds, walnuts, 

and pecans, District staff recommends the following: 

The District would provide limited burn allocation for surface harvested prunings 

from almonds, walnuts, and pecans according to the following: 

1. Prohibit burning of prunings for each agricultural operation whose total nut 

acreage (i.e., almonds, walnuts, and pecans) at all agricultural operation 

sites is 3,500 acres or more. 

2. For each agricultural operation whose total nut acreage at all agricultural 

operation sites is less than 3,500 acres, 

a. Allow burning of up to 20 acres of prunings per year, and 

b. Allow burning of additional prunings, provided: 

i. The operator submits to the APCO before the pruning

operation is completed, a representative cost estimate(s) for 

shredding all prunings generated by the total nut acreage at 

the agricultural operation site. The cost estimate(s) shall 

reflect shredding in a time frame that allows the operator to 

proceed with established post-pruning cultural practices. 

ii. The APCO determines that either the submitted cost 

estimate(s) represent(s) an unreasonable financial impact to 

the operator, or that adequate shredding services are not 

Surface 

Harvested 

Prunings 

Potentially 

feasible 

alternative 

Currently in 

practice by 

operators? 

Incremental 

Cost, $/acre 

at 20 acres 

or more: 

Percent of 

Return on 

Sales 

Economically 

Feasible? (less 

than 10% ROS) 

Almonds, Walnuts, and Pecans 

Farms Less 

than 100 acres Shredding Some 

Operators $38 10.0% Yes 

 Farms 100 

acres or more

Shredding Some 

Operators $38 8.5% Yes 
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available in time for the operator to proceed with established 

post-pruning cultural practices. 

Description and Findings

Although the pruning methods will vary among growers, nut crops in general 

would have similar or common practices. So, unless otherwise noted, the 

following description for nut crops applies to almonds, walnuts, and pecans. 

Nut trees are usually pruned after harvesting, either late or early in the year. In 

the past, growers generally open burned nut prunings to dispose of the material. 

However, many growers have found alternative ways to convert prunings into 

something useful such as soil amendment, dust control on unpaved surfaces, 

compost material, or fuel for biomass power plants. According to published 

documents and stakeholder comments, most nuts growers are currently 

shredding the prunings and leaving the materials on the orchard floor. 

Stakeholder comments include growers, vendors, and custom shredders. The 

ability to shred the materials varies among growers of different size farms and 

regions. One top nut grower in the SJVAB has continued to help minimize 

impact on air quality through environmentally responsible efforts, which include a 

contract with a biomass power plant to take its orchard removals and prunings. 

In 2008, another farm of several thousand acres initiated cultural practices and 

equipment necessary to shred all of the prunings rather than burn. District staff 

has also received comments from growers and custom shredders indicating that 

shredding of nut prunings has been a successful procedure in the farming 

operation, particularly for walnuts for one grower. However, there were also 

concerns from other growers regarding the burn prohibition for the prunings of 

nut crops. 

A primary concern that some almond and walnut growers have is preventing the 

pruning material from interfering with the harvesting of the crop. Some of the 

existing shredding equipment currently shred the materials from one inch to a 

few inches in size. 

One problem that some growers have experienced with chipping is the build up 

of chipped material on the ground, which slows the decomposition process. This 

situation can then cause the chipped material to be picked up during harvest. 

Some growers till the shredded material to help the decomposition. A grower 

noted that all pecans are no till operations whereas only a third of walnuts are no 

till operations. Although tilling could be done to bury the chipped material to 

promote faster decomposition, growers try to minimize the number of tractor 

passes in their orchards. 
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According to ag representatives, the almond hullers indicated that the impact of 

almond prunings or chips has been problematic. The chips are picked up with 

the almonds during the harvest process. The chips pass by the “detwiggers” 

which remove the larger sticks and branches that may get knocked down during 

the typical harvest process (shaking, sweeping and pick-up). The product then 

goes to the almond hullers/shellers, which separate the hull and shell from the 

almonds. Growers want to keep the harvest as clean as possible in order to 

maximize the price they receive from the almond hull processors that convert the 

hulls into animal feed. In order to keep the ground surface free of pruning 

material at harvest time, many growers have mostly relied on removing the 

pruning material from the field and open burning the pruning material. 

Ag representatives also provided the following information to the District. The 

hull has significant feed value to dairies, and hulls with 15% fiber content or less 

are considered “prime hull” and receive the highest value. The next product is 

“hull and shell” which is limited to a fiber content of between 15% and 29%. And 

lastly, the shell or any product that has greater than 29% fiber content has little 

value and hardly any market. The almond hullers that the ag representatives 

spoke to estimate a five percent to 11% loss in prime hull revenue due to the 

presence of chips. Prices vary from year to year, but prime hull sells for 

significantly more than hull and shell. During a survey that the ag 

representatives conducted in 2009 for the purposes of developing comments for 

Rule 4103, prime hull was selling for $75 per ton, while hull and shell was selling 

for $45 to $50 per ton. Chips are high fiber content and when picked up with the 

hulls during the hulling process, they can significantly shift the fiber content. One 

huller estimated that the 4,000 tons out of 35,000 expected tons were shifted 

from “prime hull” to “hull and shell” due to the existence of chips. This was an 

11.4% loss amounting to $120,000 in lost revenue. Another huller lost an 

estimated five percent of their “prime hull sales” due to the existence of the chips. 

For walnuts, the hulls are not used for feed; however, growers still need to keep 

the harvest clean in order to minimize any negative impacts during the 

processing of the nuts. According to the ag representatives, the walnut growers 

and walnut processors have indicated that the primary issue is that the chips plug 

the lines at the processor, especially under wet conditions. Walnuts are typically 

harvested from mid-September through mid-November. About half of the time, 

rains during the fall begin before the harvest can be completed. Since the 

prunings occur in the winter, it is impossible to get a chipper into the orchard until 

after the rains subside. The chips do not decompose in the six to seven months 

between the pruning and the beginning of harvest. This is where the plugging 

occurs. The wet chips impede the ability to move the walnuts through the 

ductwork at a huller/dehydrator and processor, as the chips are picked up with 

the walnuts. 
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Ag representatives stated that walnut processors have also expressed concern 

with the chips being left in the orchard due to concerns over food safety. Since 

the chips are an organic material, they are subject to mold growth. If this mold is 

picked up during harvest, it can create a significant food safety issue in terms of 

the potential for aflatoxin. Food safety has become the number one issue of 

concern for the tree nut industry, and any issue that would confound food safety 

would be problematic. 

As the trees are pruned late in the year, the ground is usually too wet to run 

heavy equipment in the field in order to chip the prunings. Growers will then wait 

for the ground to dry but they can only wait for a limited time as they need to 

spray and irrigate their fields early in the year and the pruning material can 

interfere with these operations. This gives the growers a short window of 

opportunity to have their prunings chipped. Some growers usually find it more 

conducive to their operations to gather the prunings and burn them. 

For growers that shred the pruning material as an alternative method to open 

burning, the practice varies among nut growers. In addition, the pruning practice 

for the growers in the northern region appears to be different than the southern 

region. Growers could shred the prunings by renting, purchasing, or borrowing 

special equipment, or by hiring a custom shredder. These options depend on the 

availability of the custom shredder or the equipment. Costs for the options above 

also vary; however, District staff has analyzed the cost of hiring a custom 

shredder as the likely alternative (see section on Costs for analysis) for growers 

that own smaller farms. Custom shredders currently charge a two hour minimum 

fee to shred nut prunings. The average charge is around $260 per hour for a 

total of $520 for two hours. Purchasing a special shredding equipment that can 

shred the material into fine pieces to address the issue with the chips being 

picked up during harvest season could cost over $300,000 and is an expensive 

option and less likely for a small grower. 

Ag representatives, custom shredders, and growers have mentioned that there is 

a shredder in the market which can shred the prunings into smaller pieces, 

thereby reducing problems during the harvest season. The shredder can also 

operate in all weather conditions, including the raining season. The vendor of the 

shredding equipment has indicated that 48 of those shredders are currently 

available for the industry and that previous shredding equipments have been sold 

mostly to growers where some also provide custom shredding service. One of 

the custom shredder indicated that most growers that farm over 3500 acres 

typically shred their own material and that it would be more costly for a grower 

that farms less than that to purchase the same shredder. 
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District staff conducted an analysis to determine whether it would be viable for 

growers to purchase a shredder instead of hiring a custom shredder. The 

following information was used to conduct this analysis: 

1. Harvesting ends in October and cultivation begins around 

January/February. District staff estimated that the available months 

during the pruning season are November, December, and January (three 

months). 

2. According to a custom shredder, the specific shredding equipment can 

cover eight to ten acres per hour. District staff estimated nine (9) acres 

per hour for the shredding equipment. 

3. One working day equates to about eight (8) hours. Average number of 

working days per month is 22 days. District staff estimated that two hours 

are used to prepare the equipment before and after operation and six 

hours are used to shred (process) the pruning material. 

The calculations for one shredder are as follow: 

1. Total Number of Acres Processed Per Month 

Hours Processed Per Day x Acres Processed Per Hour x Averaged Number 

of Days Per Month: 

6 hrs/day x 9 acres/hr x 22 days/month = 1188 acres/month 

2. Total Number of Acres Processed During the Pruning Season (Three Months) 

Total Acres Per Month x Three Seasonal Months: 

 1188 acres/month x 3 months = 3564 acres 

Based on the calculations, one shredder can cover approximately 3500 acres. 

District staff believes that it would be reasonable for a grower that farms 3500 

acres or more to purchase an equipment to address heavy to light prunings from 

the nut orchards. As mentioned by the vendor and custom shredder, many 

growers that own their own shredding equipment also provide custom shredding 

service to other growers. 

District staff conducted further analysis on the cost benefit of purchasing the 

shredding equipment for a farm over 3500 acres. The analysis below is intended 

to compare the two methods for the shredding alternative and is not 

representative of the incremental cost. The analysis is based on the following 

factors: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-34 Chapter 3: Technical and Economic 

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Final Staff Report and 

Recommendations on Agricultural Burning

1. Hiring a Custom Shredder: 

• Per custom shredder, the average charge is $520 for two hours 

minimum. 

• Equipment can process eight to ten acres per hour, or 16 to 20 

acres minimum (Averaged: 18 acres). 

(Reference: http://www.panerofarms.com/why-flory-powertrack.html)

• Based on the above information, minimum averaged cost per acre 

is $29. 

2. Purchasing a Shredding Equipment: 

• Per vendor and custom shredder, the estimated cost of purchasing 

the shredding equipment range from $315,000. 

• Labor rate of $14.74 per hour for machine operators, which 

includes payroll overhead of 34%. 

(Reference: http://coststudies.ucdavis.edu/files/almondvs08sprink.pdf) 

• Price for on-farm delivery of diesel is $2.50 per gallon, which 

includes a 2.25% sales tax on diesel fuel. 

(Reference: http://coststudies.ucdavis.edu/files/almondvs08sprink.pdf) 

• Fuel use for a shredding machine with similar horsepower is 12 to 

15 gallons per hour. District staff estimates that the averaged 

amount of fuel (diesel) required to operate the shredder for one 

hour is 14 gallons (References: 

http://www.jgpress.com/archives/_free/001555.html and 

http://www.neequip.com/KFNA/BROCHURES/PDF_BRO/Crambo_2005E.pdf)

• Annual maintenance is calculated as two percent of the purchase 

price. (Reference: http://coststudies.ucdavis.edu/files/almondvs08sprink.pdf)

• Other additional costs include property insurance and property 

taxes (cash overhead). According to the 2008 Almonds costs and 

Returns Study, the cash overhead contributes to about 9.5% of the 

capital recovery. (Reference: 

http://coststudies.ucdavis.edu/files/almondvs08sprink.pdf)

Based on the best available information and analysis above, the following 

calculations use 3564 acres per year for an equivalent comparison of the cost of 

purchasing a shredder and the cost of hiring a custom shredder. 

 

The calculation for hiring a custom shredder is as follows: 

1. Total Annual Cost of Hiring a Custom Shredder 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

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Minimum Averaged Cost Per Acre x Number of Acres: 

 $29/acre x 3564 acres = $103,356

The calculations for purchasing a shredder are as follows: 

1. Total Annualized Capital Costs of the Shredder 

The District uses the following formula to calculate an equivalent annual cost 

from a capital cost using a capital recovery factor as shown below: 

 A = [P x i(1 + i)n

] / [(1 + i)n – 1] 

Where: A = Equivalent annual cost of control 

P = Capital cost of the control equipment, including 

installation cost 

I = Interest rate (used 10% as a conservative estimate) 

n = Equipment life (used 10 years as a conservative 

estimate) 

 [$325,000 x 10%(1 + 10%)^10yrs] / [(1 + 10%)^10yrs – 1] = $51,265

2. Total Annual Cost of Diesel Fuel 

[Estimated Amount of Fuel (in Gallons) Used Per Hour x Hours Processed 

Per Day x Averaged Number of Days Per Month] x Cost of Fuel Per Gallon: 

 [14 gallons/hr x 6 hrs/day x 22 days/month x $2.50/gallon] x 3 months = 

$13,365

3. Total Annual Cost of Hiring a Machine Operator 

Labor Rate Per Hour x Total Number of Work Hours Per Day x Averaged 

Number of Days Per Month x Three Seasonal Months: 

 $14.74/hr x 8 hrs/day x 22 days/month x 3 months = $7,783

4. Total Annual Cost of Maintenance 

Cost of the Shredder x Two Percent of the Cost of the Shredder: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-36 Chapter 3: Technical and Economic 

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$315,000 x 2% = $6,300

5. Total Annualized Cost of Property Insurance and Property Taxes 

Total Annualized Costs of the Shredder x 9.5 Percent for the Cash Overhead 

(Insurance and Taxes): 

 $52,892 x 9.5% = $4,883

Table 3-17 and Table 3-18 summarizes the annualized cost estimates for the 

purchase of a shredder and the annual costs of hiring a custom shredder. 

Table 3-17 – Annualized Cost Estimates for the Purchase of a Shredder 

Description Costs

Total Capital Cost $315,000

Total Annualized Capital Cost of the Shredder (10% - 10 years) $51,265

Annual Operation & Maintenance Costs 

Total Annual Cost of Diesel Fuel $13,365

Total Annual Cost of Hiring a Machine Operator $7,783

Total Annual Cost of Maintenance $6,300

Total Annualized Cost of Property Insurance & Taxes $4,883

Total Annual Operation & Maintenance Costs $32,331

Net Annual Costs (Annualized Capital Cost + Annual O&M 

Costs) ($/year) $83,596

Table 3-18 – Annual Cost Estimates for a Custom Shredder 

Description Costs

Averaged Cost Per Acre $29

Total Annual Cost for 3564 acres $103,356

Net Annual Costs ($/year) $103,356

Based on the analysis above, the estimated savings from purchasing a shredder 

is close to $20,000 per year. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-37 Chapter 3: Technical and Economic 

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Recommendations on Agricultural Burning

According to GrowingProduce.com, the 2009 Top Nut Growers make up about 

228,000 of nut acreages in California. Out of the 25 Top Nut Growers, 18 of 

those growers are in the District’s burn permit database or the Conservation 

Management Practices (CMP) database. The 18 growers make up about 

183,154 acres of nut crops. Pistachios contribute to about 16% of the total 

acreage in the SJVAB, therefore the estimated acreage for almonds and walnuts 

for SJVAB growers is 154,327 acres, which is about 20% of the total nut acreage 

in the SJVAB. Twelve of those growers are over 3,500 total farm acres of nut 

crops and contributes to over 94% of the top acreages on the list, or about 

212,000 total nut acreages. At least two growers in this group are either 

shredding the pruning material or taking the material to the biomass power plant. 

Based on the 2007, 2008 & 2009 Top Nut Growers tables, District staff expects 

that at least 80 percent of the farms in the top 25 list could buy their own 

shredding equipment. At the bottom of the 80 percent range, the total nut 

acreages average about 3460 acres. 

According to the custom shredders, the average charge to shred the prunings is 

a minimum of two hours. The recommended shredder, which can shred the 

materials to finer pieces to address issues with the chips not being decomposed 

by harvest season or being picked up during harvest, can process eight to ten 

acres per hour. Due to the two hours minimum that custom shredder charges 

the grower, District staff believes that the cost on a per acre basis would increase 

as the acreage becomes smaller. Therefore, the 20 acres limit within the two 

hour timeframe is reasonable. 

District staff is aware of at least three custom shredders in the SJVAB that 

operate a total of five of those shredders and another two contractors that do 

custom shredding. There are also several types of other shredding equipment 

available, where some may require more passes in order to shred the prunings 

into acceptable sizes. 

The Jack Rabbit equipment is typically used to remove the material from the 

orchard. Transporting the material to composting facilities appear to be less 

common among growers compared to shredding the material onsite or taking the 

material to the biomass power plants. According to biomass power plant 

operators, some biomass power plants purchase some, but not all, of these 

prunings. The preferred alternative at this time for most pruning material is to 

shred and leave the material on the ground, since it can be more efficient than 

chipping and transporting the material offsite. Some growers have found that 

shredding and incorporating the materials back into the ground helps replenish 

the soil with nutrients. Several growers are also moving towards lighter pruning, 

which are about one-fifth of what they used to be. Since 2007, the amount of 

almond prunings burned has been reduced by over 22,000 acres, or 76 tons of 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-38 Chapter 3: Technical and Economic 

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Categories and Recommendations 

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PM2.5. The amount of burn acres from walnut prunings has also been reduced 

by over 5,500 acres, or over 13 tons of PM2.5. The category for pecan prunings 

has shown a slight change in open burning; however, prunings are also shredded 

and left on the ground. The overall amount of emissions reduced since then 

could be even higher as a result of lighter prunings. 

Over the past ten years, NRCS has encouraged growers to chip or shred the 

prunings from almond and walnut orchards by providing a cost-share basis 

through the Environmental Quality Incentives Program (EQIP). According to 

NRCS staff, it is uncertain how long this program will last. Many of the growers 

shred the material on site through this program, which helps reduce Nox, VOC, 

PM10, and PM2.5 emissions generated from open burning. According to NRCS, 

the program resulted in an average of 120,333 acres of almond and walnut 

prunings chipped per year in the SJVAB from 2007 to 2009. Along the same 

years, the average amount of almond and walnut prunings burned from the 

District’s database was 68,802 acres per year. According to the County 

Agricultural Commissioner’s data for Calendar Year 2008, the total harvested 

acreage for both of those crops in the SJVAB was 753,515 acres. The total 

harvested acreage for pecans is 611 acres, or 0.08% of the total nut harvested 

acreage. See table below for a summary of the alternative methods for almond 

and walnut prunings. Pecans are not included in the analysis below because 

NRCS data only addresses almonds and walnuts. 
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Recommendations on Agricultural Burning

Table 3-19 – Analysis of Alternative Methods for Almond and Walnut 

Prunings 

Surface Harvested Prunings from Almond and Walnut Crops Acres 

Total Harvested Acreage for Almonds 625,814 

Total Harvested Acreage for Walnuts 127,701 

Total Harvested Acreage for Almonds and Walnuts 753,515 

Estimated Acreage Pruned per Year1 376,758 

Chipped/Shredded Acreage of Almond & Walnut Prunings per year 

(NRCS) 

120,592 

Open Burned Acreage of Almond & Walnut Prunings per year 

(District) 

68,802 

Estimated Acreage from Alternative Disposal of Almond & Walnut 

Prunings2

187,364 

1

Assume Pruning is done in alternate years: [(753,515) / 2] = 376,758. The 2008 Almonds Costs 

and Returns Study and 2007 Walnuts Costs and Returns Study use alternate years for pruning of 

mature orchard. Both studies analyzed the alternative method of chipping and shredding onsite 

and indicated that the practices will vary among growers and regions. 

2

The remaining acreage is likely to be voluntary disposal through alternative methods to open 

burning, such as shredding, chipping, biomass fuel, or other methods, and without the EQIP 

program.

Based on the table above, if growers prune the harvested orchards during the 

dormant period every other year, the actual amount of acres pruned per year 

would be about 376,758 acres. Based on the analysis above, about 18% of the 

acreage pruned per year is contributed to open burning, while most of the 

growers are using other alternative practices rather than open burn. 
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Chapter 4 

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Chapter 4: TECHNOLOGICAL FEASIBILITY OF

ALTERNATIVES TO BURNING

District staff has conducted detailed research and identified several potentially 

feasible alternatives to open burning of agricultural materials. Some of the 

alternatives were previously identified during the 2005 and 2007 burn prohibition 

schedules. Potential alternatives for agricultural wood and agricultural non-wood 

materials were identified for each of the following groups: 1) vegetative and 

related material and 2) animal-related material. 

The more common methods of disposing of agricultural material that cannot be 

open burned include the following: 

• Some agricultural materials, like orchard removals, are primarily 

transported to biomass power plants for use as fuel. 

• Chip or grind the material and transport it off-site for disposal or other 

renewable uses. 

• Prunings and some field crop materials may be shredded in place, 

chipped onsite, or tilled into the soil. 

• Some materials, such as rice straw, may be baled and sold for various 

commercial purposes, although the market for such product is much less 

than available supplies. 

The potential alternatives to open burning of agricultural wood and agricultural 

non-wood materials are described below. 

4.1 VEGETATIVE AND RELATED MATERIAL 

Most alternatives to open burning agricultural wood materials and pruning 

materials require that the agricultural materials go through a chipping, grinding or 

shredding process. These processes are typically used to change the 

agricultural wood materials into a more manageable and useable size. Some of 

the benefits of chipping, grinding and shredding include faster decomposition of 

the materials, easier incorporation into the soil, easier to process and transport, 

and better combustion when used as fuel at biomass power plants. 

Agricultural wood and pruning material that are to be chipped need to be as free 

of debris as possible to prevent damage to the chipping equipment and to 

increase its acceptability by potential end users such as biomass power plants 
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and other processors. Orchard removal material is usually removed from the 

farm after the chipping process, as growers want a relatively clean field for 

planting a new crop. For pruning, growers may recycle the materials onsite or 

remove the material from the farm. 

4.1.1 Biomass Power Plants 

Biomass power plants in the SJVAB will generally accept agricultural, forestry, 

construction, and urban residues. The power plants burn the material in 

combustors to produce steam. The steam is then used to spin turbines to 

generate electricity. 

Biomass power plants do not universally accept all agricultural material due to 

concerns that some materials may harm power plant machinery. Several issues 

have been noted concerning the types of material, such as citrus chips, that can 

be burned by the biomass power plants and the amount of agricultural materials 

that is accepted at the biomass power plants at any given time. Biomass power 

plant operators have indicated that these issues have been overcome over the 

past few years as the facilities involved have adapted in processing the ag 

materials to better suit the situations encountered. 

Using the orchard removal materials for fuel at the biomass power plant is 

currently the most viable and cost effective alternative to open burning for 

growers due to available tax credits for biomass facilities and required 

agricultural offsets for some biomass power plants. However, reliance on 

biomass fuel as a primary alternative to burning is somewhat uncertain since 

there are no long-term federal or state funding commitments for the biomass 

facilities in the SJVAB. It is also relatively more affordable for the biomass power 

plants to accept urban waste than agricultural materials. Pruning materials are 

sometimes accepted by biomass power plants. The residents of a typical 

community are being charged more money to divert urban waste out of a landfill. 

Therefore, the urban waste is subsidized by the community in their waste 

payments and this provides the urban fuel to be processed at biomass plants at a 

more competitive price. 

4.1.2 Land Application/Soil Incorporation 

Applying agricultural materials to the soil is a common method of disposal of the 

materials. The pruning material from many tree crops and vineyards is usually 

gathered into windrows and shredded in place using grinders suitable for brush. 

The shredded material can either be left on the ground or be incorporated into 

the soil when the field is tilled. Over time, the material decomposes into the soil 

which adds valuable organic material to the soil and can lead to better water 

infiltration and soil quality. This practice is evolving as more growers and 
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equipment manufacturers innovate and collaborate to make the process work for 

everyone. 

Current practice does not work well for all crops, especially for pome (apple, 

pears, and quince) fruits with concerns over the spread of diseases and for nut 

crops which harvest the nuts from the ground. With the exception of the potential 

spread of diseases from pome fruits, other operators can usually minimize or 

prevent this problem for other crops by taking steps to better ensure that chipped 

pruning material has decomposed by the time that crops are harvested or that 

chipped pruning material is not placed in the area where the crop is to be 

harvested. The pruning material can be chipped into smaller pieces using 

upgraded technologies that can shred the material into finer quality. The cost of 

this equipment will be assessed later in this report to determine if it would be 

economically feasible. 

4.1.3 Anaerobic Digestion 

Anaerobic digestion is a biological process that decomposes organic matter with 

minimal or no oxygen level, which results in a liquid/solid stream (digestate) and 

biogas that contains mostly methane and carbon dioxide. This biological process 

can either be found or managed through some of the following: marshes, 

sediments, wetlands, the digestive tracts of ruminants and some insects, landfills, 

many wastewater treatment facilities, and animal feeding operations and dairies. 

The anaerobic digestion technology that is managed at a farm or facility could 

include several steps in the process, such as feedstock handling/storage, 

preprocessing, digester, collection and storage of the biogas, dewatering of the 

digestate, and handling/storage of the dewatered digestate. 

There are currently no commercial-scale solid waste digesters in operation in the 

United States even though anaerobic digesters have long been used to treat 

agricultural and municipal wastewater. Although, District staff has found that the 

anaerobic digestion technology will be installed in Emmetsburg, Iowa, in 2011, as 

part of a commercial scale cellulosic ethanol plant. The digestate would be used 

as a source to power the plant. 

District staff is not aware of any facilities in the SJVAB that can process 

agricultural materials through anaerobic digesters on a commercial scale. In 

addition, it is not believed to be practical to require that growers install an 

anaerobic digester for the purpose of disposing the agricultural material. The 

agricultural materials that are subject to Rule 4103 are typically pruned or 

removed once a year or every few years for orchard removals. Based on these 

considerations, District staff will not conduct further analysis on anaerobic 

digesters as a viable technology in the SJVAB. 
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4.1.4 Composting 

Composting is the process by which organic material is broken down aerobically 

to form a biologically stable organic substance suitable as a soil enhancer and 

plant fertilizer. 

Agricultural material is one of the sources of organic material for composting 

operations. Other sources could include, but are not limited to, urban waste, 

biosolids, and manure. The District distinguishes the blend of organic material 

into two categories, composting and co-composting. Along with vegetative 

material, co-composting includes biosolids, manure, and/or poultry litter. The 

vegetative materials are a good source of nitrogen, whereas, chipped wood 

provides carbon to the mixture. As a result, compost and co-compost facilities 

sometimes accept agricultural materials either as feedstock or as amendment for 

the operation. Some compost and co-compost facilities also accept and store 

the material for other use such as fuel for biomass power plants or animal feed. 

Based on District’s data, there are currently 19 composting and co-composting 

facilities in the SJVAB that might be able to accept and process the agricultural 

material. 

Sources usually pay a tipping fee to compost operators to dispose of the material 

at the composting site. With competing materials from subsidized urban waste, 

disposal costs for agricultural materials could be higher and the accepted amount 

of agricultural materials could vary. This fee would be additional to other 

operational costs, such as chipping and transporting the material to the compost 

facility. These operational costs for the grower would be similar to the cost of 

chipping and transporting the material to the biomass power plants, which does 

not charge a fee for disposal. Based on discussion with the chipping operators, 

most of the agricultural materials that are chipped are transported to biomass 

power plants for use as fuel. Therefore, District staff plans to conduct the 

economic feasibility analysis on transporting the material to biomass power 

plants as a more cost effective alternative. 

4.1.5 Landfill 

Growers and chipping companies can take agricultural materials to local landfills 

for disposal. Not all landfills will accept these materials, particularly landfills 

designated for hazardous waste. Municipal solid waste landfills are allowed to 

receive putrescible waste, such as yard waste or any methane producing 

material. Agricultural materials accepted at these landfills may be disposed at 

the site but are primarily being used as alternative daily cover (ADC) to reduce 

odor and for vector control. State Assembly Bill AB 939 was passed in 1989 and 

mandated local jurisdictions to meet solid waste diversion goals of 25 percent by 

1995 and 50 percent by 2000. Local agencies within California are required to 
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comply with the mandated landfill diversion requirement every year. 

There are four landfill facilities within the District that are currently accepting 

organic material, which could include materials from agricultural crops and 

orchard removals. Similar to compost facilities, landfills also charge tipping fees 

for the disposal. Due to the state mandated landfill diversion requirement and 

the small number of landfills that are allowed to accept organic material, it is not 

feasible to promote agricultural material going to the landfills. District staff has 

considered the information above and plans to conduct the economic feasibility 

analysis on transporting the material to biomass power plants as a more cost 

effective alternative. 

4.1.6 Cellulosic Ethanol Production 

Cellulosic ethanol, a key next-generation biofuel, can be made from switch grass, 

corn stover, forest waste, fast-growing trees, wood chips and other plant 

material. 

Advanced biofuels are those that do not rely on the corn kernel starch. In 

contrast, the most common type of ethanol in the United States is corn ethanol 

which is produced from corn with only the grain being used. Corn ethanol is 

primarily used in the United States as an alternative to gasoline and petroleum 

(first-generation biofuel). 

The production of cellulosic ethanol is still predominately in the demonstration 

plant phase of development. At this time, District staff is not aware of any 

commercial plant within the SJVAB that currently uses agricultural materials for 

the production of cellulosic ethanol. 

4.1.7 Gasification for Liquid Fuels 

There are emerging technologies that can convert agricultural materials, sewer 

sludge, wood, trash, and plastics into diesel or biofuel. In traditional gasification, 

oxygen is used, but the new technique uses hydrogen and steam at nearly 1,500 

degrees F to break apart the feedstock into a gas made up of its molecular 

components. After gasification, the resulting gas then goes through additional 

steps that produce water, wax, and diesel fuel. Up to 85% of the feed material 

becomes usable liquid fuel at the end of the process. 

Agricultural wood materials can be used as a solid fuel by being burned in a 

combustion device or it can undergo processing to convert it into a gas or liquid 

fuel. Operators could choose to purchase a system given adequate space, but 

many of these vendors are located outside of California. For most of these 

situations, the agricultural wood materials are usually chipped on the farm site 
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and then transported to the processing facility. District staff is not aware of these 

types of facilities currently in operation in the SJVAB, which would indicate that 

these technologies are not current alternatives to burning. 

4.1.8 Pyrolysis 

A new biofuel derived from wood chips through a pyrolysis process has been 

developed. The process involves heating wood chips and small pellets in the 

absence of oxygen and high temperature (pyrolysis). About a third of the dry 

wood becomes charcoal and the rest becomes a gas. The gas then undergoes a 

chemical process where it is converted into liquid bio-oil. According to 

researchers, the new method offers environmental benefits and could reduce 

industrial costs of alternative fuel for conventional diesel engines. The technique 

is still in the early stage; therefore, use of wood chips for this process would not 

be a viable alternative source in the SJVAB at this time. 

4.1.9 Mulch 

Soil Stabilization / Dust Control 

A project in Northern California gauged the use of wood chips as an alternative 

source for soil erosion and stability to roads and parking areas. The Road 

Stabilization and Improvement Demonstration Project demonstrated that the use 

of wood chippings not only provides stabilization and erosion control on light 

duty, low-use roads, parking, and access areas, but is also cost-effective when 

compared to the use of other road materials. 

The project found that using wood chips for road use was a feasible alternative to 

expensive materials such as rock or shale. Other benefits resulting from the 

project include added value to the chipped materials, improved site and off-site 

water quality, improved stability, usability, and mud free road and area 

conditions. The project addresses the successful use of wood chippings for soil 

stabilization or dust control as potential alternatives. District staff is not aware of 

a feasible market in the SJVAB that could accept and process all of the 

agricultural material for use as dust control but this alternative would be 

considered as a similar alternative to soil incorporation and a possible option, 

given that the materials serve as beneficial use. Typically, operators apply the 

chipped material onto surfaces for nutrient value and may apply the extra 

material on road surfaces. In other cases, not all roads are in need of chipped 

materials. 

Hydraulic Mulch 

Agricultural material can be shredded into wood fiber and used as hydraulic 

mulch by Caltrans or others. Hydraulic mulch is a mixture of shredded wood 

fiber or a hydraulic matrix and a stabilizing emulsion or tackifier. The mixture is 
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typically applied to disturbed areas requiring temporary protection until 

permanent vegetation is established or disturbed areas that must be re-disturbed 

following an extended period of inactivity (Caltrans Storm Water Quality 

Handbooks, Section 3, Hydraulic Mulch SS-3). Caltrans uses hydraulic mulch as 

one of the alternatives to temporarily protect exposed soil from erosion by rain or 

wind. However, the wood fiber hydraulic mulches are generally short-lived, 

lasting only a part of a growing season, which operators may have to take into 

account for long-term projects. In addition, for the wood fiber hydraulic mulches 

to be effective, the material requires a drying time of 24-hours (Standard 

Specifications Sections 20-2.08). 

Wood chips to be used as hydraulic mulch are required to be cleaned and free of 

salt and deleterious materials such as clods, coarse objects, sticks, rocks, and 

weeds. Such requirements may minimize efficiency during processing of the 

agricultural materials, and increase costs from separating the material or 

diverting different parts of the material to various locations for alternative use. 

Use of hydraulic fiber mulch has increased over the years as it has proven to be 

a cleaner alternative to hay or straw mulches, however, staff is not aware of 

agricultural material being used for the hydraulic mulch process on a market 

scale. Therefore, staff will not pursue this option as a feasible alternative for 

open burning of agricultural material. 

Wood Mulch 

Agricultural materials could also be recycled as wood mulch. Wood mulching 

can be used in landscape projects or for erosion control and may be a mixture of 

shredded wood mulch, bark, and compost. The material is primarily used to 

reduce erosion by protecting bare soil from rainfall impact, increasing infiltration, 

and reducing runoff. Caltrans found that wood mulching can be used as 

temporary soil stabilization for disturbed areas awaiting revegetation and 

permanent cover or as a temporary, non-vegetative ground cover on slopes 

(Caltrans Storm Water Quality Handbooks – Section 3, Wood Mulching SS-8). 

As part of wood mulching, the greeneries from the agricultural materials may also 

be used for similar purposes and composted as necessary to kill weed seeds. 

However, there are limitations to using wood mulch, such as introduction to 

unwanted species, possible sheet erosion because the material cannot withstand 

concentrated flows, and the green materials may bring in unwanted weeds and 

plant materials. In addition to these considerations, staff is not aware of most 

agricultural material being used for this process on a market scale. Therefore, 

staff will not pursue this option as a feasible alternative to open burning of 

agricultural material. 
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4.1.10 Hand Crews for Removal of Materials 

Some operators have considered using hand crews to remove materials, such as 

weeds, as a potential alternative for open burning. The labor-intensive removal 

of individual weeds is often characterized with unreasonable costs and safety 

issues. Additionally, hand removal of weeds is technically unfeasible due to the 

magnitude of weed abatement. Technological development is needed to reduce 

the burning of weed abatement material. 

4.1.11 Overseas Shipment of Raisin Trays 

In the past, some growers have shipped reusable materials, such as raisin trays, 

overseas to be recycled. However, the alternative is no longer available for 

these materials. 

4.1.12 Water Decomposition for Rice Stubble (Straw)

In recent years, water decomposition has become more prevalent than burning 

rice fields stemming with the passing of the Connelly-Areias-Chandler Rice Straw 

Burning Reduction Act of 1991. The Act mandated the reduction of burned rice 

acres over a ten year period besides that which is done for disease control. 

Currently, rice farmers are restricted to burn no more than 25% of planted acres, 

or up to 125,000 acres basinwide, and have moved more to flooding rice fields to 

improve the rate of decomposition. 

Rice farmers flail mow the rice stubble into about 4-inch sections and stubble 

disk it, to ensure it has contacted with the soil four to five inches deep. It is then 

flooded as soon as possible to keep the clods covered. Flooding the fields 

during the winter helps with blast and speeds decomposition, as well as providing 

some fertilizer benefits. 

Water availability and costs for winter water are a concern but can be offset by 

other practices. Some disadvantages of water decomposition arise with certain 

weather conditions but extra precaution is taken, such as managing the water 

flow and battening down the hatches, to prevent damage to the rice patties. 

Water decomposition is a common alternative to burning and is required in areas 

that limit the amount of acreage that can be burned. 

4.1.13 Baling Rice Stubble (Straw) 

As discussed above, alternatives to burning rice fields have been sought, 

especially with the passing of the Connelly-Areias-Chandler Rice Straw Burning 

Reduction Act of 1991. Baling rice straw was a highly anticipated option when the 

Act was passed but has declined in viability. It is estimated that only about 3-5% 
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of farmers use rice straw off-field. Baling rice straw is utilized even less due to a 

diminished market need and cost of production. Soil incorporation and flooding 

rice fields are more feasible and viable alternatives while potential uses are still 

being explored.

4.2 ANIMAL-RELATED MATERIAL 

4.2.1 Burial 

Burial seems to be most suitable for small amounts of material. Burial requires 

care in site selection because as carcasses decompose, they release materials 

that can pollute ground water, particularly if large volumes are buried. 

Advantages of burial are the low cost (if the operator owns the necessary 

equipment) and biosecurity (no trucks coming to the farm to pick up carcasses). 

4.2.2 Incineration 

Field incineration is only appropriate for deceased animals in those instances 

where the spread of disease is a concern. Decisions on how to dispose of 

diseased animals are deferred to local agricultural commissioners. 

4.2.3 Rendering 

Rendering provides a much needed service to the animal industries in the 

SJVAB and is subject to certain government food safety and environmental 

regulations. There are six rendering plants in the SJVAB. Five of the plants are 

independent operations and collect animals from other sites. The sixth plant is 

an integrated plant and operates in conjunction with its affiliated animal slaughter 

and meat processing plants. 

In most rendering systems, raw materials are ground to a uniform size and 

placed in continuous cookers or in batch cookers, which evaporate moisture and 

free fat from protein and bone. A series of conveyers, presses, and a centrifuge 

continue the process of separating fat from solids. The finished fat (e.g., tallow, 

lard, yellow grease) goes into separate tanks, and the solid protein (e.g., meat 

and bone meal (MBM) and poultry meal) is pressed into cake for processing into 

feed. Other rendering systems are used, including those that recover protein 

solids from slaughterhouse blood or that process used restaurant grease. 

The five independent rendering plants provide pick up and delivery for their 

customers. The plants do not allow public drive-up delivery in order to better 

control traffic at the plant and the quality of the animals processed. The pick up 

and delivery service is not available to any operator that has animals available for 
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several reasons. A key reason is the traveling expense which may make it 

impractical to pick up small numbers of carcasses. 

Rendering companies have certain regulatory and operational restrictions 

regarding the condition of the carcasses they process. In addition to complying 

with regulations governing diseased animals, rendering companies will generally 

not accept carcasses that do not remain intact when handled. Depending upon 

the end product of the rendering process, there may be other restrictions on 

carcass quality and condition. Although this alternative is available, District staff 

does not consider rendering to be a viable or feasible alternative. District staff 

considers burial and incineration (for deceased animals with diseases) to be 

viable alternatives, which are current practices for the industry. 

4.2.4 Sterilization 

For bee hives of diseased colonies that must be destroyed, disease experts 

recommend that the frames and combs be burned in a pit and the ashes 

covered. The heavy woodenware (supers, tops and bottoms, etc.) may be 

sterilized by scraping them clean (the scrapings should be burned) and scorching 

the inside surfaces. The scorching can be done with a propane torch with 

particular attention being paid to cracks and corners. If large quantities of supers 

are to be scorched they may be stacked and painted inside with kerosene and lit. 

To sterilize large quantities of equipment, operators could set up a barrel with a 

boiling lye solution. The woodenware should be immersed in the solution and 

boiled until clean. Frames may also be sterilized in this manner. 
Final Staff Report and 

Recommendations on Agricultural Burning 

Chapter 5 

Emissions from Agricultural Burning 

and Alternatives to Burning 

and Health Considerations 
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 Final Staff Report and 

Recommendations on Agricultural Burning 

Chapter 5: EMISSIONS FROM AGRICULTURAL BURNING AND 

ALTERNATIVES TO BURNING, AND HEALTH CONSIDERATIONS

Figure 5.1 Map illustrating PM2.5 Emissions in the Valley from Open Burning 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

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5-2 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning 

5.1 DISTRIBUTION OF AGRICULTURAL OPEN BURNING EMISSIONS 

The map on the previous page illustrates the tons of PM2.5 emissions per square 

mile and existing and proposed biomass plants in the San Joaquin Valley air 

basin (Valley). The Sectional divisions of the map are the 103 burn allocation 

zones as developed by the District for use in the smoke management system 

(SMS). Each zone in the map is marked to illustrate the three-year average 

annual tons of PM 2.5 emissions per square mile generated from agricultural 

burning of all types for that zone between the years of 2007 and 2009. Most of 

the burn allocation zones with the highest emissions from agricultural burning 

have biomass facilities in or near them. 

5.2 CURRENT EMISSIONS INVENTORY FROM AGRICULTURAL BURNING 

For purposes of this report, the criteria pollutants analyzed include volatile 

organic compounds (VOC), oxides of nitrogen (NOx), and particulate matter 

(PM2.5). The 2007 Ozone Plan control measure for Open Burning (S-AGR-1) 

(Managed Burning and Disposal) pertains to the burning of any material including 

agricultural materials. The Plan identified the summer 2005 emissions inventory 

for open burning as 4.8 tons of NOx per day and 5.7 tons of VOC per day. In the 

winter, the 2008 PM2.5 Plan control measure for Open Burning (S-AGR-1) 

(Managed Burning and Disposal) identifies the 2005 emissions inventory for 

open burning as 8.16 tons of NOx per day, 10.70 tons of PM2.5 per day and 0.19 

tons of SO2 per day. As shown in Figure 5-2, agricultural burning is concentrated 

in winter months when PM2.5 is elevated and ozone values are relatively low. 

Figure 5-2

Average Monthly Agricultural Burning (2007-2009)

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

January 

February 

March

April

May

June

July

August

September

October

November

December

Burn Tons
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 Final Staff Report and 

Recommendations on Agricultural Burning 

Table 5-1 below presents the burn tons, burn acres, and tons of associated 

criteria pollutant emissions associated with agricultural burning averaged over a 

three year period for specific crop types and activities. The specific crop types 

and activities are the crops to be analyzed for the 2010 burn prohibitions 

resulting from state law. Because several crops are not a part of this analysis 

and do not pertain to this report, the data from those crops has been omitted 

from the table below. The data for this table is the best available information, 

and came from the District SMS emission database. 

Table 5-1 

Average Annual Tons, Acres, and Emissions 

from Open Burning of the Remaining CH&SC Crop Types (2007-2009) 

Emissions (Tons) 

Crop Name 

Burn 

Tons 

Burn 

Acres NOx PM 2.5 VOC PM 10 

Almond Pruning 51718 51718 152.57 173.26 134.47 181.01

Apple Pruning 900 391 2.34 1.66 1.03 1.75

Fig Pruning 1227 558 3.19 3.99 3.68 4.23

Pear Pruning 286 110 0.74 1.19 0.73 1.26

Pecan Pruning 501 295 1.30 1.83 1.58 1.96

Quince 47 28 0.12 0.17 0.15 0.18

Walnut Pruning 17083 14236 38.44 34.17 41.00 35.88

<20 Acre Orchard Removal 

(all crops) 70010 2334 182.03 255.54 220.53 273.04

Apple Orchard Removal 691 23 1.80 1.28 0.79 1.35

Citrus Orchard Removal 54035 1801 140.49 151.30 183.72 159.40

Fig Orchard Removal 2392 80 6.22 7.78 7.18 8.25

Pear Orchard Removal 490 16 1.27 2.03 1.25 2.16

Quince Orchard Removal 10 0 0.03 0.04 0.03 0.04

Brooder Paper <1 n/a 0.00 0.00 0.00 0.00

Diseased Beehives 90 41 0.20 0.68 0.48 0.71

Goat <1 n/a 0.00 0.00 0.00 0.003

Ponding/Levee Banks 302 139 0.68 2.29 1.62 2.40

Rice * 9049 3073 23.45 27.79 21.98 29.65

Raisin Trays 890 29683 1.90 0.33 1.94 0.35

Vineyard Removal 197140 13143 512.56 719.56 620.99 768.85

Totals: 406,861 117,668 1,069.3 1,384.9 1,243.2 1,472.5

* Note: no citrus pruning after 2005 

1. Rice category includes residual rice straw, rice straw, rice stubble, and rice field levees. 

Table 5-1 includes the Phase IV materials that were issued open burning 

permits. District staff calculated the burn acres and associated emissions from a 

list of the amounts of selected Phase IV materials that were issued open burning 
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 Final Staff Report and 

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permits, averaged from 2007-2009. The list includes almond pruning, walnut 

pruning, pecan pruning, vineyard removal, raisin trays, and rice stubble. The 

total acres burned from the three-year average of the crops previously mentioned 

are 109,128 acres. The emissions from such activities are presented below: 

Table 5-2 

Average Annual Emissions From 

Open Burning of Selected Phase IV Crops (2007-2009)

Emissions NOx PM 2.5 VOC PM 10 

Tons per Year 706.98 929.38 800.17 988.30 

5.3 EXPECTED EMISSIONS FROM ALTERNATIVES 

 (Criteria Pollutant – PM 2.5) 

Pruning Materials

The analysis in this report indicates that prunings from several crops will most 

likely be shredded on site, or already are shredded on site, as an alternative to 

open burning. The table below is a comprehensive comparison of the average 

annual PM 2.5 emissions from open burn versus shredding for the 

aforementioned crops. For purposes of this analysis, District staff assumed the 

average burn acres would remain constant and that all burn acres would be 

shredded on site. 

The information for this analysis was derived by inputting the burn acre data from 

the “Average Annual Tons, Acres, and Emissions from Open Burning of Crops 

(2007-2009) table presented in Section 5-1 of this report into the District 

Emissions Calculator. The District Emissions Calculator incorporates the 

emissions from various pieces of equipment, including tractors and excavators 

associated with the activity, emissions from transfer and delivery vehicles, and 

other processes such as chipping, as well as the emission factor for each crop 

type and activity. The data presented in the table below is a comprehensive 

emission inventory encompassing all aspects of the affected crops. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-5 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning 

Table 5-3 

Comparison of the Average Annual PM 2.5 Emissions 

From Open Burning and Shredding (2007-2009) 

 PM 2.5 Emissions (Tons) 

Crop Name 

Burn 

Acres Open Burn Shred 

Almond Pruning 51718 203.0 4.8 

Apple Pruning 391 3.5 0.1 

Fig Pruning 558 4.8 0.1 

Pear Pruning 110 1.1 0.01 

Pecan Pruning 295 2.0 0.0 

Quince 28 0.2 0.003 

Walnut Pruning 14236 67.0 1.4 

Total: 67336 281.6 6.4 

Orchard Removal Materials

The analysis in this report also indicated that several crops are sent to the 

biomass facilities and will most likely continue to be sent to biomass facilities as 

biomass fuel as an alternative to open burning. The table below is a 

comprehensive comparison of the average annual PM 2.5 emissions from open 

burn versus biomass processing for the aforementioned crops. For purposes of 

this analysis, District staff assumed the average burn acres would remain 

constant and that all burn acres would be sent to the biomass plant as fuel. 

The information for this analysis was derived by inputting the burn acre data from 

the “Average Annual Tons, Acres, and Emissions from open burning of Crops 

(2007-2009) table presented in Section 5-1 of this report into the District 

Emission Calculator. The District Emission Calculator incorporates the 

emissions created from various pieces of equipment, including tractors and 

excavators associated with the activity, emissions from transfer and delivery 

vehicles, and other processes such as chipping, as well as the emission factor 

for each crop type and activity. The data presented in the next table is a 

comprehensive emission inventory encompassing all aspects of the affected 

crops. 

Table 5-4 

Comparison of the Average Annual PM 2.5 Emissions 

From Open Burning and Biomass Operations (2007-2009) 

 PM 2.5 Emissions (Tons) 

Crop Name 

Burn 

Acres Open Burn Biomass 

<20 Acre Orchard Removal 

(all crops) 2334 264.2 32.8 

Citrus Orchard Removal 1801 203.9 25.3 

Fig Orchard Removal 80 9.1 1.1 

Total: 4215 477.2 59.2 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-6 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning 

5.4 EMISSION REDUCTION ANALYSIS 

5.4.1 Introduction 

The recommendations as described elsewhere in this report will result in greater 

curtailment of agricultural open burning currently allowed under District Rule 

4103. The recommendations will result in the following additional prohibitions: 

 

Orchard Removals

 

• The prohibition of burning of all orchard removals from fig crops over 15 acres 

(District Rule 4103 currently allows burning at all acreage sizes). 

• The prohibition of burning of all orchard removals for all crops (with the 

exception of citrus, apples, pears, and quince) with acreages over 15 acres 

up to and including 20 acres (District Rule 4103 currently allows burning of 

acreages in this range). 

Prunings

• The prohibition of burning of all orchard pruning material from fig crops for all 

acreages (District Rule 4103 currently allows burning at all acreage sizes). 

• The prohibition of burning of prunings for each agricultural operation whose 

total nut acreage (i.e., almonds, walnuts, and pecans) at all agricultural 

operation sites is 3,500 acres or more. For each agricultural operation whose 

total nut acreage at all agricultural operation sites is less than 3,500 acres, 

burning of up to 20 acres of prunings per year is allowed plus additional 

acreage when a determination of economic hardship is made by the District 

(District Rule 4103 currently allows burning at all acreage sizes). 

The estimated emission reductions to be achieved by the new prohibitions listed 

above are presented in Table 5-5. Details of the emission reduction analysis are 

discussed in the next section (Methodology and Calculations). 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-7 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning 

Table 5-5 

Total Annual Emission Reductions from All New Open Burning 

Prohibitions 

Category Crop Nox 

(ton/year) 

PM2.5 

(ton/year) 

VOC 

(ton/year) 

Figs 2.8 6.7 6.1 

Orchard 

Removals All Orchards 

Less Than 

20 Acres* 

25.8 61.7 56.4 

Figs 0.4 2.1 1.7 

Almond 9.5 48.8 38.0 

Pecan 0.0 0.1 0.1 

Orchard 

Prunings 

Walnut 0.7 3.7 2.9 

Total 39.2 123.1 105.2 

* except citrus, apples, pears and quince 

5.4.2 Methodology and Calculations 

Step 1: Determine the reduction in acreage which will be burned as a result of 

the new prohibitions

District staff analyzed information collected during 2007-2009 from the District’s 

Smoke Management System (SMS) in order to estimate the reduction in acreage 

of burning resulting from the new prohibitions. The SMS manages agricultural 

open burning in the San Joaquin Valley Air Basin (SJVAB) and collects and 

maintains information pertinent to the amount and type of material burned in the 

SJVAB. For each permitted open burning operation during the time period, the 

SMS identifies the specific item burned and the associated acreage. 

In order to estimate the reductions in acreage of orchard burning resulting from 

each of the new orchard prohibitions listed, it was assumed that average annual 

acreage of permitted burns in the SMS for the period 2007-2009 is representative 

of the expected burning reduction for each category. 

Extraction and analysis of data from the SMS for orchard removals yielded the 

following annual reductions in acres burned: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-8 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning 

Table 5-6 Data from the SMS for Orchard Removal and Pruning 

New Prohibition

Annual 

Reduction in 

Acreage Burned

Orchard removals from fig crops over 15 acres 61 

Orchard pruning material from fig crops for all acreages 557 

Orchard removals for all crops (with the exception of citrus, apples, 

pears, and quince) 560 

Almond pruning material 12,670 

Pecan pruning material 22 

Walnut pruning material 969 

Step 2: Establish Applicable Emission Factors on a Per Acre Basis

Differential emission reduction factors for orchard removals and for orchard 

prunings, along with the basis for their development, are presented in Tables 5-7 

and 5-8 respectively of the cost and emissions section of this staff report 

(Chapter 5). 

Differential emission reduction factors for orchard removals (assuming 30 tons 

dry biomass per acre) are based on chipping and conversion of the removed 

trees to biomass fuel rather than burning: 

Differential 

Emission 

Factor 

(tons/acre) 

=

Burning 

Emission 

Factor 

(tons/acre)

- 

Chipping/Biomass 

Emission Factor 

(tons/acre) 

From Table 5-4 of the cost and emissions section the differential emission factors 

for orchard removals between 15 and 20 acres are: 

NOx 0.0460 tons per acre 

PM2.5 0.1101 tons per acre

VOC 0.1007 tons per acre 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-9 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning 

Differential factors for prunings (assuming 1 ton of dry prunings per acre) are 

based on chipping and land incorporation of prunings in lieu of burning: 

Differential 

Emission 

Factor 

(lb/acre) 

=

Burning 

Emission 

Factor 

(lb/acre) 

- 

Land 

Incorporation 

Emission Factor 

(lb/acre) 

From Table 5-8 of the cost and emissions section the differential emission factors 

for orchard prunings are: 

NOx 1.5 lb per acre 

PM2.5 7.7 lb per acre

VOC 6.0 lb per acre 

Step 3: Apply Applicable Emission Factor to Acreage Data Extracted from the 

SMS 

 

Tables 5-11 and 5-12 present the results for orchard removals and prunings 

respectively. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

5-10 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

Table 5-7

Emission Reductions from New Orchard Removal Prohibitions 

Prohibition NOx PM2.5 VOC 

Crop 

Current 

Permitted 

Open 

Burning 

New 

Prohibition 

Acres 

Reduced 

per SMS

Differential 

Emission 

Factor 

(ton/acre) 

Annual 

Emission 

Reduction 

(tons) 

Differential 

Emission 

Factor 

(ton/acre) 

Annual 

Emission 

Reduction 

tons) 

Differential 

Emission 

Factor 

(ton/acre) 

Annual 

Emission 

Reduction 

tons) 

Figs 

Permitted 

at all 

acreages 

Prohibited 

for acreage 

greater than 

15 acres 

61 0.046 2.8 0.1101 6.7 0.1007 6.1 

All other crops 

(with the 

exception of 

citrus, apples, 

pears, and 

quince) 

Permitted 

for 20 

acres or 

Less 

Prohibited 

for acreage 

greater than 

15 acres 

560 0.046 25.8 0.1101 61.7 0.1007 56.4 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

5-11 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

Table 5-8 

Emission Reductions from New Orchard Pruning Prohibitions 

Prohibition NOx PM2.5 VOC 

Crop 

Current 

Permitted 

Open 

Burning 

New 

Prohibition 

Acres 

Reduced 

per SMS

Differential 

Emission 

Factor 

(lb/acre) 

Annual 

Emission 

Reduction 

(ton) 

Differential 

Emission 

Factor 

(lb/acre) 

Annual 

Emission 

Reduction 

(ton) 

Differential 

Emission 

Factor 

(lb/acre) 

Annual 

Emission 

Reduction 

(ton) 

Figs 

Permitted 

at all 

acreages 

Prohibited for 

all acreages 557 1.5 0.4 7.7 2.1 6.0 1.7 

Almond (surface 

harvested crop) 

Permitted 

at all 

acreages 

Prohibited for 

acreage 

greater than 

20 acres 

12,670 1.5 9.5 7.7 48.8 6.0 38.0 

Pecan (surface 

harvested crop) 

Permitted 

at all 

acreages 

Prohibited for 

acreage 

greater than 

20 acres 

22 1.5 0.0 7.7 0.1 6.0 0.1 

Walnut (surface 

harvested crop) 

Permitted 

at all 

acreages 

Prohibited for 

acreage 

greater than 

20 acres 

969 1.5 0.7 7.7 3.7 6.0 2.9 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-12 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

5.5 HEALTH BENEFITS OF REDUCED OPEN BURNING 

Given the minimal impact of open burning on ozone levels in the Valley 

mentioned above, this discussion emphasizes the health benefits of reduced 

open burning and associated PM 2.5 emissions. Prior scientific studies as well 

as District experience have shown the importance of steadily reducing population 

exposure to PM 2.5 through controls on residential wood burning and open 

burning. The San Joaquin Valley experiences some of the highest annual 

average concentrations of PM 2.5 in the nation. Well-defined epidemiological 

relationships have been established between exposure to elevated PM 2.5 and a 

range of health endpoints, including ischemic heart disease, asthma, chronic 

bronchitis, premature mortality, and others. The region can experience multi-day 

periods of atmospheric stagnation during which very little air mass is transferred 

in and out of the Valley. The net result can be a daily buildup of PM 2.5 levels, 

sometimes beyond the 24 hour federal standard of 35 μg/m3

. 

Unlike areas such as Southern California where PM 2.5 levels are more 

distributed throughout the year, fine particulates are seasonally concentrated in 

the Valley. Because of this seasonal concentration effect, District controls 

currently imposed on open burning and residential wood burning have had a 

disproportionate effect in reducing wintertime PM 2.5 concentrations. In the case 

of residential wood burning, an external scientific evaluation was conducted by 

California State University (CSU) Fresno of Rule 4901’s periodic curtailments 

(see www.cvhpi.org). This assessment found that as of the winter 2007-08 

season (prior to the October 2008 amending of Rule 4901), daily curtailments 

coupled with reduced household wood burning overall had resulted in a 12.9% 

and 13.6% reduction in annual PM 2.5 concentrations for Bakersfield and 

Fresno, respectively. Using the US EPA’s BenMAP model for calculating health 

benefits of reduced PM2.5 exposure, these reductions translated into significant 

public health benefits, including significantly reduced cardiovascular disease, 

pulmonary disease, and pre-mature deaths. 

A key element in this success has been the imposition of restrictions in 

residential wood burning on days when meteorological conditions create the risk 

of health standard violations. Initially, as of November 1, 2003, that threshold 

was established at the 1997 24 hr. PM 2.5 standard of 65 μg/m3. As amended in 

October 2008 for the 2008-09 winter season, that daily curtailment threshold was 

substantially reduced to 30 μg/m3

. That reduced curtailment threshold has 

benefited public health in three ways: First, it has resulted in an absolute 

reduction in the total seasonal tonnage of residential wood burned. Second, it 

has insured that on days when wood burning is allowed, each ton of emissions is 

more thoroughly diluted and dispersed, with attendant reductions in harmful peak 

exposures. And third, by restricting burning to days with reasonably good 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-13 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

atmospheric dispersion, the formation of secondary aerosols such as ammonium 

nitrate during multi-day stagnation events is minimized. 

By restricting the analysis to the Bakersfield and Fresno/Clovis metro areas, the 

health evaluation of Rule 4901 (Wood Burning Fireplaces and Wood Burning 

Heaters) was made possible by a well-defined pre-and post-Rule 4901 

population exposure estimate for PM2.5. However, in the case of health benefits 

from reduced burning under Rule 4103, it is not possible to replicate this analysis 

for several reasons. First, ambient monitors are generally not found in rural 

areas. In addition, the population density is considerably lower. As a result, 

estimating accurate population exposure reductions resulting from current or 

estimated reductions on agricultural burning is very difficult and not attempted 

here. 

However, it is possible to draw on the experience of the District evaluation of 

Rule 4901 to draw some reasonable conclusions that provide a public health 

justification for past and prospective reductions in open burning under Rule 4103. 

First, the basin-wide emissions inventory for open burning and residential wood 

combustion are comparable. According to the 2008 CARB emissions inventory, 

estimated tons per day (tpd) of PM2.5 from wood burned by households was 9.5 

and 14.8 for agricultural material. Second, it is important to note at that as of 

December 2009, daily county-level curtailments of open burning are based on 

the same predicted 24 hr. 30 μg/m3

 concentration threshold used in Rule 4901. 

This means that a predominant source of rural and urban open burn emissions 

has been eliminated on low dispersion days, with corresponding reductions in 

overall exposure to individuals in areas where open burning is occurring, as well 

as minimizing exposure to secondary PM2.5. 

Reduced emissions from Rule 4103 are presented below in Table 5-9. In a 

historical sense, reductions achieved to date represent a very rapid rate of 

emission decline in a given economic sector, with attendant health benefits to a 

more dispersed, rural population. 

Table 5-9 

Reductions in Criteria Pollutants Under Rule 4103 Since 2004 

 NOx PM10 PM2.5 VOC CO 

Total Tonnage Reduction 

Since 2004 1,217 1,981 1,860 1,516 15,273

% Reduction Since 2004 48.9% 52.7% 52.6% 50.4% 48.5%

TPD Reduction Since 2004 3.3 5.4 5.1 4.2 41.8

Additional reductions anticipated under the amended Rule 4103 are shown 

above. The more modest reductions arising from the recommendations reflect 

the current balance of commodity profitability and costs for processing at 

biomass plants, as defined by the CH&SC. Past experience has shown that the 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-14 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

per unit costs of alternative disposal options with less environmental impacts 

tend to decline over time due to, in this case, new biomass plant capacity and the 

emergence of alternative disposal technologies. The District supports legislation 

that will encourage, promote and facilitate alternative uses for agricultural 

material as well as policies and initiatives that encourage renewable energy and 

energy efficiency including supporting legislation that provides additional biomass 

capacity utilizing agricultural materials. It is likely that the current constraints on 

open burning emission reductions imposed by the CH&SC will be reduced over 

time, with proportional health benefits. 

5.6 HEALTH RISK ASSESSMENT OF OPEN BURNING AND 

ALTERNATIVES 

Often under the requirements of CEQA-mandated risk assessments, the District 

routinely employs several health risk assessment (HRA) models in order to 

estimate health risks posed by exposure to air pollutants from existing or 

hypothetical sources. These HRA models are based on the following elements: 

(1) knowledge from prior scientific studies about the relative toxicity of pollutants, 

(2) similar knowledge about the relative effects of increased concentrations of a 

given pollutant, (3) the hourly rate of emissions by mass or parts per volume, i.e. 

emission factor, from a given source and the duration of those emissions, (4) 

specification of meteorological conditions, (5) how the pollutants are dispersed 

and/or transformed in the atmosphere, (6) a gradient or exposure surface that 

specifies various concentration levels at a given distance from a source and time, 

(7) (in some cases) the spatial distribution and characteristics of the exposed 

population, and (8) (in some cases) whether and how different sub-populations 

may be differentially affected such as children to a given level and duration of 

exposure. 

To evaluate the acute (short-term) and chronic (long-term) health impact of open 

burning of agricultural material and alternative disposal methods, the following 

scenarios were analyzed (modeled): 

Scenario 1: Open burning of prunings from 20 acres of nut trees. Emission 

sources included diesel exhaust from equipment used to form the 

burn piles, and emissions from combustion of the organic material. 

Scenario 2: Land incorporation of prunings from 20 acres of nut trees. Emission 

source included diesel exhaust from equipment used to shred and 

incorporate prunings into the soil. 

Scenario 3: Transfer of prunings from 20 acres of nut trees to a biomass facility. 

Emission sources included diesel exhaust from equipment used to 

collect and chip/shred prunings, diesel exhaust from trucks used to 

transport the chipped material to the biomass plant, diesel exhaust 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-15 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

from equipment used to unload and process the chipped material at 

the biomass plant, and emissions from the biomass combustor. 

Scenario 4: Open burning of 20 acres of nut trees (orchard removal). Emission 

sources included diesel exhaust from equipment used to form the 

burn piles and emissions from the combustion the organic material. 

Scenario 5: Transfer of 20 acres of nut trees (orchard removal) to a biomass 

facility. Emission sources included diesel exhaust from equipment 

used to collect and chip/shred the orchard material, diesel exhaust 

from a truck used to transport the chipped material to the biomass 

plant, diesel exhaust from equipment used to unload and process 

the chipped material at the biomass plant, and emissions from the 

biomass combustor. 

5.6.1 Methodology and Calculations 

Emissions for each scenario evaluated were calculated using District-developed 

spreadsheets and the parameters listed below: 

Table 5-10 

Variables used to estimate scenario emissions 

Variables Prunings Orchard 

Removal 

Crop type Orchard Orchard 

Ag material (acres) 20 20 

Material removed (tons/acre) 1 30 

Roots removed (tons/acre) 0 1 

Field equipment activity (hours/acre) 1 1 

Power plant equipment activity (hours/acre) 2 2 

Ag material delivered to power plant 

(tons/truck) 

24 24 

Round trip distance to power plant (miles) 100 100 

Off-road diesel equipment was used to process crop material in the field and at 

the biomass facility. Off road equipment activity was modeled as an area source 

over the entire surface of the orchard or that portion of the biomass facility used 

to receive and process wood chips. All particulate matter from off-road diesel 

equipment exhaust was modeled as diesel particulate matter (DPM). Relative 

risks generated by air contaminants from the open burning of agricultural material 

were calculated using the California Air Resources Board (CARB) particulate 

matter speciation profile 450 for particulates, and emission factors from Lemieux, 

Lutes and Santoianni (2002) for volatile organic compounds. Emissions from 

open burn piles were modeled as point sources to allow for thermal loft from the 

heat of combustion. The open burning of orchard prunings was assumed to 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-16 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

occur in four separate piles located at the southern border of the orchard. The 

open burning of the orchard removal material was assumed to occur in twenty 

piles evenly distributed within the orchard over a 24 hr. period. All particulate 

matter from on-road diesel truck exhaust was modeled as DPM. On-road truck 

travel was modeled as a line source consisting of a one mile series of volume 

sources. 

To calculate pollutant dispersion and the resulting exposure gradient, the 

AERMOD model was used. Meteorological data for 2004-2008 from Bakersfield 

was employed to determine the dispersion factors (i.e., the predicted 

concentration or Χ divided by the normalized source strength or Q) for a receptor 

(human population) grid. These dispersion factors were input into the Hot Spots 

Analysis and Reporting Program (HARP) risk assessment module to calculate 

the chronic and acute hazard indices as well as the carcinogenic risk for five 

scenarios outlined above. No actual locations and nearby populations were used 

in the model analysis. 

5.6.2 Health Risk Assessment Results 

Worst case health risks for the open burning of agricultural material and their 

alternatives are presented in Table 5-11 (pruning scenario) and Table 5-12 

(orchard removal scenario). The model results for open burning of prunings 

show that the cancer risk and chronic hazard indices are very low and not of 

concern for all disposal options. The acute hazard index in this case pertains to 

risk of an acute respiratory response over the short-term (24 hour) exposure 

generated by the burning of the prunings for a person standing within 25 meters 

of the burn piles. In this air pollutant modeling scenario, any acute hazard index 

score of over 1.0 indicates the potential for a negative impact on respiratory 

health. As shown, this threshold is not exceeded for a maximum 24 hour. 

exposure scenario. 

In the case of a worst-case health risk assessment for orchard removal options 

are shown in Table 5-11. As in the case of prunings, cancer and chronic hazard 

indices for all options are very low values that do not indicate excessive risk. As 

shown in Figure 5-3, the open burning exposure scenario is based on the 

assumption that removed trees are put into 20 piles, one per acre, and burned 

simultaneously. In this case, the acute hazard index score for 24 hr. exposure in 

the zone nearest the burn piles is excessive (10.70). As one moves further from 

the burn zone this relative hazard to short-term respiratory health drops relatively 

quickly, falling by approximately 50% after 500 meters and to an acceptable level 

of less than 1.0 after 1,000 meters. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-17 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

Table 5-11 

Comparative Pruning Risk (20 Acres): Open Burning vs. Chipping/Shredding and 

Incorporation vs. Biomass Facility

Health Risk 

Source 

Maximum 

Individual Cancer 

Risk2

 

(x 10-6) 

Acute Hazard 

Index 

Chronic Hazard 

Index 

Orchard Burning 3.32 0.83 0.07 

Land Incorporation 7.59 nc1 nc 

Biomass Facility – Off Site 

 Orchard 9.69 nc nc 

 Transit 0.00 nc nc 

 Off Site Total 9.69 nc nc 

Biomass Facility – On Site 

 Facility 0.10 0.00 0.00 

 Transit 0.00 nc nc 

 On Site Total 0.10 0.00 0.00 

1

 Acute and Chronic Hazard Indices were not calculated since there is no risk factor or the risk factor is so low that it has 

been determined to be insignificant for this type of unit. 

2 70 year exposure used.

 

Table 5-12 

Comparative Orchard Burning Risk (20 Acres): Open Burning vs. Chipping/Shredding, 

On-Site Biomass Facility vs. Off-Site Biomass Facility 

Health Risk 

Source 

Maximum 

Individual Cancer 

Risk2

(x 10-6) 

Acute Hazard 

Index 

Chronic Hazard 

Index 

Orchard Burning 2.69 10.70 0.58 

Biomass Facility – Off Site 

 Orchard 1.84 nc1 nc 

 Transit 0.09 nc nc 

 Off Site Total 1.93 nc nc 

Biomass Facility – On Site 

 Facility 0.55 0.00 0.00 

 Transit 0.09 nc nc 

 On Site Total 0.65 0.00 0.00 

1

 Acute and Chronic Hazard Indices were not calculated since there is no risk factor or the risk factor is so low that it has 

been determined to be insignificant for this type of unit. 

2 9 year exposure used.
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

5-18 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

Figure 5-3 

Acute Respiratory Risk Isopleths for Open Burning of Prunings (24 hr exposure) 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

5-19 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

Figure 5-4 

Acute Respiratory Risk Isopleths for Open Burning of Orchard Removal (24 hr exposure) 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-20 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

There are a number of practices currently employed by District Compliance staff 

under the policy for Rule 4103 that are designed to minimize the potential health 

hazard of orchard removal burnings of this scale. The Appendix A (p. 7) from the 

Rule 4103 District Policy identifies the conditions that must be satisfied when 

District Compliance staff conduct their mandatory field site inspections prior to 

granting approval to proceed with burning: 

Burn permits issued in rural residential areas, or in other areas 

where smoke may affect smoke sensitive areas, must include sitespecific instructions and permit conditions. The instructions and/or 

conditions must limit the possible smoke impact on nearby 

neighbors and/or smoke sensitive areas. 

1. The permit applicant must be advised that only those materials 

produced along with the crop and listed on the burn permit may 

be permitted to burn. 

2. Additional permit conditions may stipulate any or all of the 

following: 

a. The wind direction required at the time of ignition 

b. The burn site location on the property 

c. The day(s) of the week the burning may occur 

d. The time of day a burn may be ignited 

e. The time of day to cease burning or cease adding material to 

the fire 

f. The size of the burn pile permitted to be burned at one time 

g. The permit will be issued for the duration of need only. 

Compliance Appendix A (p. 35) from the Rule 4103 District Policy also makes 

explicit limits on burning in smoke sensitive areas with greater population 

densities or facilities with sensitive individuals:

SMOKE SENSITIVE AREAS: Smoke sensitive areas are populated 

areas or other areas where smoke and air pollutants can adversely 

affect public health or welfare. These areas can include cities, 

towns, communities, campgrounds, trails, recreational areas, 

hospitals, nursing homes, medical clinics, schools, day-care 

centers, roads and highways, airports, public events, and shopping 

centers. 

A District on-site inspection is required near dense populations or 

smoke sensitive areas. If the District determines there is a reason 

to believe smoke produced from a proposed burn may cause 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-21 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

complaints or create a nuisance, the burning may only be permitted 

under the following conditions: 

A. The District must determine there is no other reasonable 

method of disposal. 

B. The quantities of materials to be burned shall be limited as 

needed. 

C. The days burning may be authorized may be limited. For 

example, a burn site upwind from a school may have to limit 

burning to when school is not in session, such as on weekends 

or during school vacation provided that no other special events 

or school functions are occurring during these off times. 

D. Permittee must establish and provide an at-ready means to 

extinguish the fire if directed to do so by the District or any 

public officer. 

E. Additional permit conditions may stipulate: 

1. The wind direction required at the time of ignition. 

2. The burn site location on the property. 

3. The day(s) of the week the burning may occur. 

4. The time of day a burn may be ignited. 

5. The time of day to cease burning or cease adding material 

to the fire. 

6. The size of the burn pile and/or the number of burn piles 

authorized to burn at one time. 

7. The permit will be issued for the duration of need only. 

F. If any of the conditions provided above cannot be met, such 

burning shall not be permitted. 

Because of these limitations, excess acute health risks from orchard removals 

are minimized. As noted above, the overall trajectory of health risks from 

agricultural open burning has been following a steep downward path since 2004. 

The results of this health risk assessment underscore the logic of (1) the current 

balance stuck under the current CH&SC between the economic costs of 

alternatives to burning on the one hand and the potential health impacts of open 

burning on the other, as well as (2) the ongoing importance of finding new 

incentives and technologies for the long-term elimination of open burning of 

agricultural materials. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

5-22 Chapter 5: Emissions from Agricultural Burning and 

Alternatives to Burning and Health Considerations 

 Final Staff Report and 

Recommendations on Agricultural Burning

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Recommendations on Agricultural Burning 

Chapter 6 

Cost Impacts of Alternatives to Burning 
Final Staff Report and 

Recommendations on Agricultural Burning 

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San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-1 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Chapter 6: COST IMPACTS OF ALTERNATIVES TO BURNING 

(for each affected crop/material)

The costs shown in this analysis are borne by growers. Growers typically pay 

the contractor to burn, chip, or shred the materials. The biomass facilities also 

pay chipping operators for the chipped material. The District is estimating 

incremental costs of non-burning alternatives by subtracting the cost of open 

burning from the total cost of the alternative. The incremental costs are then 

used in further analysis. 

6.1 COSTS FOR OPEN BURNING 

6.1.1 Costs for Orchard and Vineyard Removal by Open Burning 

Since the entire orchard or vineyard removal process may be affected by the 

method utilized for disposal of the material, the District examined current costs 

for the complete removal/burning process including tree or vine extraction, 

transport/piling and burning. For orchard removals, the trees are typically either 

pushed over with a dozer or removed from the ground with an excavator. Large 

trees may require some breaking up for handling. After drying in the field, the 

downed trees are then moved to burn piles either by dozer or wheel-loader. 

Vineyards are typically bull dozed into piles for burning with vineyard wire in 

place (the wire is removed and disposed after burning is complete). 

To obtain costs, orchard removal contractors in the SJV were contacted who 

provided expected average costs for the removal and burning for various orchard 

types and vineyards. All contractors requested confidentiality with respect to 

their pricing. Per discussions with the contractors, actual cost for a particular site 

will vary with specific orchard or vineyard configuration and site conditions. 

The agricultural industry also provided estimates for removal/burning operations. 

Average pricing provided to the District by the orchard removal contractors as 

well as estimates provided by the agricultural industry are as follows: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-2 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Table 6-1 

Prices for Orchard and Vineyard Removals by Open Burning 

$ per acre 

 Citrus 

Average for 

other Orchards 

including nuts, 

stone fruit and 

general 

deciduous 

Vineyards 

Minimum 

Charge per 

Burning 

Project 

Average 

Contractor 

Pricing 

$400 $267 $213 $1,150 

Ag Industry 

Estimates $314 - $267 - 

The above pricing includes burning of roots, assuming the roots would be 

extracted from the ground prior to the burning operation. Orchard removal 

contractors generally indicated citrus orchard removal and burning to be 

somewhat more difficult than the average for other types of orchards and 

indicated a higher price for this specific type. 

Agricultural industry estimates for open burning did not specifically address 

orchard removals other than Citrus. For purposes of analysis, the District will 

assume that the agricultural industry estimate of $314 per acre applies to all 

orchards. Additionally, agricultural industry estimates did not address a minimum 

project charge for burning projects. For purposes of analysis, the District will 

assume that the minimum project charge estimated by orchard contractors will be 

generally applicable. 

6.1.2 Costs for Disposal of Orchard Prunings by Open Burning 

Disposal of orchard prunings by open burning requires that the prunings be 

pushed to the end of each row and then piled for burning. Pruning weights are 

typically 1 to 1.5 tons per acre on a wet basis (30-35% moisture) for orchards 

regardless of tree type per information provided both by orchard contractors and 

the farming industry. To burn the prunings, costs must be incurred to 1) push the 

prunings to the end of each row and then pile them for burning, 2) obtain a 

burning permit and 3) then supervise the burn. The farming industry estimates 

the cost of this activity at approximately $22 per acre. It is assumed that a $500 

minimum project cost would be required by a contractor to perform these 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-3 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

services consistent with quoted project minimums for smaller chipping 

operations. 

6.2 COSTS OF ALTERNATIVES TO BURNING 

6.2.1 Costs for Orchard and Vineyard Removal for fuel at Biomass Power 

Plants 

The District has identified the grinding (or chipping) of orchard removal material 

followed by utilization of the material as fuel for power generation as a feasible 

alternative to open burning. In this approach for orchard removal the trees are 

typically extracted or pushed over and then allowed to dry in the field for 

approximately four weeks prior to grinding (except for citrus for which a drying 

time of approximately eight weeks is required to ensure that grinding will produce 

a usable biomass fuel). After drying, the downed trees are typically loaded on a 

wheel-loader which transports them to the grinder. The grinder may be either a 

tub grinder or a horizontal hammer mill, depending upon the contractor and/or 

the specifics of the job. After grinding, the biomass is normally loaded into heavy 

haul trucks and transported to the biomass facility. 

To obtain costs for conversion of orchard removal matter into biomass fuel, the 

District contacted several established orchard removal contractors and obtained 

budgetary quotations for typical orchard removal operations with conversion of 

the material to biomass. In addition, the agricultural industry provided cost 

estimates for this activity. Results of the cost survey are presented in the 

following table: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-4 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Table 6-2 

Cost for Orchard and Vineyard Removals by Grinding to Biomass Fuel 

$ per acre 

Citrus Other Orchards Vineyards Minimum Charge per Project 

Orchard 

Contractors

Ag 

Industry 

Estimate 

Orchard 

Contractors

Ag 

Industry 

Estimate 

Orchard 

Contractors

Ag 

Industry 

Estimate 

Orchard 

Contractors

Ag 

Industry 

Estimate

Average 

Contractor 

Quote/Estimate 

for Orchard 

Removal 

$525 $580 $388 $400 $225 $380 

Transporting and 

Composting 

Roots 

$244 $75 $244 $75 $75 $244 

Removal of 

Vineyard Wire 

and Trellis 

N/A N/A N/A N/A $650 $775 

$5,000 $5,000 

Total Evaluated 

Cost Based on 

Average 

Contractor Quote 

or Ag Industry 

Estimate 

$769 $655 $632 $475 $950 $1,399 $5,000 $5,000 

Cost Differential 

Between 

Grinding to 

Biomass and 

Open Burning 

$369 $341 $365 $161 $737 $1,132 $3,850 $3,850 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-5 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Per discussions with the contractors providing budgetary estimates, the actual 

cost for a particular site will vary with specific orchard or vineyard configuration, 

site conditions, haul distance to a biomass power plant and the current price paid 

for biomass fuel. To ensure that the quoted costs would be comparable to those 

quoted for open burning, the scope included tree removal, grinding and transport 

to the biomass facility. The pricing did not include any impact from any federal or 

other incentive programs aimed at promoting use of agricultural material as 

biomass fuel (since such programs are considered temporary). 

Similar to the pricing obtained for orchard burning, the District’s discussions with 

orchard removal contractors also indicated that the pricing for citrus orchards is 

higher than the average for other orchard types, primarily due to issues with 

separation of dirt from the root ball in clay or rocky soil and the lower desirability 

of citrus as biomass fuel. This is consistent with the estimates provided by the 

agricultural industry which also indicate a higher pricing for citrus versus other 

types of orchards. Based on discussions with contractors, a value of 30 tons 

biomass fuel per acre was assumed for citrus orchards. 

In the costs presented in the table above, the District’s data assumed that the 

roots, after drying in the field, will be transported to a composting operation. The 

following cost estimates were provided by the ag industry for removing root 

materials: $75 for one ton of roots and $244 for four tons of roots. For orchard 

removals, District staff estimated the roots to weigh four tons per acre. For 

vineyard removals, District staff assumed that the roots weigh one ton per acre. 

Ag industry estimates were based on 1 ton of roots per acre for orchards and 4 

tons per acre for vineyards. 

As with open burning, the prices listed above do not include extraction of roots 

from the field and the loading of roots into piles for further handling because as 

mentioned previously, it is assumed that this cost will be incurred regardless of 

the approach used for orchard or vineyard removal and thus can be ignored for 

the District’s comparative analysis. 

Review of Table 6-2 indicates that the prices obtained by the District for open 

burning and grinding for biomass are very similar to the estimates provided by 

the ag industry. In addition, since the pricing differential between grinding to 

biomass and open burning shown in Table 6-2 is generally greater when based 

on the quotations obtained by the District rather than on the information provided 

by the ag industry, the District’s cost effectiveness analysis will be performed 

based only on the quotations obtained by the District since this will provide the 

most conservative analysis with respect to industry’s concerns. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-6 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

6.2.2 Costs for Disposal of Orchard Prunings by Chipping 

Options for chipping and recycle of prunings consist of: 

1. Chipping prunings for conversion to biomass fuel

2. In-row chipping of prunings for on-site land incorporation 

The practice of chipping prunings for conversion to biomass fuel is less 

commonly practiced in comparison to in-row chipping for land incorporation and 

the pricing was found to be variable depending upon the business approach by 

the contractor. Information provided by an operator with smaller chipping 

equipment indicated that prunings could be chipped for biomass at a cost of $100 

per dry ton with a minimum job charge of $500. An operator with large grinding 

equipment indicated that under good conditions the cost could be $40 - $60 per 

ton with a minimum of $6,000 per day when grinding prunings for biomass. 

Costs for chipping prunings for land incorporation have been included in a 

number of recent studies by the University of California Cooperative Extension as 

presented in Table 6-3: 

Table 6-3 

Published Costs for In-Row Chipping of Prunings for Land Incorporation 

UC Report Title Date 

Cost per Acre to 

Shred Prunings 

NC-VS-09 

Sample Costs to Establish and 

Produce Nectarines 2009 $41 

OL-SV-09 Sample Costs to Produce Olives 2009 $10 

PH-VS-09 

Sample Costs to Establish and 

Produce Peaches 2009 $41 

WN-VN-07 

Sample Costs to Establish and 

Produce Walnuts 2007 $27 

AM-VS-08-1

Sample Costs to Establish and 

Produce Almonds 2007 $24 

In addition, a chipper operator was contacted to obtain a budgetary quotation. 

This contractor indicated an in-row chipping price of $26 per acre with a $500 

project minimum, regardless of tree type. An analysis provided by the farming 

industry indicated that the in-row chipping operation for almonds would cost $30-

$65 per acre depending upon the age of the trees. For purposes of this analysis 

and based on the information above, the District will assume that the prices for 

in-row chipping for land incorporation may vary from $30 to $60 per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-7 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

6.3 COST EFFECTIVENESS OF ALTERNATIVES TO OPEN BURNING 

6.3.1 Approach 

In general, the reduction of agricultural material from the pruning or the removal 

of orchards and vineyards by grinding or chipping followed by conversion to 

either biomass fuel or land incorporation results in fewer emissions when 

compared to open burning; however, these operations may incur extra costs over 

those associated with open burning. To examine the cost feasibility of these 

alternatives, cost effectiveness (CE) in dollars per ton of emission reduction is 

defined as the cost differential between chipping or grinding and open burning in 

dollars per acre divided by the difference between burning and chipping in per 

acre total emissions (PM2.5 + NOx + VOC), or: 

(($/acre)chip - ($/acre)burn)

CE =

(

(tonsemissions/acre)burn -(tonsemissions/acre)chip

)

The cost effectiveness calculated by the above expression will primarily be a 

function of the type of tree or plant (which determines the difficulty of removal 

and the amount and fuel quality of the material, affecting both the denominator 

and numerator of the above expression) and of the total acreage which affects 

the numerator of the above expression since operations on smaller acreages 

cost more per acre due to the project minimums imposed by most orchard 

contractors. 

6.3.2 Emissions Due To Open Burning 

Open Burning of Orchard Removals

Emissions of PM2.5, NOx and VOC from open burning operations have been 

estimated by the District based on the following: 

• Emissions estimates for orchard removals include: 

1. Highway vehicle emissions to deliver mobile equipment to the site 

2. Emissions from a dozer used to remove the trees or vines 

3. Emissions from a wheel loader used to stack trees or vines into piles 

for burning 

4. Tractor emissions for collection and stacking of roots for burning 

5. Emissions from open burning of trees, vines and roots 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-8 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Emission factors for open burning are taken from the District’s 2008 Area 

Sources Emission Inventory Methodology (revised 01Jun09) for orchard 

removals. Values are: 

PM2.5 7.3 lb/ton material burned 

NOx 5.2 lb/ton material burned 

VOC 5.2 lb/ton material burned 

• Highway vehicle emissions for delivery of equipment assumes two 100 

mile round-trips for a heavy haul truck to deliver a dozer and a wheel 

loader. 

• Dozer emissions are estimated based on a 300 hp Tier 2 diesel engine 

requiring one hour of operation for 70 tons for material. 

• Wheel loader emissions are estimated based on a 250 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

• Tractor emissions required for piling and burning of roots are estimated 

based on an 80 hp tier 2 diesel engine operating at a rate of one hour per 

acre. 

Open Burning of Orchard Prunings

Emissions of PM2.5, NOx and VOC from open burning operations have been 

estimated by the District based on the following: 

• Emissions estimates for orchard removals include: 

1. Highway vehicle emissions to deliver mobile equipment to the site 

2. Emissions from a wheel loader used to stack trees or vines into piles 

for burning 

3. Emissions from open burning of prunings 

• Emission factors for open burning are taken from the District’s 2008 Area 

Sources Emission Inventory Methodology (revised 01Jun09) for orchard 

removals. Values are: 

PM2.5 7.3 lb/ton material burned 

NOx 5.2 lb/ton material burned 

VOC 5.2 lb/ton material burned 

• Highway vehicle emissions for delivery of equipment assumes one 100 

mile round-trip for a heavy haul truck to deliver a wheel loader to the site. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-9 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Wheel loader emissions are estimated based on a 250 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

6.3.3 Emissions Due to Grinding and Conversion of Material to Biomass 

Fuel 

Grinding and Conversion of Material from Orchard Removals to Biomass Fuel

Emissions of PM2.5, NOx and VOC from grinding and conversion have been 

estimated by the District based on the following: 

• Emissions estimates for grinding and conversion of material to biomass 

fuel include: 

1. Highway vehicle emissions to deliver mobile equipment to the site, 

deliver ground material to the biomass plant and to deliver roots to a 

composting operation 

2. Emissions from an excavator or dozer used to remove the trees or 

vines 

3. Emissions from two wheel loaders used to stack trees, vines, and roots 

into piles for burning 

4. PM2.5 emissions from grinding of trees, vines and roots 

5. Engine emissions (PM2.5, NOx, and VOC) from the grinder 

6. Dozer operation at the biomass facility to receive and handle the fuel 

7. Power plant emissions due to fuel burning 

• The PM2.5 emission factor for grinding (0.05 lb per ton) was based on a 

review of existing District permits for grinding wood material and vineyard 

materials. A review of four existing permits indicated a range of 0.0088 

lb/ton to 0.08 lb/ton with an average of 0.03. 

• Emission factors for biomass power plant operation are based on reported 

operation for the Delano plant. Values are: 

PM2.5 0.86 lb/ton material burned 

NOx 1.92 lb/ton material burned 

VOC 0.38 lb/ton material burned 

• Highway vehicle emissions calculations assume four 100 mile round-trips 

for a heavy haul truck to deliver a tubgrinder, an excavator and two wheel 

loaders to the site, one (1) 100-mile round trip for every 24 tons of ground 

material for delivery to the biomass power plant, and one (1) 100-mile 

round trip for every 24 tons of roots for delivery to composting operation. 

• Excavator emissions for orchard removal are estimated based on a 240 

hp Tier 1 diesel engine requiring one hour of operation per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-10 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Wheel loader emissions associated with the grinding operation are 

estimated based on a 250 hp Tier 2 diesel engine operating at a rate of 

three hours per acre. 

• Tub grinder emissions are estimated based on a 1000 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

• Dozer emissions for receiving and handling material at the biomass power 

plant are estimated based on a 300 hp Tier 2 diesel engine requiring two 

hours of operation for 70 tons for material received. 

• Wheel loader emissions required for gathering and loading roots for 

transport to a composter are estimated based on a 250 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

Grinding and Conversion of Orchard Prunings to Biomass Fuel

Emissions of PM2.5, NOx and VOC from grinding and conversion have been 

estimated by the District based on the following: 

• Emissions estimates for grinding and conversion of material to biomass 

fuel include: 

1. Highway vehicle emissions to deliver mobile equipment to the site and 

deliver ground material to the biomass plant 

2. Emissions from one wheel loader used to handle prunings 

3. PM2.5 emissions from grinding of prunings 

4. Engine emissions (PM2.5, NOx, and VOC) from the grinder 

5. Dozer operation at the biomass facility to receive and handle the fuel 

6. Power plant emissions due to fuel burning 

• The PM2.5 emission factor for grinding (0.05 lb per ton) was based on a 

review of existing District permits for grinding wood material and vineyard 

materials. A review of four existing permits indicated a range of 0.0088 

lb/ton to 0.08 lb/ton with an average of 0.03. 

• Emission factors for biomass power plant operation are based on reported 

operation for the Delano plant. Values are: 

PM2.5 0.86 lb/ton material burned 

NOx 1.92 lb/ton material burned 

VOC 0.38 lb/ton material burned 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-11 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Highway vehicle emissions calculations assume two 100 mile round-trips 

for a heavy haul truck to deliver a grinder and a wheel loader to the site 

and one (1) 100-mile round trip for every 24 tons of ground material for 

delivery to the biomass power plant. 

• Wheel loader emissions associated with the grinding operation are 

estimated based on a 250 hp Tier 2 diesel engine operating at a rate of 

three hours per acre. 

• Grinder emissions are estimated based on a 100 hp Tier 2 diesel engine 

operating at a rate of one hour per acre. 

• Dozer emissions for receiving and handling material at the biomass power 

plant are estimated based on a 300 hp Tier 2 diesel engine requiring two 

hours of operation for 70 tons for material received. 

Chipping of Prunings for Land Incorporation

Emissions of PM2.5, NOx and VOC from grinding and conversion have been 

estimated by the District based on the following: 

• Emissions estimates for chipping of prunings for land incorporation 

include: 

1. Highway vehicle emissions to deliver mobile equipment to the site 

2. Emissions from a wheel loader used to handle the prunings 

3. PM2.5 emissions from grinding of prunings 

4. Engine emissions (PM2.5, NOx, and VOC) from the grinder 

• The PM2.5 emission factor for grinding (0.05 lb per ton) was based on a 

review of existing District permits for grinding wood material and vineyard 

materials. A review of four existing permits indicated a range of 0.0088 

lb/ton to 0.08 lb/ton with an average of 0.03. 

• Highway vehicle emissions calculations assume two 100 mile round-trips 

for a heavy haul truck to deliver a grinder or chipper and one wheel loader 

to the site. 

• Chipping or grinding emissions are estimated based on a 415 hp Tier 1 

diesel engine requiring one hour of operation per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-12 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Wheel loader emissions associated with the grinding operation are 

estimated based on a 250 hp Tier 2 diesel engine operating at a rate of 

one hour per acre. 

6.3.4 Per Acre Costs and Per Acre Emissions 

Table 6-4 presents the results of the District’s evaluation of emissions and per 

acre costs for converting orchard removal material to biomass fuel by grinding 

versus open burning for orchards other than citrus. Likewise, Table 6-5 presents 

the results of the District’s evaluation emissions and per acre costs for converting 

orchard removal material to biomass fuel by grinding versus open burning for 

citrus orchards. The tables present results for plot sizes between 1 and 20 acres, 

with the expected emissions and cost for burning per acre, expected emissions 

and cost for grinding per acre, differential emissions and differential cost per 

acre. The cost structure shown in the tables reflects a $5,000 minimum charge 

required for orchard removals by grinding to biomass and a minimum charge of 

$1,150 for orchard removal by open burning. The “per acre” charge indicated in 

Table 6-2 only becomes effective after the minimum project cost is exceeded. As 

a result, per-acre cost is generally higher for smaller acreages, trending to a 

lower fixed value for larger acreages as would be expected. Per acre emissions 

are also somewhat higher for smaller acreages primarily due to the emissions 

associated with mobilization of equipment at the site. 

Table 6-6 presents a similar analysis for vineyard removals with a pricing 

structure similar to Tables 6-4 and 6-5. As with orchards, per-acre costs and 

cost effectiveness value is generally higher for smaller acreages, trending to a 

lower fixed value for larger acreages. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010

 Revised July 21, 2010 

6-13 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

NO x PM 2.5 VOC NO x PM 2.5 VOC NO x PM 2.5 VOC

1 0.0945 0.1240 0.1075 $1,150 0.0575 0.0145 0.0065 $5,244 0.0370 0.1095 0.1010 $4,094

2 0.0925 0.1243 0.1073 $575 0.0503 0.0143 0.0065 $2,744 0.0422 0.1100 0.1008 $2,1693 0.0918 0.1242 0.1072 $383 0.0480 0.0142 0.0065 $1,911 0.0438 0.1100 0.1007 $1,5274 0.0915 0.1241 0.1073 $288 0.0468 0.0141 0.0065 $1,494 0.0447 0.1100 0.1008 $1,2075 0.0913 0.1242 0.1072 $267 0.0465 0.0141 0.0065 $1,244 0.0448 0.1101 0.1007 $977

6 0.0912 0.1242 0.1072 $267 0.0460 0.0141 0.0065 $1,077 0.0452 0.1101 0.1007 $8107 0.0911 0.1241 0.1072 $267 0.0459 0.0141 0.0065 $958 0.0452 0.1100 0.1007 $6918 0.0910 0.1242 0.1072 $267 0.0456 0.0141 0.0065 $869 0.0454 0.1101 0.1007 $6029 0.0909 0.1242 0.1072 $267 0.0456 0.0141 0.0065 $800 0.0453 0.1101 0.1007 $533

10 0.0909 0.1242 0.1072 $267 0.0453 0.0141 0.0065 $744 0.0456 0.1101 0.1007 $47712 0.0908 0.1242 0.1072 $267 0.0450 0.0140 0.0065 $661 0.0458 0.1102 0.1007 $39414 0.0908 0.1242 0.1072 $267 0.0450 0.0141 0.0065 $632 0.0458 0.1101 0.1007 $36515 0.0908 0.1242 0.1072 $267 0.0449 0.0141 0.0065 $632 0.0459 0.1101 0.1007 $36516 0.0908 0.1242 0.1072 $267 0.0448 0.0141 0.0065 $632 0.0460 0.1101 0.1007 $36518 0.0907 0.1242 0.1072 $267 0.0448 0.0141 0.0065 $632 0.0459 0.1101 0.1007 $36520 0.0907 0.1242 0.1072 $267 0.0447 0.0141 0.0065 $632 0.0460 0.1101 0.1007 $365

Basis:

30 BDT/acre for other orchard

4 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding caseGrind & haul cost includes $244 for root composting

Table 6-4 

Per Acre Emissions and Costs Using District Data 

Open Burning versus Grind and Haul for Orchards other than Citrus

Cost Basis: Chipper Contractor Quotations Jan 2010

Orchard 

Removal 

Size

Open Burning Grind & Haul Difference

Emissions 

Tons per Acre Cost $/acre

Emissions 

Tons per Acre Cost $/acre

Emissions Reduction 

Tons per Acre Cost $/acre
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-14 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

NO x PM 2.5 VOC NO x PM 2.5 VOC NO x PM 2.5 VOC

1 0.0945 0.1240 0.1075 $1,150 0.0575 0.0145 0.0065 $5,244 0.0370 0.1095 0.1010 $4,094

2 0.0925 0.1243 0.1073 $575 0.0503 0.0143 0.0065 $2,744 0.0422 0.1100 0.1008 $2,169

3 0.0918 0.1242 0.1072 $400 0.0480 0.0142 0.0065 $1,911 0.0438 0.1100 0.1007 $1,5114 0.0915 0.1241 0.1073 $400 0.0468 0.0141 0.0065 $1,494 0.0447 0.1100 0.1008 $1,0945 0.0913 0.1242 0.1072 $400 0.0465 0.0141 0.0065 $1,244 0.0448 0.1101 0.1007 $844

6 0.0912 0.1242 0.1072 $400 0.0460 0.0141 0.0065 $1,077 0.0452 0.1101 0.1007 $6777 0.0911 0.1241 0.1072 $400 0.0459 0.0141 0.0065 $958 0.0452 0.1100 0.1007 $5588 0.0910 0.1242 0.1072 $400 0.0456 0.0141 0.0065 $869 0.0454 0.1101 0.1007 $4699 0.0909 0.1242 0.1072 $400 0.0456 0.0141 0.0065 $800 0.0453 0.1101 0.1007 $400

10 0.0909 0.1242 0.1072 $400 0.0453 0.0141 0.0065 $769 0.0456 0.1101 0.1007 $36912 0.0908 0.1242 0.1072 $400 0.0450 0.0140 0.0065 $769 0.0458 0.1102 0.1007 $36914 0.0908 0.1242 0.1072 $400 0.0450 0.0141 0.0065 $769 0.0458 0.1101 0.1007 $36915 0.0908 0.1242 0.1072 $400 0.0449 0.0141 0.0065 $769 0.0459 0.1101 0.1007 $36916 0.0908 0.1242 0.1072 $400 0.0448 0.0141 0.0065 $769 0.0460 0.1101 0.1007 $36918 0.0907 0.1242 0.1072 $400 0.0448 0.0141 0.0065 $769 0.0459 0.1101 0.1007 $36920 0.0907 0.1242 0.1072 $400 0.0447 0.0141 0.0065 $769 0.0460 0.1101 0.1007 $369

Basis:

30 BDT/acre for citrus4 BDT/acre for rootsRoots are burned in burning case

Roots are transported to composting operation for grinding caseGrind & haul cost includes $244 for root composting

Difference

Emissions 

Tons per Acre

Open Burning

Cost 

$/acre

Table 6-5 

Per Acre Emissions and Costs Using District Data 

Open Burning versus Grind and Haul for Citrus

Cost Basis: Chipper Contractor Quotations Jan 2010

Emissions 

Tons per Acre

Orchard 

Removal 

Size

Cost 

$/acre

Grind & Haul

Emissions Reduction 

Tons per Acre Cost $/acre
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-15 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

NOx PM 2.5 VOC NO x PM2.5 VOC NOx PM2.5 VOC

1 0.0210 0.0220 0.0190 $1,150 0.0305 0.0030 0.0020 $5,725 0.0000 0.0190 0.0170 $4,575

2 0.0193 0.0220 0.0190 $575 0.0233 0.0028 0.0018 $3,225 0.0000 0.0192 0.0172 $2,6503 0.0185 0.0220 0.0190 $383 0.0210 0.0027 0.0017 $2,392 0.0000 0.0193 0.0173 $2,0084 0.0183 0.0220 0.0190 $288 0.0199 0.0026 0.0016 $1,975 0.0000 0.0194 0.0174 $1,6885 0.0180 0.0220 0.0190 $230 0.0195 0.0026 0.0016 $1,725 0.0000 0.0194 0.0174 $1,4956 0.0179 0.0220 0.0190 $213 0.0190 0.0026 0.0016 $1,558 0.0000 0.0194 0.0174 $1,3457 0.0176 0.0219 0.0190 $213 0.0186 0.0026 0.0016 $1,439 0.0000 0.0193 0.0174 $1,2268 0.0178 0.0219 0.0189 $213 0.0183 0.0026 0.0016 $1,350 0.0000 0.0193 0.0173 $1,1379 0.0177 0.0219 0.0189 $213 0.0181 0.0026 0.0016 $1,281 0.0000 0.0193 0.0173 $1,068

10 0.0177 0.0220 0.0190 $213 0.0182 0.0026 0.0016 $1,225 0.0000 0.0194 0.0174 $1,01212 0.0176 0.0220 0.0190 $213 0.0178 0.0026 0.0016 $1,142 0.0000 0.0194 0.0174 $929

14 0.0175 0.0220 0.0190 $213 0.0176 0.0026 0.0016 $1,082 0.0000 0.0194 0.0174 $86915 0.0175 0.0220 0.0190 $213 0.0176 0.0026 0.0016 $1,058 0.0000 0.0194 0.0174 $84516 0.0175 0.0219 0.0190 $213 0.0176 0.0026 0.0016 $1,038 0.0000 0.0193 0.0174 $82518 0.0175 0.0219 0.0189 $213 0.0175 0.0026 0.0016 $1,003 0.0000 0.0193 0.0173 $79020 0.0175 0.0220 0.0190 $213 0.0175 0.0026 0.0016 $975 0.0000 0.0194 0.0174 $762

* Grind and haul cost includes $650 per acre for removal of wire and stakes

$75 per acre for composting roots

Basis

5 BDT/acre for Vineyard1 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding case

Grind & Haul

Emissions Reduction 

Tons per Acre Cost $/acre

Difference

Table 6-6 

Per Acre Emissions and Costs Using District Data 

Open Burning versus Grind and Haul for Vineyards/Kiwis

Cost Basis: Chipper Contractor Quotations Jan 2010

Emissions 

Tons per Acre

Open Burning

Cost 

$/acre

Emissions 

Tons per Acre

Orchard 

Remova

l Size

Cost* 

$/acre
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

 

6-16 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Prunings

For the alternative of grinding orchard prunings for conversion to biomass fuel, the 

District evaluated the emissions as follows based on one (1) bone-dry ton per acre 

of prunings and a 20 acre orchard plot size: 

Table 6-7 

Emissions Comparison 

Open Burning versus Grinding for Biomass Fuel 

Burn - lbs/acre Grind/Biomass - 

lb/acre 

Emission Reduction for 

Tons Chipping - lb/acre 

per 

acre 

Acres

PM2.5 NOx VOC PM2.5 NOx VOC PM2.5 NOx VOC 

1 20 7.9 7.7 6.4 1.1 7.6 0.6 6.8 0.1 5.8 

For the alternative of chipping orchard prunings for land incorporation, emissions 

estimates are as follows based on one (1) bone dry ton of prunings per acre: 

Table 6-8 

Emissions Comparison 

Open Burning versus Shredding for Land Incorporation 

Burn - lbs/acre Chip/Land 

Incorporate lb/acre 

Emission Reduction for 

Tons Chipping - lb/acre 

per 

acre 

Acres

PM2.5 NOx VOC PM2.5 NOx VOC PM2.5 NOx VOC 

1 20 7.9 7.7 6.4 0.2 6.2 0.4 7.7 1.5 6.0 

Per the above tables, shredding the pruning materials provides the greatest reduction in 

emissions relative to open burning. Based on the greater emission reductions and 

reliability of cost data, the District will base further analysis only on the alternative method 

of shredding the materials in place. As previously mentioned, shredding operations may 

vary between $30 and $60 per acre depending on the availability of custom shredder and 

the amount of pruning material, while burning costs $22 per acre. District staff has used 

the higher costs of shredding as a conservative estimate and determined the incremental 

cost of shredding to be $38 per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

 

6-17 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

6.4 ADDITIONAL IMPACTS (COST AND AVAILABILITY) OF NEW ARB 

REGULATIONS ON TRUCKS AND EQUIPMENT 

Agricultural representatives note that the costs for the upcoming off-road equipment 

(Tier 3), which needs to be replaced by 2012, need to be considered. The factors in the 

previous rulemaking analysis did not include trucks, Heavy Duty Rules, and AB32 (new 

colors on tractors, turning off AC units). It has been suggested that District staff analyze 

what has changed for the line items for ‘20 acres or less’ in the 2007 analysis. 

Agricultural representatives do not believe there has been any decrease in costs and 

that the new costs will increase for chippers because of the equipment replacements. 

The additional components of the “Off-Road” rule and the amount ($26/ton instead of 

$28/ton) the biomass power plants are now paying for the material could also impact the 

cost analysis. The District’s costs analysis above are based on the most current and 

best available information from the chipping operator and agricultural industry. District 

staff will reevaluate any significant impact to the industry as necessary. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

 

6-18 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

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