SAN JOAQUIN VALLEY UNIFIED 

AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT AND 

RECOMMENDATIONS ON AGRICULTURAL BURNING 

May 20, 2010 

(Revised July 21, 2010) 

Prepared by: 

Koshoua Thao, Senior Air Quality Specialist 

Anna Myers, Air Quality Specialist 

Dennis Roberts, Senior Air Quality Engineer 

David Nunes, Senior Air Quality Specialist 

Joven R. Nazareno, Senior Air Quality Engineer 

David Garner, Senior Air Quality Specialist 

Yu Vu, Air Quality Specialist 

Dr. David Lighthall, Health Science Advisor 

Nichole Corless, Air Quality Specialist 

Reviewed By: 

Daniel Martinez, Supervising Air Quality Inspector 

Leland Villalvazo, Supervising Air Quality Specialist 

George Heinen, Rule Development Supervisor 

Scott Nester, Senior Project Manager 

Errol Villegas, Planning Manager 

Morgan Lambert, Director of Compliance 

Samir Sheikh, Director of Strategy and Incentives 

Rick McVaigh, Deputy APCO 
ACKNOWLEDGMENTS

The District would like to take the opportunity to acknowledge those individuals 

and associations who assisted the District throughout the process of compiling 

this report. We thank you for your efforts, your open communication, your 

willingness to share data, and for working collaboratively with us in carrying out 

the District’s mission. 

Agricultural Industry Representatives 

Applied Development Economics 

Biomass Industry Representatives 

California Air Resources Board 

Chipping and Shredding Operators/Vendors 

County Ag Commisioners 

County Farm Bureau 

Environmental Protection Agency 

Other SJVAB Agencies and Districts 

Other SJVAB Growers 

May 20, 2010 

(Revised July 21, 2010) 

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

 Revised July 21, 2010 

i Table of Contents 

 Final Staff Report and 

Recommendations On Agricultural Burning 

Table of Contents 

Executive Summary 

 State Law Requirements 

Summary of Proposed Recommendations Contained in this Report 

Summary of Methodology for Determining Proposed Recommendations 

Governing Board Approval of this Report Satisfies the Determinations 

Required by State Law 

Chapter 1 Background 

1.1 Reasons for this Report 

1.1.1 State Law Requires Determinations by the District, 

with Concurrence by ARB 

1.1.2 Description of Affected Categories 

1.2 Overview of the Methodology for Alternatives to Open Burning 

for Making the Determinations 

1.2.1 Is There a Technologically Feasible Non-Burning 

Alternative for Disposing of the Specific Crop Type? 

1.2.2 Does the Cost Analysis Show an Economically 

Feasible Non-Burn Alternative? 

1.2.3 Do Biomass Power Plants or Other Facilities in the 

Valley Have Capacity? 

1.2.4 Does ARB Concur With the Analysis? 

1.3 Process and Schedule for 2010 Determinations 

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

2.1 Current District Rule 

2.2 CH&SC Burning Prohibitions 

Chapter 3 Technical and Economic Analysis of Affected Crop Categories 

and Recommendations 

3.1 Vineyard Removal Materials 

3.2 Orchard Removal Matter From Citrus, Apple, Pear, Quince and 

Fig Crops and Orchard Removal Matter from a Total of 20 

Acres or Less 

3.2.1 Orchard Removal Matter from a Total of 20 Acres or 

Less 

3.2.2 Fig Crops Orchard Removal Matter 

3.2.3 Citrus Crops Orchard Removal Matter 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

ii Table of Contents 

 Final Staff Report and 

Recommendations On Agricultural Burning 

3.2.4 Apple, Pear, and Quince Orchard Removal Matter 

3.3 Weed Abatement Activities Affecting Surface Waterways, 

Including Ponding and Levee Banks 

3.4 Other Materials 

3.4.1 Brooder Paper 

3.4.2 Deceased Goats 

3.4.3 Diseased Bee Hives 

3.5 Rice Stubble (Straw) 

3.6 Prunings From Apple, Pear, Quince, and Fig Crops 

3.6.1 Prunings from Apple, Pear and Quince Crops 

3.6.2 Prunings from Fig Crops 

3.7 Surface Harvested Prunings 

3.7.1 Prunings from Grape Vines and Grape Canes 

3.7.2 Raisin Tray 

3.7.3 Almond, Walnut, and Pecan Prunings 

 

Chapter 4 Technological Feasibility of Alternatives to Burning 

4.1 Vegetative and Related Material 

4.1.1 Biomass Power Plants 

4.1.2 Land Application / Soil Incorporation 

4.1.3 Anaerobic Digestion 

4.1.4 Composting 

4.1.5 Landfill 

4.1.6 Cellulosic Ethanol Production 

4.1.7 Gasification for Liquid Fuel 

4.1.8 Pyrolysis 

4.1.9 Mulch 

4.1.10 Hand Crews for Removal of Materials 

4.1.11 Overseas Shipment of Raisin Trays 

4.1.12 Water Decomposition for Rice Stubble (Straw) 

4.1.13 Baling Rice Stubble (Straw) 

4.2 Animal-Related Material 

4.2.1 Burial 

4.2.2 Incineration 

4.2.3 Rendering 

4.2.4 Sterilization 

Chapter 5 Emissions From Agricultural Burning and Alternatives to 

Burning and Health Considerations 

5.1 Distribution of Agricultural Open Burning Emissions 

5.2 Current Emissions Inventory from Agricultural Burning 

5.3 Expected Emissions From Alternatives 

5.4 Emission Reduction Analysis 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

iii Table of Contents 

 Final Staff Report and 

Recommendations On Agricultural Burning 

5.4.1 Introduction 

5.4.2 Methodology and Calculations 

5.5 Health Benefits from Reduced Open Burning 

5.6 Health Risk Assessment of Open Burning and Alternatives 

5.6.1 Methodology and Calculations 

5.6.2 Health Risk Assessment Results 

Chapter 6 Cost Impacts of Alternatives to Burning 

6.1 Costs for Open Burning 

6.1.1 Costs for Orchard and Vineyard Removal by Open 

Burning 

6.1.2 Costs for Disposal of Orchard Prunings by Open 

Burning 

6.2 Costs of Alternatives to Burning 

6.2.1 Costs for Orchard and Vineyard Removal for fuel at 

Biomass Power Plants 

6.2.2 Costs for Disposal of Orchard Prunings by Chipping 

6.3 Cost Effectiveness of Alternatives to Open Burning 

6.3.1 Approach 

6.3.2 Emissions Due to Open Burning 

6.3.3 Emissions Due to Grinding and Conversion of 

Material to Biomass Fuel 

6.3.4 Per Acre Costs and Per Acre Emissions 

6.4 Additional Impacts of New ARB Regulations on Trucks and 

Equipment 

Chapter 7 Biomass Power Plants 

7.1 Current Biomass Power Plants 

7.1.1 Locations 

7.1.2 Fuel Use and Storage Capacities 

7.1.3 Historical Fuel Usage 

7.1.4 Emissions and Emission Controls 

7.1.5 Economics-Agricultural Fuel Vs. Urban Fuel 

7.2 Outlook 

7.2.1 How Much More Agricultural Material Do We 

Anticipate? 

7.2.2 Could the Current Biomass Facilities Physically 

Handle the Increase in Materials? 

7.2.3 Policies for Renewable Energy 

7.2.4 Contracts with Utilities 

7.2.5 Legislative Platform 

7.2.6 New Facilities 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

iv Table of Contents 

 Final Staff Report and 

Recommendations On Agricultural Burning 

7.3 State and Federal Commitments for Continued Operation 

7.3.1 Renewable Electricity Production Tax Credit 

7.3.2 Existing Renewables Facilities Program 

7.3.3 Biomass-to-Energy Incentive Grant Program 

7.4 Discussion 

Chapter 8 Air Quality Impacts of Continued Open Burning and 

Alternatives 

8.1 Smoke Management System 

8.2 2007 Ozone Plan 

8.3 2008 PM2.5 Plan 

8.3.1 Annual PM2.5 Standard 

8.3.2 24-Hour PM2.5 Standard 

8.4 Open Burning Emissions Inventory 

Chapter 9 Determinations Required by State Law 

9.1 Economic Feasibility 

9.2 Federal and State Commitments for Biomass Facilities 

9.3 Air Quality Impacts 

9.4 ARB Concurrence 

Chapter 10 References
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

v Table of Contents 

 Final Staff Report and 

Recommendations On Agricultural Burning 

Appendices

Appendix A: Amended Rule 4103 

Appendix B: Table of Crop Categories 

Appendix C: Initial Study and Negative Declaration 

Appendix D: Summary of Significant Comments and District Responses 

Appendix E: Economic Feasibility Analysis Methodology 

Appendix F: Summarized Information from CH&SC Section 41855.5 

Category Definitions List 

Open Burn Prohibition Schedule 

Appendix G: Cost Effectiveness Analysis 

Appendix H: Ag Burn Information Provided by the Agricultural Industry 

Wine Grapes

Table Grapes

Raisin Grapes

Citrus

Nut Crops

Diseased Crops

Raisin Trays 

Porter-Cologne Water Quality Control Act 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

vi Table of Contents 

 Final Staff Report and 

Recommendations On Agricultural Burning 

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