1

ANNUAL REPORT ON

VOLATILE ORGANIC COMPOUND EMISSIONS 

FROM PESTICIDES: EMISSIONS FOR 1990 – 2010

Rosemary Neal, Ph.D. 

Staff Environmental Scientist

Frank Spurlock, Ph. D 

Research Scientist III

and 

Randy Segawa

Environmental Program Manager I

March 2012 

California Environmental Protection Agency 

Department of Pesticide Regulation 

Environmental Monitoring Branch 

P.O. Box 4015 

Sacramento, California 95812-4015 

(916) 324-4039 

AIR2012-1
2

EXECUTIVE SUMMARY

Preface

This report fulfills the requirements of Title 3, California Code of Regulations (3 CCR), section 

6452.4 which requires the Director of Department of Pesticide Regulation (DPR) to issue an 

annual emissions inventory report for the Sacramento Metro, San Joaquin Valley, South Coast, 

Southeast Desert, and Ventura ozone nonattainment areas (NAAs). This report presents data 

reported to or produced by DPR from May 1, 2010, to October 31, 2010, the peak ozone season 

in California. In addition, data from the same months in 1990 are included for baseline 

comparisons, and from 2007, 2008 and 2009 for trend analysis. 

Background 

Under the federal Clean Air Act, California must meet national standards for airborne 

pollutants and must specify how it plans to achieve these goals in a federally approved State 

Implementation Plan (SIP). Five regions in California – the Sacramento Metro area, the San 

Joaquin Valley, the Southeast Desert region, Ventura County and the South Coast area - exceed 

federal ozone standards and are therefore designated NAAs. SIPs require the control of 

emissions of nitrogen oxides and volatile organic compounds (VOCs) because they are 

precursors to ozone. Under California’s SIP, approved by the U.S. Environmental Protection 

Agency (U.S. EPA) in 1997, DPR must track and control VOC emissions from pesticide 

products used in agriculture and by commercial structural applicators in these five NAAs. 

Under the SIP, California is expected to reduce pesticide VOCs by 12 percent in the San 

Joaquin Valley and 20 percent in the other four NAAs, compared to 1990 levels. 

DPR’s VOC emission inventory database includes only pesticide applications that are made 

between May 1 and October 31, the peak ozone season in California. The database is updated 

when annual pesticide use report data from the previous year becomes available, and contains 

data for every year since 1990. Each year contains about 2.5 million pesticide use records 

(PUR) and emission potential (EP) values for approximately 5,000 products. The EP is that 

fraction of a product that is assumed to contribute to atmospheric VOCs. 

Beginning in 2008 DPR adopted regulations to reduce VOC emissions from fumigant 

pesticides. Section 6452.2, 3 CCR, includes specific emission target levels (VOC regulation 

benchmarks) for each of the five NAAs, equivalent to the SIP obligation of a 12 percent or 20 

percent reduction. The regulations reduce VOC emissions by requiring low-emission 

fumigation methods in certain NAAs. In all NAAs but Ventura, if, in spite of these application 

method requirements, pesticide VOC emissions exceed 95 percent of the benchmark for a 

NAA, DPR will, as specified by the regulations, ensure that the benchmark is achieved by 

establishing a fumigant limit. A fumigant limit is required at least through 2012 in Ventura. 

The fumigant limit is determined by subtracting the estimated nonfumigant emissions from the 

regulatory benchmark, basing the nonfumigant emissions estimate on VOC emission inventory 

data from previous years. 
3

Report Summary

VOC emissions in all five nonattainment areas increased in 2010, but in compliance with the 

SIP goals and below the VOC regulation benchmarks. 

• Sacramento Metro NAA: VOC emissions decreased between 2006 and 2008, increased by 

less than one percent in 2009 and a further 12 percent in 2010. Pesticide VOC emissions in 

2010 were 62 percent lower than the 1990 base year and remain well in compliance with 

the SIP goal and the VOC regulation benchmark. In 2010, 91 percent of emissions were 

derived from nonfumigants.

• San Joaquin Valley NAA: VOC emissions decreased between 2006 and 2009 and then 

increased by approximately 25 percent in 2010. Pesticide VOC emissions in 2010 were 18 

percent lower than the 1990 base year and comply with the SIP goal and VOC regulation 

benchmark. Three-quarters of pesticide emissions are derived from nonfumigants.

• Southeast Desert NAA: VOC emissions increased from 2006 to 2007, but then decreased in 

2008 and 2009. There was an increase of more than twice the amount of pesticide VOC 

emissions from 2009 to 2010, but emissions in 2010 were 60 percent lower than the 1990 

base year and comply with the SIP goal and VOC regulation benchmark. Emissions from 

fumigants account for more than one half of the total.

• Ventura NAA: The SIP goal and VOC regulation benchmark is phased in over several years 

for this NAA. VOC emissions increased in 2010 but continue to meet the SIP goal for 2010 

as well as the final goal to be met beginning in 2012. Pesticide VOC emissions in 2010 

were 31 percent lower than the 1990 base year. Eighty-two percent (82%) of emissions are 

derived from fumigants. 

• South Coast NAA: VOC emissions increased in 2010 by more than 40 percent compared to 

2009 but remain well below the emission targets. Pesticide VOC emissions in 2010 were 84 

percent lower than the 1990 base year. More than three quarters of emissions are derived 

from nonfumigants 

Section 6452.3 requires a 45-day public comment period of the draft report. Comments that 

were received during the comment period (November 17, 2011 – January 3, 2012) are included 

in Appendix 4.
4

Abbreviations and Definitions

AI Active Ingredient

APCD Air Pollution Control District

AMAF Application Method Adjustment Factor

ARB California Air Resources Board

EP Emission Potential

GIS Geographic Information System

MUF Method Use Fraction

NAA nonattainment area

PUR pesticide use report

SIP state implementation plan

TGA thermogravimetric analysis

tpd tons per day

VOC Volatile Organic Chemical

ACKNOWLEDGEMENTS

The authors wish to thank the reviewers whose unique perspectives and experiences helped 

ensure the accuracy and readability of this report. We gratefully acknowledge the staff of DPR 

and cooperating federal, state, local, and private agencies for contributing to the database.

DISCLAIMER

The mention of commercial products, their source, or their use in this report is not to be 

construed as either an actual or implied endorsement of such product. 
5

TABLE OF CONTENTS

EXECUTIVE SUMMARY

Preface..................................................................................... 2

Background............................................................................... 2

Report Summary......................................................................... 3

Abbreviations and Definitions......................................................... 4

ACKNOWLEDGEMENTS................................................................... 4

DISCLAIMER................................................................................... 4

LIST OF TABLES.............................................................................. 6

LIST OF FIGURES............................................................................. 8

OVERVIEW

Introduction............................................................................... 9

Nonattainment Area Goals.............................................................. 12

Procedure For Calculating Unadjusted and Adjusted VOC Emissions........... 12

Data Revisions............................................................................ 14

VOLATILE ORGANIC COMPOUND INVENTORY RESULTS................... 16

Sacramento Metro Area - NAA 1...................................................... 23

San Joaquin Valley - NAA 2........................................................... 27

Southeast Desert - NAA 3.............................................................. 31

Ventura - NAA 4........................................................................ 35

South Coast - NAA 5.................................................................. 39

PROJECTION OF 2012 VOC EMISSIONS AND FUMIGANT LIMITS......... 43

REFERENCES................................................................................... 45

APPENDIX 1 

a. SUMMARY OF APPLICATION METHOD ADJUSTMENT FACTORS 

AND METHOD USE FRACTIONS

b. FIELD FUMIGATION METHODS (FFM), FFM CODE FOR PESTICIDE 

USE REPORTING, AND EMISSION RATINGS

APPENDIX 2 – SUMMARY OF UNADJUSTED PESTICIDE VOC EMISSIONS

APPENDIX 3 – SUMMARY OF ADJUSTED PESTICIDE VOC EMISSIONS

APPENDIX 4 – COMMENTS ON THE DRAFT REPORT AND RESPONSES
6

LIST OF TABLES

Table 1. Key information included in pesticide use reports that form the basis of 

DPR’s VOC emission inventory.................................................... 10

Table 2. A listing of counties wholly or partially within nonattainment areas in 

California.............................................................................. 12

Table 3. Nonattainment Area Goals for 2008 – 2012.................................... 12

Table 4. Revised application method adjustment factors Iemission ratings)......... 15

Table 5. May–October (ozone season) unadjusted and adjusted pesticide VOC 

emissions and goals.................................................................. 19

Table 6a. May–October (ozone season) adjusted fumigant and nonfumigant

pesticide VOC emissions............................................................ 19

Table 6b. May–October (ozone season) unadjusted fumigant and nonfumigant

pesticide VOC emissions............................................................ 20

Table 6c. May-October (ozone season) nonfumigant pesticide VOC emissions 

derived from Emulsifiable Concentrate formulations (ECs) and all 

Others................................................................................... 21

Table 7. Top ten primary active ingredients contributing to 2010 May-October 

ozone season adjusted VOC emissions in NAA 1, the Sacramento Metro

Area..................................................................... 24

Table 8. Top ten pesticide application sites contributing to 2010 May-October 

ozone season unadjusted VOC emissions in NAA 1............................. 25

Table 9. Unadjusted 2010 May–October VOC emissions in NAA1 by ARB 

emission inventory classification (tons per day, tpd)............................. 26

Table 10. Top ten primary active ingredients contributing to 2010 May-October 

ozone season adjusted VOC emissions in NAA 2, the San Joaquin Valley... 28

Table 11. Top ten pesticide application sites contributing to 2010 May-October 

ozone season unadjusted VOC emissions in NAA 2............................. 29

Table 12. Unadjusted 2010 May–October VOC emissions in NAA 2 by ARB 

emission inventory classification (tons per day, tpd)............................ 30

Table 13. Top ten primary active ingredients contributing to 2010 May-October 

ozone season adjusted VOC emissions in NAA 3, the Southeast Desert...... 32

Table 14. Top ten pesticide application sites contributing to 2010 May-October 

ozone season unadjusted VOC emissions in NAA 3............................. 33

Table 15. Unadjusted 2010 May–October VOC emissions in NAA 3 by ARB 

emission inventory classification (tons per day, tpd)............................. 34

Table 16. Top ten primary active ingredients contributing to 2010 May-October 

ozone season adjusted VOC emissions in NAA 4, Ventura..................... 36

Table 17. Top ten pesticide application sites contributing to 2010 May-October 

ozone season unadjusted VOC emissions in NAA 4............................. 37

Table 18. Unadjusted 2010 May–October VOC emissions in NAA 4 by ARB 

emission inventory classification (tons per day, tpd)............................. 38

Table 19. Top ten primary active ingredients contributing to 2010 May-October 

ozone season adjusted VOC emissions in NAA 5, South Coast............... 40

Table 20. Top ten pesticide application sites contributing to 2010 May-October 

ozone season unadjusted VOC emissions in NAA 5............................. 41
7

Table 21. Unadjusted 2010 May–October VOC emissions in NAA 5 by ARB 

emission inventory classification (tons per day, tpd)............................. 42

Table 22. Fumigant limit triggers and 2010 pesticide VOC 

emissions.............................................................................. 43

Table 23. May–October (ozone season) nonfumigant pesticide VOC emissions... 44

Table 24. Projection for 2012 NAA 4 VOC emissions. The 2012 fumigant 

emission limit was determined by subtracting the forecast 2012 

nonfumigant emissions from the SIP goal and VOC regulation benchmark 

(Tao, 2011)............................................................................ 44
8

LIST OF FIGURES

Figure 1. Federal nonattainment areas affected by California Regulations to 

reduce emissions from fumigant pesticides....................................... 11

Figure 2. Annual unadjusted ozone season pesticide VOC emissions by NAA 

from 1990 to 2010, inclusive........................................................ 18

Figure 3. Annual ozone season pesticide VOC emissions by NAA. These figures 

show adjusted emissions and SIP goals (reductions from 1990 emissions)... 22

Figure 4. Pesticide VOC emissions for the Sacramento Metro NAA, May–

October................................................................................ 24

Figure 5. Changes in adjusted emissions of selected AIs in the Sacramento Metro 

NAA from 2007 to 2010............................................................. 25

Figure 6. Changes in unadjusted emissions from selected commodities/sites in the 

Sacramento Metro NAA from 2007 to 2010...................................... 26

Figure 7. Pesticide VOC emissions for the San Joaquin Valley NAA, May–

October................................................................................. 28

Figure 8. Changes in adjusted emissions of selected AIs in the San Joaquin Valley 

NAA from 2007 to 2010............................................................. 29

Figure 9. Changes in unadjusted emissions from selected commodities/sites in the 

San Joaquin Valley NAA from 2007 to 2010..................................... 30

Figure 10. Pesticide VOC emissions for the Southeast Desert NAA, May–

October............................................................................... 32

Figure 11. Changes in adjusted emissions of selected AIs in the Southeast Desert 

NAA from 2007 to 2010............................................................. 33

Figure 12. Changes in unadjusted emissions from selected commodities/sites in 

the Southeast Desert NAA from 2007 to 2010.................................... 34

Figure 13. Pesticide VOC emissions for the Ventura NAA, May–October........... 36

Figure 14. Changes in adjusted emissions of selected AIs in the Ventura NAA 

from 2007 to 2010..................................................................... 37

Figure 15. Changes in unadjusted emissions from selected commodities/sites in 

the Ventura NAA from 2007 to 2010.............................................. 38

Figure 16. Pesticide VOC emissions for the South Coast NAA, May–

October................................................................................. 40

Figure 17. Changes in adjusted emissions of selected AIs in the South Coast NAA 

from 2007 to 2010..................................................................... 41

Figure 18. Changes in unadjusted emissions from selected commodities/sites in 

the South Coast NAA from 2007 to 2010.......................................... 42
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OVERVIEW

Introduction

The State Implementation Plan (SIP) for pesticides requires the California Department of 

Pesticide Regulation (DPR) to develop and maintain an emission inventory to track pesticide 

Volatile Organic Chemical (VOC) emissions and to reduce emissions by 20 percent from a 

base year in four out of five California nonattainment areas (NAA), and by 12 percent in the 

fifth NAA. These five NAAs are defined as areas that do not meet the National Ambient Air 

Quality Standards for ozone as designated in the Clean Air Act. The scope of the VOC 

inventory allows DPR to estimate VOC emissions from agricultural and commercial structural 

pesticide applications within the state. To do this DPR calculates emissions for each year 

beginning with 1990, and updates these calculations annually based on most recent data. The 

inventory focuses on the peak ozone period between May 1 and October 31 for each year. 

The VOC emission inventory is estimated based on pesticide use reports (PURs) that are 

collected by DPR. The inventory includes applications that are made for agricultural and 

structural use as defined by law. Included are all applications with the exception of home use, 

industrial use, institutional use, applications made for vector control purposes and veterinarian 

uses. Production agricultural use covers applications to approximately 400 commodities/crops. 

Non-production agricultural use includes applications to approximately 20 sites including 

cemeteries, golf courses, parks, rights of way, etc. Structural use includes all applications by 

structural pest control businesses, regardless of site treated. 

The key pesticide use report data used to calculate VOC emissions is given in Table 1. There 

are seven counties that are partially within NAAs. Because the locations of non-production 

agricultural and non-agricultural applications are only given down to the county level, these 

types of applications need to be allocated to the portions of those seven counties so that their 

contribution to NAA emissions can be accurately determined. Using a Geographic Information 

System (GIS) and surrogate data such as population, roadways, waterways and power lines, 

proportional estimates have been derived for structural and rights-of-way applications. 

Commodity fumigations are allocated based on information provided by the California County 

Agricultural Commissioners.
10

Table 1. Key information included in pesticide use reports that form the basis of DPR’s VOC 

emission inventory. 

Information Production Agriculture 

Report

(Each Application)

Non-Production Agriculture 

Report and Non Agricultural 

Reports

(Monthly Summary of Applications)

Product Applied Yes Yes

Crop/Site Treated Yes Yes

Amount Applied Yes – each application Monthly Total

Date Applied Date and Time Month

Application Method Yes No

Acres/Units Treated Yes Monthly Total

Location of Application Township/Range/Section County

Fumigant Method Code Yes* No

* fumigant use reports only

California’s five ozone NAAs included in the pesticide VOC emission inventory are 

Sacramento Metro (1), San Joaquin Valley (2), Southeast Desert (3), Ventura (4), and South 

Coast (5). The boundaries of these NAAs, as defined by CFR 40 Part 81 and a listing of 

counties that fall within the boundaries are shown in Figure 1 and Table 2, respectively. 

In January 2008, DPR adopted 3 CCR section 6452.3 requiring an annual VOC emissions 

inventory report that includes the following information: 

• report total agricultural and structural pesticide VOC emissions for the previous years, 

• evaluate compliance with SIP goals (benchmarks specified in section 6452.2), 

• establish fumigant emission limits for the upcoming year if necessary, according to 

section 6452.2, and 

• establish an emission rating (or application method adjustment factor, the percentage of 

fumigant applied emitted to air) for each fumigation method

Section 6452.3 also requires a 45-day public comment period of the draft report. This report 

contains all of the information specified above, including emission estimates for 1990–2010 

and fumigant limits for 2012. 
11

Figure 1. Federal nonattainment areas affected by California Regulations to reduce emissions 

from fumigant pesticides. 
12

Table 2. A listing of counties wholly or partially within nonattainment areas in California.

NAA Counties within the NAA

1 – Sacramento Metro All of Sacramento, Yolo 

Parts of Sutter, Solano, Placer, El Dorado

2 – San Joaquin Valley All of Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus, Tulare 

Western Part of Kern

3 – Southeast Desert Parts of Los Angeles, San Bernardino, Riverside

4 – Ventura All of Ventura

5 – South Coast All of Orange

Western Parts of Los Angeles, San Bernardino, Riverside

Nonattainment Area Goals

The emissions in DPR’s VOC inventory are compared to NAA goals listed in Table 3, which 

are described in California’s original 1994 SIP (62 Fed. Reg. at 1170, 1997) and Appendix H to 

the 2007 SIP (73 Fed. Reg. 41277, 2008). These “SIP goals” are a 20 percent reduction from 

1990 for the Sacramento Metro, Southeast Desert, and South Coast NAAs; a 12 percent 

reduction from 1990 for the San Joaquin Valley NAA; and a phase-in of the reductions for the 

Ventura NAA, with a final reduction for Ventura of 20 percent from 1990 by 2012. 

Table 3. Nonattainment Area Goals for 2008 – 2012. 

NAA

SIP Goal

(tons/day)

2008 - 2012

1 – Sacramento Metro 2.2

2 – San Joaquin Valley 18.1

3 – Southeast Desert 0.92

4 – Ventura 2008 2009 2010 2011 2012

4.3 4.0 3.6 3.3 3.0

5 – South Coast 8.7

Procedure for Calculating Unadjusted and Adjusted VOC Emissions

Prior to 2008, DPR reported an unadjusted emission inventory that assumed the entire volatile 

portion of a fumigant product eventually volatilizes, contributing to atmospheric VOC 

loadings. However, several dozen field studies have shown that actual emissions from soilapplied fumigants such as methyl bromide vary by application method and are generally less 

than 100 percent. DPR has developed an adjustment procedure to account for the effect of 

application method on reducing fumigant VOC emissions. 
13

The unadjusted inventory is based on the premise that the VOC emission from a single

application of fumigant or nonfumigant product is equal to the amount used times the Emission 

Potential (EP) (Spurlock, 2002; 2006). 

 emission = lbs of product used x EP 

In the adjusted inventory the emission from a single application of a fumigant active ingredient 

(AI) is reduced by an additional factor called the Application Method Adjustment Factor 

(AMAF), also referred to as the emission rating. AMAFs have been determined from field 

study data and are AI and application method specific (Barry et al., 2007). Since the AMAFs 

are based on field measured data for specific application methods and fumigants, they yield 

more refined estimates of fumigant VOC emissions than the previous unadjusted emission 

estimates

 emission = lbs of product used x EP x AMAF

In the adjusted inventory, nonfumigant product emissions are not currently adjusted for 

application method or other field factors due to a lack of data to support such adjustments. 

Consequently their emissions are calculated using the same procedure as the unadjusted 

inventory. 

Usually there are several different types of application methods used for a particular fumigant 

in any particular NAA. Each method of use (e.g. drip, sprinkler, shank, tarp, etc.) represents a 

fraction of the total number of methods used and is referred to as the Method Use Fraction 

(MUF). The sum of all MUFs for any particular (NAA/fumigant AI) combination is one. Use 

practices change over time so that different MUFs are used for the baseline year (1990) as 

opposed to more recent inventory years. For 2007 and earlier years, MUFs are determined in a 

number of different ways. For 1,3-dichloropropene the MUFs are determined from use data 

collected by the registrant in support of DPR’s township application caps; for metam sodium 

and metam potassium grower/applicator surveys were conducted to determine types of 

applications for different crops and areas. Methyl bromide and chloropicrin MUFs are based on 

expert opinion and regulatory history. Finally, MUFs for dazomet and sodium 

tetrathiocarbonate equal one because the AMAFs for each of these two fumigants are constant, 

independent of application method. A detailed discussion of how MUF and AMAFs were 

determined is given by Barry et al (2007). 

The 2008 VOC regulations included a change to pesticide use reports that requires recording 

the specific application method for each fumigation within NAAs. The MUFs for 2008 and 

later years are calculated using the fumigation method documented in pesticide use reports 

rather than the surrogate data described above. The use of a fumigant code to identify the 

fumigant application method in the pesticide use report was implemented in 2009 (Ibewiro, 

2008). For all NAAs combined, approximately six percent of the pesticide use reports for 2010 

are missing the identification of the application method (fumigant code). In these cases, DPR 
14

used a conservative approach by assuming that the application method with the highest AMAF 

allowed by the regulations for that fumigant was used. Field fumigation methods (FFM), FFM 

codes for pesticide use reporting, and corresponding emission ratings, and the AMAFs and 

method use fractions for 1990, 2005, 2006, 2007 and 2008 in each of the NAAs are included in 

the appendix of this document (Tables A1 – 1 to A1 – 27, Appendix 1B). 

In addition to the VOC emissions derived from fumigant active ingredients, inert ingredients 

for products that contain chloropicrin, methyl bromide, 1,3-dichloropropene and methyl iodide 

are assumed to be volatile and are included in the inventory calculations. For the highest use 

products containing those fumigants, DPR analyzes their confidential statements of formula to 

determine the composition of inerts and decides whether those inerts are nonvolatile. Inert 

ingredients used in products containing metam sodium, metam potassium, sodium 

tetrathiocarbonate and dazomet are non-volatile and so do not contribute to the emission 

potential of these products. 

VOC emissions were calculated for each NAA and summed according to primary active 

ingredient, application site, and emission category as defined by the Air Resources Board 

(ARB). The primary active ingredient is defined as the pesticide active ingredient present at the 

highest percentage in a product. If a pesticide product contains 20 percent of active ingredient 

“A” and 10 percent of active ingredient “B”, all estimated emissions from that product are 

assigned to the primary active ingredient “A”. This approach prevents “double-counting” of 

emissions from products containing two active ingredients. 

Both unadjusted and adjusted emission inventory data for the top ten primary active ingredients 

contributing to May-October ozone in 2007, 2008 and 2009 are included in this report. 

Appendix 2 contains summaries of emissions attributable to specific application sites (or 

commodities). These summary data are provided only for unadjusted emissions because it is 

not possible to allocate adjusted emissions to specific application sites with the currently 

available data. 

ARB defines four VOC emission categories: methyl bromide emissions from agricultural 

applications, non-methyl bromide emissions from agricultural applications, methyl bromide 

emissions from structural applications, and non-methyl bromide emissions from structural 

applications. Emissions were calculated for the May–October ozone season, and are reported as 

U.S. tons per day (tpd). 

Data Revisions 

DPR continually evaluates pesticide use report data, EP values, MUFs, and AMAFs to ensure 

the VOC inventory includes the most reliable data. Since the last annual report, DPR has 

completed review of several studies conducted under contract to ARB (Johnson 2011). These 

studies evaluated 1,3-dichloropropene deep-shank injection fumigation methods that included 

five post-fumigation water treatments and a composted green waste soil amendment. Based on 

these studies, DPR has established the AMAFs shown in Table 4. However, neither of these 

fumigation methods may be commercially feasible due to the high cost. Fumigation method 

codes will be assigned if and when these methods are used. 
15

Table 4. Revised application method adjustment factors (emission ratings) 

Method Description Fumigation 

Method Code

Original 

AMAF (%)

Revised AMAF 

(%)

1,3-D, deep-shank w/ 5 water treatments None None 15 

1,3-D deep shank w/ green waste None None 5 

VOC emissions from inert ingredients in glyphosate products have increased in the last few 

years in several NAAs. Most if not all of the increase in emissions was due to Roundup 

Powermax Herbicide, first registered in 2007. Due to a lack of thermogravimetric analysis data, 

at that time DPR assigned an EP of 35.28 percent for this product. Most other glyphosate 

products have EPs of 0 to 6 percent. DPR then requested EP data from the product registrant, 

and has subsequently received, reviewed and approved that data that shows an EP of 0 percent 

for that product. Consequently the 2008 and 2009 inventories have been updated based on this 

new information. 

DPR recently adopted a new procedure for estimating emission potentials (EP) of selected 

products with very high use when thermogravimetric analysis data are not available. That 

method is based on analysis of product confidential statements of formula as described by Oros 

and Spurlock (2011). 

DPR has proposed a SIP revision with a commitment to ensure pesticide VOC emissions do not 

exceed 18.1 tons/day in the San Joaquin Valley NAA, equivalent to a 12 percent reduction 

from 1990 (Table 3). DPR will use the emissions estimation methodology described in this 

report to meet the SIP commitment. Emission ratings for application methods that were used in 

1990 will not be modified, absent a SIP revision. Similarly, regarding nonfumigant pesticides, 

DPR will not revise the emission potentials of formulations that were used in the base year, 

absent a SIP revision. 
16

VOLATILE ORGANIC COMPOUND INVENTORY RESULTS

The main text of this report summarizes the pesticide VOC emission inventory data for 2010 

only. Adjusted and unadjusted emission data for 2007, 2008 and 2009, and unadjusted data for 

2010 are summarized in Appendices 2 and 3. Previous inventory memos and the 2007, 2008 

and 2009 reports included a summary of pesticide VOC emissions by commodity/site. At this 

time it is not possible to determine the breakdown of adjusted emissions by commodity, so only 

the unadjusted emissions are shown by commodity. Tables for emissions calculated for active 

ingredients (adjusted and unadjusted) and application sites (unadjusted) contain information for 

the top ten contributors only. 

Figure 2 illustrates the changes in unadjusted VOC emissions from 1990 to 2010. These values 

are unadjusted and so do not take in to consideration MUFs and AMAFs that can only be 

applied to emissions in 2004 through 2010, and 1990. The figure is useful in that it compares 

emissions for the entire history of the inventory and shows trends in five NAAs. 

Tables 5 and 6a and Figure 3 summarize the adjusted pesticide VOC emissions for 2004 

through 2010, and compare them to the SIP goals that based a percentage reduction from the 

1990. Table 6b compares the unadjusted and adjusted fumigant VOC emissions for 2004 

through 2010. Table 6c shows the amount of emissions that resulted from nonfumigant 

products with emulsifiable concentrate formulations compared to all other formulations. The 

emissions in the base year are also included to reflect the long term decrease or increase. 

Generally, what the tables and figure show can be summarized as follows: 

• Adjusted emissions in 2010 in the Sacramento Metro (1) reversed the decline of 2006 to 

2009 and increased to above 1 ton per day (1.061 tpd). Nonfumigants represented 91 

percent of the total, the latter remaining well below the SIP goal. Fifty-three percent 

(0.509 tpd) of nonfumigant emissions were derived from products with emulsifiable 

concentrate formulations. 

• Emissions in the South Coast NAA (5) increased by 42 percent over 2009 values but 

remain well below the SIP goal. More than three quarters of the total adjusted VOC 

emissions came from non-fumigants (1.359 tpd), of which less than one third are 

attributable to products with emulsifiable concentrate formulations. 

• In 2010, fumigants accounted for more than half of VOC emissions in the Southeast 

Desert (3), up significantly from 2009. Total VOC emissions in 2010 increased by more 

than 60 percent from 2009 but continue to meet the SIP goal. 

• 2010 VOC emissions in the Ventura NAA (4) increased by 0.518 tpd from the previous 

year but continue to meet the regulatory goal for 2010, 2011and 2012. Eighty two

percent of emissions came from fumigants.

• In the San Joaquin Valley NAA (2), nonfumigants accounted for three quarters of the 

total VOC emissions in 2010. In this NAA, VOC emissions increased from 2009 to 

2010 by about 24 percent, but continue to be below the SIP goal by 1.263 tpd, and 2010 

emissions were approximately the average level of 2004-2009. Nonfumigant emissions 

from products with emulsifiable concentrate formulations accounted for almost half of 

the total VOC emissions for this NAA and 64 percent of emissions from nonfumigants. 
17

Pesticide use varies from year to year depending on many factors, including weather, pest 

problems, economics and types of crops planted. Increases and decreases in pesticide use from 

one year to the next or in the span of a few years do not necessarily indicate a trend. Such 

variances are and will continue to be a normal occurrence. For example, extremely heavy rains 

result in excessive weeds, thus more pesticides may be used; drought conditions may result in 

fewer planted acres, thus less pesticide may be used. A more detailed explanation of pesticide 

use patterns is given in DPR’s annual summary of pesticide use reports available at:

http://www.cdpr.ca.gov/docs/pur/pur10rep/chmrpt10.pdf . 

While emissions increased in 2010, DPR, growers, registrants, and others have taken steps to 

reduce VOC emissions. In the last few years, DPR has registered several reformulated products 

with lower EPs, including products containing chlorpyrifos and abamectin that are major VOC 

contributors in the San Joaquin Valley. Many growers are switching to the reformulated 

products. For example, the reformulated chlopyrifos product with a lower EP was registered in 

2008, and it was the chlorpyrifos product with the highest use in the San Joaquin Valley during 

2010. DPR is drafting regulations to address nonfumigant VOC emissions for the San Joaquin 

Valley, so this trend should continue. 
18

Figure 2. Annual unadjusted ozone season pesticide VOC emissions by NAA from 1990 to 

2010, inclusive. 

NAA 1 Sacramento Metropolitan

Year

1990

1993

1996

1999

2002

2005

2008

2011

Emission Rate (tpd)

0

1

2

3

4

NAA 2 San Joaquin Valley 

Year

1990

1993

1996

1999

2002

2005

2008

2011

Emission Rtae (tpd)

0

10

20

30

40

NAA 3 Southeast Desert 

Year

1990

1993

1996

1999

2002

2005

2008

2011

Emission Rate (tpd)

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

NAA 4 Ventura

Year

1990

1993

1996

1999

2002

2005

2008

2011

Emission Rate (tpd)

0

2

4

6

8

10

12

NAA 5 South Coast

Year

1990

1993

1996

1999

2002

2005

2008

2011

Emission Rate (tpd)

0

2

4

6

8

10

12
Table 5. May–October (ozone season) adjusted pesticide VOC emissions and goals.

NAA

1990

Emissions

(tons/day)

SIP 

Goal 

(tons/day)

2004

Emissions

(tons/day)

2005

Emissions

(tons/day)

2006

Emissions

(tons/day)

2007

Emissions

(tons/day)

2008 

Emissions

(tons/day)

2009 

Emissions

(tons/day)

2010

Emissions

(tons/day)

1 – Sacramento Metro 2.784 2.2 1.235 1.239 1.354 1.050 0.938 0.946 1.061

2 – San Joaquin Valley 20.517 18.1 17.322 20.740 21.305 17.164 14.543 13.484 16.837

3 – Southeast Desert 1.153 0.92 0.995 0.740 0.634 0.762 0.286 0.283 0.453

4 – Ventura 3.787 3.0 a 3.924 3.617 3.682 3.363 1.739 2.080 2.598

5 – South Coast 10.840 8.7 1.922 1.969 1.482 1.487 1.283 1.220 1.734

a These numbers reflect the SIP goal for 2012 in Ventura, and do not reflect the phase in of reductions between 2008 and 2012.

Table 6a. May–October (ozone season) adjusted fumigant and nonfumigant pesticide VOC emissions.

NAA

1990

Emissions

(tons/day)

2004

Emissions

(tons/day)

2005

Emissions

(tons/day)

2006

Emissions

(tons/day)

2007

Emissions

(tons/day)

2008

Emissions

(tons/day)

2009

Emissions

(tons/day)

2010

Emissions

(tons/day)

1 – Sacramento Metro

Fumigants 0.384 (14%) 0.111 (9%) 0.085 (7%) 0.162 (12%) 0.189 (18%) 0.064 (7%) 0.133 (14%) 0.097 (9%)

Nonfumigants 2.400 (86%) 1.124 (91%) 1.154 (93%) 1.192 (88%) 0.861 (82%) 0.873 (93%) 0.813 (86%) 0.965 (91%)

2 - San Joaquin Valley

Fumigants 5.536 (27%) 6.362 (37%) 6.910 (33%) 6.808 (32%) 6.123 (36%) 3.370 (23%) 3.424 (25%) 4.023 (24%)

Nonfumigants 14.981 (73%) 10.960 (63%) 13.831 (67%) 14.498 (68%) 11.041 (64%) 11.173 (77%) 10.060 (75%) 12.814 (76%)

3 - Southeast Desert

0.840 (73%) 0.762 (77%) 0.474 (64%) 0.413 (65%) 0.575 (75%) 0.119 (42%) 0.138 (49%) 0.272 (60%) Fumigants

Nonfumigants 0.313 (27%) 0.233 (23%) 0.266 (36%) 0.221 (35%) 0.187 (25%) 0.167 (58%) 0.145 (51%) 0.181 (40%)

4 - Ventura

3.140 (83%) 3.302 (84%) 3.119 (86%) 3.175 (86%) 2.935 (87%) 1.252 (72%) 1.627 (78%) 2.122 (82%) Fumigants

Nonfumigants 0.647 (17%) 0.622 (16%) 0.497 (14%) 0.508 (14%) 0.428 (13%) 0.487 (28%) 0.453 (22%) 0.476 (18%)

5 – South Coast

Fumigants 9.372 (86%) 0.702 (37%) 0.594 (30%) 0.422 (28%) 0.411 (28%) 0.377 (29%) 0.297 (24%) 0.376 (22%)

Nonfumigants 1.468 (14%) 1.220 (63%) 1.375 (70%) 1.060 (72%) 1.075 (72%) 0.906 (71%) 0.922 (76%) 1.359 (78%)
20

Table 6b. May–October (ozone season) unadjusted and adjusted fumigant pesticide VOC emissions.

NAA

1990

Emissions

(tons/day)

2004

Emissions

(tons/day)

2005

Emissions

(tons/day)

2006

Emissions

(tons/day)

2007

Emissions

(tons/day)

2008 

Emissions

(tons/day)

2009 

Emissions

(tons/day)

2010

Emissions

(tons/day)

1 – Sacramento Metro

Unadjusted Fumigants 0.461 0.186 0.151 0.315 0.383 0.241 0.362 0.181

Adjusted Fumigants 0.384 0.111 0.085 0.162 0.189 0.064 0.133 0.097

2 - San Joaquin Valley

Unadjusted Fumigants 7.491 14.213 15.400 15.034 13.750 12.620 10.559 12.696

Adjusted Fumigants 5.536 6.362 6.910 6.808 6.123 3.370 3.424 4.023

3 - Southeast Desert

Unadjusted Fumigants 0.933 1.275 0.863 0.750 1.086 0.684 0.470 0.812

Adjusted Fumigants 0.840 0.762 0.474 0.413 0.575 0.119 0.138 0.272

4 - Ventura

Unadjusted Fumigants 3.909 8.916 8.841 9.113 8.658 6.543 6.345 8.844

Adjusted Fumigants 3.140 3.302 3.119 3.175 2.935 1.252 1.627 2.122

5 – South Coast

Unadjusted Fumigants 9.514 1.418 1.301 0.898 0.883 1.043 0.692 0.647

Adjusted Fumigants 9.372 0.702 0.594 0.422 0.411 0.377 0.297 0.376
21

Table 6c. May-October (ozone season) nonfumigant pesticide VOC emissions derived from Emulsifiable Concentrate formulations 

(ECs) and all Others. The adjusted and unadjusted VOC emissions for nonfumigants are the same. 

NAA

1990

Emissions

(tons/day)

2004

Emissions

(tons/day)

2005

Emissions

(tons/day)

2006

Emissions

(tons/day)

2007

Emissions

(tons/day)

2008

Emissions

(tons/day)

2009

Emissions

(tons/day)

2010

Emissions

(tons/day)

1 – Sacramento Metro

ECs 1.129 (47%) 0.534 (47%) 0.642 (56%) 0.640 (54%) 0.479 (56%) 0.522 (60%) 0.429 (53%) 0.509 (53%)

Others 1.271 (53%) 0.590 (53%) 0.513 (44%) 0.552 (46%) 0.382 (44%) 0.351 (40%) 0.384 (47%) 0.456 (47%)

2 - San Joaquin Valley

ECs 12.162 (81%) 8.613 (79%) 10.199 (74%) 10.119 (70%) 7.618 (69%) 7.510 (67%) 6.350 (63%) 8.140 (64%)

Others 2.819 (19%) 2.347 (21%) 3.632 (26%) 4.379 (30%) 3.423 (31%) 3.663 (33%) 3.710 (37%) 4.674 (36%)

3 - Southeast Desert

ECs 0.217 (69%) 0.150 (64%) 0.185 (69%) 0.131 (59%) 0.105 (56%) 0.089 (53%) 0.073 (50%) 0.092 (51%)

Others 0.096 (31%) 0.083 (36%) 0.082 (31%) 0.091 (41%) 0.083 (44%) 0.078 (47%) 0.073 (50%) 0.089 (49%)

4 - Ventura

ECs 0.402 (62%) 0.263 (42%) 0.286 (58%) 0.272 (54%) 0.210 (49%) 0.237 (49%) 0.242 (53%) 0.240 (50%)

Others 0.245 (38%) 0.360 (58%) 0.211 (42%) 0.236 (46%) 0.218 (51%) 0.250 (51%) 0.212 (47%) 0.236 (50%)

5 – South Coast

ECs 0.921 (63%) 0.647 (53%) 0.762 (55%) 0.514 (48%) 0.459 (43%) 0.339 (37%) 0.371 (40%) 0.415 (31%)

Others 0.547 (37%) 0.573 (47%) 0.613 (45%) 0.546 (52%) 0.616 (57%) 0.567 (63%) 0.551 (60%) 0.944 (69%)
22

Figure 3. Annual ozone season pesticide VOC emissions by NAA. These figures show 

adjusted emissions and SIP goals (reductions from 1990 emissions). 

NAA 1 Sacramento Metropolitan

Year

1990

1995

2000

2005

2010

2015

Emission Rate (tpd)

0.0

0.5

1.0

1.5

2.0

2.5

3.0

NAA 2 San Joaquin Valley 

Year

1990

1995

2000

2005

2010

2015

Emission Rate (tpd)

0

5

10

15

20

25

NAA 3 Southeast Desert 

Year

1990

1995

2000

2005

2010

2015

Emission Rate (tpd)

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

NAA 4 Ventura

Year

1990

1995

2000

2005

2010

2015

Emission Rate (tpd)

0

1

2

3

4

5

NAA 5 South Coast

Year

1990

1995

2000

2005

2010

2015

Emission Rate (tpd)

0

2

4

6

8

10

12

• Adjusted Emissions 

(1990, 2004, 2005, 2006, 2007, 

2008, 2009 & 2010)

SIP Goals

 
23

Sacramento Metro Area - NAA 1

The Sacramento Metro NAA (NAA 1) 2010 adjusted emissions increased to above the levels of 

the two previous years. Adjusted emissions in 2007 were 1.050 tpd which decreased to 0.938 

tpd in 2008, increased to 0.946 tpd in 2009, and increased again to 1.061 tpd in 2010. 

Fumigant emissions increased from 18 percent in 2007 (0.189 tpd), were reduced to 7 percent 

(0.064 tpd) in 2008, increased in 2009 to 0.133 tpd and decreased to 0.097 tpd in 2010. In 

2010, 91 percent of emissions were attributable to nonfumigants, 53 percent (0.509 tpd ) of 

which were from products with emulsifiable concentrate formulations. Total adjusted VOC 

emissions (1.061 tpd) continue to remain well below the SIP goal of 2.2 tpd. (Tables 6a, 6b, 6c, 

Figures 3, 4). 

Emissions from chlorpyrifos use decreased to 0.086 tpd in 2009 and 0.076 tpd in 2010, the 

latter accounting for over seven percent of the total emissions in 2010 (Table 7). Emissions 

from the use of 1,3-dichloropropene, which doubled from 2008 to 2009, decreased to 0.035 tpd 

in 2010 accounting for 3.43 percent of emissions, and emissions from methyl bromide use 

increased from 0.031 tpd in 2009 to 0.045 tpd in 2010. Emissions from bifenthrin, a pyrethroid 

insecticide used on a range of crops, have increased every year from 0.025 tpd in 2007 to 0.120 

tpd in 2010, as have emissions from trifluralin, which have tripled from 0.017 tpd in 2007 to 

0.054 tpd in 2010. (Tables 7, A3-1a to A3-1d, Figure 5).

In 2010 combined emissions from tomatoes and walnuts increased by approximately 0.1 tpd 

(0.139 tpd in 2009 to 0.198 tpd in 2010, and 0.115 tpd in 2009 to 0.161 tpd in 2010, 

respectively). These two commodities/sites accounted for over 30 percent of the total emissions 

in the Sacramento Metro Area NAA, with emissions from rice accounting for an additional 

18.02 percent, an increase from 0.192 tpd in 2009 to 0.206 tpd in 2010. Emissions from wine 

grapes fell sharply from 0.177 tpd in 2009 to 0.055 tpd in 2010. It should be noted that in 2010 

use of the category “soil application” as a site/commodity was substantially reduced from 

previous years. Correspondingly, emissions from this category fell from 0.128 tpd in 2009 to 

less than 0.001 tpd in 2010. The “soil application” category is often used when a field is treated 

before a commodity has been planted. In 2010 it is most likely that the category has been 

replaced by more specific annual commodities such as tomatoes, sunflowers, strawberries, 

alfalfa, etc. (Tables 8, A2-1e to A2-1h, Figure 6).

Since this NAA has complied with the SIP goal for several years, most provisions of the 2008 

fumigant regulations do not apply. Therefore, the fumigant regulations had little or no impact 

on emissions in this NAA. 

Using the ARB emission inventory classification, emissions from structural applications of 

methyl bromide continue to be less than 0.001 tpd. Agricultural applications decreased from 

0.062 tpd in 2007 to 0.035 tpd in 2009, but increased to 0.057 tpd in 2010. Non-methyl 

bromide emissions from structural applications continue to decline from 0.066 tpd in 2007, 

0.062 tpd in 2008 and 0.053 tpd in 2009, to 0.047 tpd in 2010 (Tables 9, A2-1i - A2-1l). 
24

Figure 4. Pesticide VOC emissions for the Sacramento Metro NAA, May–October. Emissions 

for each year are divided into fumigants, nonfumigants with emulsifiable concentrate 

formulations (ECs) and other nonfumigants (Others). Fumigant emissions are adjusted to 

account for fumigation method. 

Table 7. Top ten primary active ingredients contributing to 2010 May-October ozone season 

adjusted VOC emissions in NAA 1, the Sacramento Metro Area.

Primary AI

Total Product 

Adjusted Emissions 

(tons/day)

Percent of All NAA 1 May – 

Oct 2010 Adjusted Emissions

BIFENTHRIN 0.120 11.80

CHLORPYRIFOS 0.076 7.42

TRIFLURALIN 0.054 5.31

THIOBENCARB 0.048 4.68

METHYL BROMIDE 0.045 4.41

ABAMECTIN 0.042 4.14

PROPANIL 0.038 3.71

PENOXSULAM 0.037 3.63

1,3-DICHLOROPROPENE 0.035 3.43

ETHALFLURALIN 0.030 2.99

0.0

0.5

1.0

1.5

2.0

2.5

3.0

1990 2006 2007 2008 2009 2010

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
25

Figure 5. Changes in adjusted emissions of selected AIs in the Sacramento Metro NAA from 

2007 to 2010. 

Table 8. Top ten pesticide application sites contributing to 2010 May-October ozone season 

unadjusted VOC emissions in NAA 1.

Application Site Emissions (tons/day) Percent of all NAA 1 May –

Oct 2010 emissions

RICE 0.206 18.02

TOMATOES, FOR PROCESSING/CANNING 0.198 17.27

WALNUT 0.161 14.01

RIGHTS OF WAY 0.059 5.16

GRAPES, WINE 0.055 4.80

STRUCTURAL PEST CONTROL 0.046 4.06

LANDSCAPE MAINTENANCE 0.046 3.99

ALMOND 0.039 3.43

COMMODITY FUMIGATION 0.034 2.97

N-OUTDR CONTAINER/FLD GRWN PLANTS 0.033 2.87

0.000

0.020

0.040

0.060

0.080

0.100

0.120

0.140

2007 2008 2009 2010

VOC Emissions (tons/day)

CHLORPYRIFOS 1,3-DICHLOROPROPENE

METHYL BROMIDE BIFENTHRIN

TRIFLURALIN
26

Figure 6. Changes in unadjusted emissions from selected commodities/sites in the Sacramento 

Metro NAA from 2007 to 2010. 

Table 9. Unadjusted 2010 May–October VOC emissions in NAA1 by ARB emission inventory 

classification (tons per day, tpd). 

NAA 1 - 2010 Agricultural 

Applications

Structural 

Applications

METHYL BROMIDE EMISSIONS 0.057 0.000

NON-METHYL BROMIDE EMISSIONS 1.036 0.047

0.000

0.050

0.100

0.150

0.200

0.250

0.300

0.350

2007 2008 2009 2010

VOC Emissions (tons/day)

RICE GRAPES, WINE

TOMATO, PROCESSING STRUCTURAL PEST CONTROL

WALNUT SOIL APPLICATION, PREPLANT
27

San Joaquin Valley - NAA 2

Adjusted emissions in 2010 increased from 13.484 tpd in 2009 to 16.837 tpd in 2010, a 24 

percent increase. As with the 2009 emissions, the 2010 emissions are below the SIP goal of 

18.1 tpd (Tables 6a, 6b, Figure 3, 7). 

Nonfumigants continue to account for the largest portion of adjusted emissions, with more than 

76 percent of the total in 2010 (12.814 tpd). Overall, nonfumigant emissions increased by 2.754 

tpd (27 percent) in 2010, bringing emissions back to a level not seen since before 2007. In 

2010, 64 percent of nonfumigant emissions was from products with emulsifiable concentrate 

formulations (8.140 tpd), an increase of 1.79 tpd from 2009 (Table 6c). The top emission 

contributor for 2007 through 2010 was the nonfumigant, chlorpyrifos, which accounted for 

2.263 tpd in 2007, 2.221 tpd in 2008, 1.389 tpd in 2009 and 1.828 tpd in 2010. (Tables 10, A3-

2a to A3-2d, Figure 7). In 2010 more than 25 percent of emissions from chlorpyrifos came 

from use on almonds, with another 55 percent of emissions from chlorpyrifos from the 

combined use on cotton, oranges and alfalfa. Fumigant use on carrots, in the form of metamsodium, 1,3-dichloropropene and potassium N-methyldithiocarbamate, accounted for more than 

98 percent of emissions from this commodity (Tables 11, A2- 2e to A2-2h, Figure 9). Total 

adjusted emissions from metam-sodium increased from 1.120 tpd in 2009 to 1.148 tpd in 2010 

from use on onions, head lettuce and tomatoes. Emissions from products containing bifenthrin 

increased by almost 500 percent from 0.296 tpd in 2009 to 1.553 tpd in 2010, due in large part 

to increased use on almonds and pistachios (Figure 8). 

Although the 2008 fumigant regulations continued to maintain lower emissions from 

fumigants, adjusted fumigant emissions increased by 0.599 tpd (18 percent) between 2009 and 

2010. Use (unadjusted emissions) of fumigants increased by 20 percent (Table 6b). The 

increase in fumigant emissions is primarily due to increased product use overall, as the use of 

low-emission fumigation methods required by the 2008 regulations is now well established. 

Using the ARB emission inventory classification, emissions from structural applications of 

methyl bromide decreased significantly in 2010 going from 0.012 tpd in 2009 to less than 0.001 

tpd in 2010. Agricultural applications increased by approximately 15 percent from 0.908 tpd in 

2009 to 1.044 tpd in 2010. Non-methyl bromide emissions from agricultural applications 

increased from 19.242 tpd in 2009 to 23.892 tpd in 2010, and structural applications increased 

from 0.190 tpd in 2009 to 0.239 tpd in 2010. (Tables 12, A2-2i to A2-2l). 
28

Figure 7. Pesticide VOC emissions for the San Joaquin Valley NAA, May–October. Emissions 

for each year are divided into fumigants, nonfumigants with emulsifiable concentrate 

formulations (ECs) and other nonfumigants (Others). Fumigant emissions are adjusted to 

account for fumigation method. 

Table 10. Top ten primary active ingredients contributing to 2010 May-October ozone season 

adjusted VOC emissions in NAA 2, the San Joaquin Valley. 

Primary AI

Total Product 

Adjusted Emissions 

(tons/day)

Percent of All NAA 2 May – 

Oct 2010 Adjusted Emissions

CHLORPYRIFOS 1.828 11.32

BIFENTHRIN 1.553 9.61

1,3-DICHLOROPROPENE 1.488 9.21

METAM-SODIUM 1.148 7.11

ABAMECTIN 1.064 6.58

OXYFLUORFEN 0.687 4.25

GIBBERELLINS 0.684 4.23

METHYL BROMIDE 0.581 3.60

GLYPHOSATE, ISOPROPYLAMINE SALT 0.459 2.84

POTASSIUM N-METHYLDITHIOCARBAMATE 0.436 2.70

0.0

5.0

10.0

15.0

20.0

25.0

1990 2006 2007 2008 2009 2010

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
29

Figure 8. Changes in adjusted emissions of selected AIs in the San Joaquin Valley NAA from 

2007 to 2010. 

Table 11. Top ten pesticide application sites contributing to 2010 May-October ozone season 

unadjusted VOC emissions in NAA 2.

Application Site Emissions (tons/day) Percent of all NAA 2 May –

Oct 2010 emissions

ALMOND 4.662 18.28

CARROTS 3.604 14.13

COTTON 1.605 6.29

SOIL APPLICATION, PREPLANT-OUTDOOR 1.303 5.11

GRAPES 1.274 5.00

TOMATOES, FOR PROCESSING/CANNING 1.245 4.88

ORANGE 1.020 4.00

N-OUTDR CONTAINER/FLD GRWN PLANTS 1.017 3.99

WALNUT 0.897 3.52

POTATO 0.872 3.42

0.000

1.000

2.000

3.000

2007 2008 2009 2010

VOC Emissions (tons/day)

CHLORPYRIFOS 1,3-DICHLOROPROPENE

METAM-SODIUM METHYL BROMIDE

BIFENTHRIN GLYPHOSATE, ISOPROPYLAMINE SALT
30

Figure 9. Changes in unadjusted emissions from selected commodities/sites in the San Joaquin 

Valley NAA from 2007 to 2010. 

Table 12. Unadjusted 2010 May–October VOC emissions in NAA 2 by ARB emission 

inventory classification (tons per day, tpd). 

NAA 2 - 2010 Agricultural 

Applications

Structural 

Applications

METHYL BROMIDE EMISSIONS 1.044 0.000

NON-METHYL BROMIDE EMISSIONS 23.892 0.239

0.000

0.500

1.000

1.500

2.000

2.500

3.000

3.500

4.000

4.500

5.000

2007 2008 2009 2010

VOC Emissions (tons/day)

CARROT ALMOND COTTON TOMATO, PROCESSING
31

Southeast Desert - NAA 3

In 2010 total adjusted emissions for the Southeast Desert increased from 0.283 tpd in 2009 to 

0.453 tpd in 2010. The 2010 rate is well below the SIP goal of 0.92 tpd, (Tables 6a, 6b, Figure 

3, 10). 

Fumigants accounted for 60 percent of the emissions in this NAA in 2010, increasing to 0.272 

tpd, almost double that of the previous year. Metam-sodium continues to be the primary 

contributor, accounting for 35 percent of emissions in 2010 (0.160 tpd), up from 0.074 tpd in 

2009. Emissions from four other fumigants, chloropicrin, 1,3-dichloropropene, dazomet and 

methyl bromide accounted for an additional 22 percent of the total. Emissions from the use of 

1,3- dichloropropene increased from 0.001 tpd in 2009 to 0.038 tpd in 2010, while methyl 

bromide and dazomet declined (Tables 13, A3-3a to A3-3d, Figure 11). Approximately half of 

emissions from nonfumigant came from products with emulsifiable concentrate formulations 

(Table 6c). Unadjusted emissions from commodities during the ozone season in 2010 was 

varied. Emissions from potatoes, peppers and strawberries increased, while those from carrots 

and ornamental turf declined. The use of metam-sodium on peppers and watermelon correlates 

to the increase in emissions from this fumigant (Tables 14, A2- 3d to A2-3h, Figure 12).

The 2008 fumigant regulations caused a decrease in emissions in Southeast Desert NAA in 

2009. However, fumigant emissions almost doubled between 2009 and 2010, from 0.138 tpd to 

0.272 tpd. Approximately three-quarters of the increased emissions were due to increased use, 

as indicated by the change in unadjusted and adjusted fumigant emissions shown in Table 6b. 

Fumigants accounted for almost two-thirds of the pesticide emissions in 2010 for this NAA, but 

accounted for less than half the emissions in 2009 (Figure 10). 

Using the ARB emission inventory classification, emissions from structural applications of 

methyl bromide have been less than 0.001 tpd since 2005. Agricultural applications peaked at 

0.286 tpd in 2007, and have since decreased to 0.012 tpd in 2010. These findings are consistent 

with the trend found for the decline in use of methyl bromide on turf/sod. Non-methyl bromide 

emissions from agricultural applications increased by 88 percent from 0.494 tpd in 2009 to 

0.930 tpd in 2010. Structural non-methyl bromide emissions also increased from 0.045 tpd in 

2009 to 0.051 tpd in 2010 (Tables 15, A2-3i to A2-3l). 
32

Figure 10. Pesticide VOC emissions for the Southeast Desert NAA, May–October. Emissions 

for each year are divided into fumigants, nonfumigants with emulsifiable concentrate 

formulations (ECs) and other nonfumigants (Others). Fumigant emissions are adjusted to 

account for fumigation method.

Table 13. Top ten primary active ingredients contributing to 2010 May-October ozone season 

adjusted VOC emissions in NAA 3, the Southeast Desert 

Primary AI

Total Product 

Adjusted Emissions 

(tons/day)

Percent of All NAA 3 May – 

Oct 2010 Adjusted Emissions

METAM-SODIUM 0.160 35.31

CHLOROPICRIN 0.038 8.34

1,3-DICHLOROPROPENE 0.038 8.28

BENSULIDE 0.032 7.16

DAZOMET 0.012 2.75

METHYL BROMIDE 0.012 2.69

EPTC 0.011 2.54

GLYPHOSATE, ISOPROPYLAMINE SALT 0.010 2.28

GIBBERELLINS 0.010 2.22

CYFLUTHRIN 0.009 1.94

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1990 2006 2007 2008 2009 2010

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
33

Figure 11. Changes in adjusted emissions of selected AIs in the Southeast Desert NAA from 

2007 to 2010. 

Table 14. Top ten pesticide application sites contributing to 2010 May-October ozone season 

unadjusted VOC emissions in NAA 3.

Application Site Emissions (tons/day) Percent of all NAA 3 May –

Oct 2010 emissions

PEPPERS 0.275 27.73

STRAWBERRY 0.149 14.97

CARROTS 0.087 8.72

WATERMELONS 0.079 7.94

LETTUCE, LEAF 0.056 5.64

UNCULTIVATED AGRICULTURAL AREAS* 0.053 5.32

STRUCTURAL PEST CONTROL 0.051 5.11

CAULIFLOWER 0.029 2.92

POTATO 0.028 2.81

GRAPES 0.027 2.68

* Treatment of an area prior to determining which crop will be planted.

0.000

0.100

0.200

0.300

0.400

2007 2008 2009 2010

VOC Emissions (tons/day)

METAM-SODIUM METHYL BROMIDE 1,3-DICHLOROPROPENE DAZOMET
34

Figure 12. Changes in unadjusted emissions from selected commodities/sites in the Southeast 

Desert NAA from 2007 to 2010. 

Table 15. Unadjusted 2010 May–October VOC emissions in NAA 3 by ARB emission 

inventory classification (tons per day, tpd). 

NAA 3 - 2010 Agricultural 

Applications

Structural 

Applications

METHYL BROMIDE EMISSIONS 0.012 0.000

NON-METHYL BROMIDE EMISSIONS 0.930 0.051

0.000

0.050

0.100

0.150

0.200

0.250

0.300

0.350

2007 2008 2009 2010

VOC Emissions (tons/day)

PEPPERS ORNAMENTAL TURF POTATO

CARROT STRAWBERRY
35

Ventura - NAA 4

Ozone season adjusted emissions in the Ventura NAA (NAA 4) increased by 0.518 tpd from 

2.080 tpd in 2009 to 2.598 tpd in 2010 (25 percent). Emissions continued to meet the SIP goal 

for 2012 (3.0 tpd). (Tables 6a, 6b, Figure 3, 13). 

As in previous years, fumigants dominate the pesticide inventory for this NAA. In 2010 

fumigants accounted for 82 percent of the emissions, up from 78 percent in 2009 and 72 

percent in 2008. The most heavily used fumigants in NAA 4 in 2010 were chloropicrin, methyl 

bromide, and 1,3-dichloropropene, which together accounted for over 65 percent of emissions 

(Tables 16, A3-4a to A3-4d, Figure 14). Emissions from 1,3-dichloropropene and chloropicrin

increased in 2010, while emissions from methyl bromide declined slightly from 0.544 tpd in 

2009 to 0.515 tpd in 2010, but were above emission levels in 2008 (0.277 tpd). In 2010 over 96 

percent of chloropicrin emissions and over 89 percent of methyl bromide emissions came from 

applications to strawberries or “soil application/preplant”. It should be noted that the 

commodity/site description “soil fumigation/preplant” refers to applications that are made 

before the grower has made a decision about which commodity to plant. These sites may be reidentified at a later time as any number of commodities including strawberries, peppers, 

raspberries, herbs, etc., but it is beyond the scope of this inventory to be able to identify which 

commodities these are. Other major commodities/sites in 2010 include raspberries, lemons, 

and tomatoes. (Tables 17, A2-4e to A2-4h, Figure 15). In 2010 50 percent of nonfumigant 

emissions, which account for less than 20 percent of this NAA’s total adjusted emissions, were 

from products with emulsifiable concentrate formulations (0.240 tpd) (Table 6c). 

Using the ARB emission inventory classification, emissions from structural applications were 

below 0.001 tpd in 2010. Emissions from agricultural applications of methyl bromide decreased 

from 1.134 tpd in 2009 to 1.073 tpd in 2010. These findings are consistent with the trend found 

for the use of methyl bromide to strawberries and soil fumigation/preplant. Non-methyl 

bromide emissions from agricultural applications increased from 5.160 tpd in 2009 to 7.634 

tpd in 2010. Structural non-methyl bromide emissions were less than 0.025 tpd (Tables 18, A2-

4i to A2-4l). 
36

Figure 13. Pesticide VOC emissions for the Ventura NAA, May–October. Emissions for each 

year are divided into fumigants, nonfumigants with emulsifiable concentrate formulations 

(ECs) and other nonfumigants (Others). Fumigant emissions are adjusted to account for 

fumigation method. 

Table 16. Top ten primary active ingredients contributing to 2010 May-October ozone season 

adjusted VOC emissions in NAA 4, Ventura. 

Primary AI Total Product Adjusted 

Emissions (tons/day)

Percent of All NAA 4 May –

Oct 2010 Adjusted Emissions

CHLOROPICRIN 0.804 31.00

METHYL BROMIDE 0.515 19.88

1,3-DICHLOROPROPENE 0.380 14.64

METAM-SODIUM 0.056 2.18

CHLORPYRIFOS 0.043 1.64

MINERAL OIL 0.037 1.44

ABAMECTIN 0.036 1.38

PETROLEUM OIL, UNCLASSIFIED 0.029 1.11

OXAMYL 0.022 0.85

METALDEHYDE 0.021 0.80

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

1990 2006 2007 2008 2009 2010

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
37

Figure 14. Changes in adjusted emissions of selected AIs in the Ventura NAA from 2006 to 

2009. 

Table 17. Top ten pesticide application sites contributing to 2010 May-October ozone season 

unadjusted VOC emissions in NAA 4.

Application Site Emissions (tons/day) Percent of all NAA 4 May –

Oct 2010 emissions

STRAWBERRY 7.493 80.40

SOIL APPLICATION, PREPLANT-OUTDOOR 0.981 10.53

RASPBERRY 0.160 1.72

LEMON 0.159 1.70

TOMATO 0.149 1.60

N-OUTDR GRWN CUT FLWRS OR GREENS 0.085 0.92

PEPPERS 0.036 0.39

AVOCADO 0.033 0.35

STRUCTURAL PEST CONTROL 0.025 0.27

CELERY 0.024 0.25

0.000

0.200

0.400

0.600

0.800

1.000

1.200

1.400

2007 2008 2009 2010

VOC Emissions (tons/day)

CHLOROPICRIN METHYL BROMIDE 1,3-DICHLOROPROPENE
38

Figure 15. Changes in unadjusted emissions from selected commodities/sites in the Ventura 

NAA from 2007 to 2010. 

Table 18. Unadjusted 2010 May–October VOC emissions in NAA 4 by ARB emission 

inventory classification (tons per day, tpd). 

NAA 4 - 2010 Agricultural 

Applications

Structural 

Applications

METHYL BROMIDE EMISSIONS 1.134 0.000

NON-METHYL BROMIDE EMISSIONS 7.634 0.025

0.000

1.000

2.000

3.000

4.000

5.000

6.000

7.000

8.000

2007 2008 2009 2010

VOC Emissions (tons/day)

STRAWBERRY SOIL FUMIGATION/PREPLANT LEMON
39

South Coast - NAA 5

In the South Coast NAA, adjusted emissions increased from 1.220 tpd in 2009 to 1.734 tpd in 

2010, well below the SIP goal of 8.7 tpd. In 2010, emissions from nonfumigants accounted for 

more than 78 percent of the total for the South Coast NAA. Emissions from nonfumigants with 

emulsifiable concentrate formulations accounted for 0.415 tpd, which is 24 percent of the 

nonattainment area’s total adjusted emissions (Tables 6a, 6b, 6c, Figure 3, 16).

The fumigants methyl bromide, chloropicrin, and 1,3-dichloropropene, contributed to 18.86 

percent of 2010 adjusted emissions. Emissions from methyl bromide decreased from 2009 by 

0.005 tpd, but chloropicrin and 1,3-dichloropropene emissions increased from 0.058 tpd and 

0.025 in 2009 to 0.106 and 0.071 tpd in 2010, respectively. Cyfluthrin and permethrin, 

pyrethroid insecticides used in structural pest control, landscape maintenance and on a wide 

range of nursery commodities, were the largest nonfumigant contributors to the adjusted 

inventory accounting for 28.04 percent (0.265 tpd and 0.226 tpd, respectively) of emissions, up 

from 0.066 tpd and 0.203 tpd in 2009 (Tables 19, A3-5a to A3-5d, Figure 17). Limonene, an oil 

extracted from citrus that is used almost exclusively in structural pest control, decreased in 

emissions in 2010 (0.024 tpd), one third those from 2009 (0.070 tpd). Over seventy-six percent

of emissions in NAA 5 came from fumigant and nonfumigant use in structural pest control and 

on strawberries, with landscape maintenance accounting for another 8.21 percent (0.165 tpd ). 

Emissions from dazomet, primarily used on rights-of-way, decreased from 0.037 tpd in 2009 to 

0.021 tpd in 2010 to (Tables 20, A2-5e to A2-5h, Figure 18). 

Since this NAA has complied with the SIP goal for several years, most provisions of the 2008 

fumigant regulations do not apply. Therefore, the fumigant regulations had little or no impact 

on emissions in this NAA.

Using the ARB emission inventory classification, emissions from structural applications of 

methyl bromide remained at 0.002 tpd in 2010. Agricultural applications decreased from 0.227 

tpd in 2009 to 0.189 tpd in 2010. Non-methyl bromide emissions from agricultural applications 

increased from 0.655 tpd in 2009 to 0.757 tpd in 2010. Structural non-methyl bromide 

emissions increased from 0.658 tpd in 2009 to 1.018 tpd in 2010 (Tables 21, A2-5i to A2-5l). 
40

Figure 16. Pesticide VOC emissions for the South Coast NAA, May–October. Emissions for 

each year are divided into fumigants, nonfumigants with emulsifiable concentrate formulations 

(ECs) and other nonfumigants (Others). Fumigant emissions are adjusted to account for 

fumigation method.

Table 19. Top ten primary active ingredients contributing to 2010 May-October ozone season 

adjusted VOC emissions in NAA 5, South Coast. 

Primary AI

Total Product 

Adjusted Emissions 

(tons/day)

Percent of All NAA 5 May – 

Oct 2010 Adjusted Emissions

CYFLUTHRIN 0.265 15.27

PERMETHRIN 0.226 13.02

DISODIUM OCTABORATE TETRAHYDRATE 0.156 9.02

METHYL BROMIDE 0.149 8.62

CHLOROPICRIN 0.106 6.12

N-OCTYL BICYCLOHEPTENE 

DICARBOXIMIDE 0.087 5.01

1,3-DICHLOROPROPENE 0.071 4.12

IMIDACLOPRID 0.067 3.88

PIPERONYL BUTOXIDE 0.054 3.11

BIFENTHRIN 0.041 2.39

0.0

2.0

4.0

6.0

8.0

10.0

12.0

1990 2006 2007 2008 2009 2010

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
41

 Figure 17. Changes in adjusted emissions of selected AIs in the South Coast NAA from 2007 

to 2010. 

Table 20. Top ten pesticide application sites contributing to 2010 May-October ozone season 

unadjusted VOC emissions in NAA 5.

Application Site Emissions (tons/day) Percent of all NAA 5 May –

Oct 2010 emissions

STRUCTURAL PEST CONTROL 1.019 50.79

STRAWBERRY 0.512 25.52

LANDSCAPE MAINTENANCE 0.165 8.21

FUMIGATION, OTHER 0.085 4.23

N-OUTDR GRWN CUT FLWRS OR GREENS 0.077 3.85

RIGHTS OF WAY 0.039 1.97

N-OUTDR CONTAINER/FLD GRWN PLANTS 0.026 1.27

COMMODITY FUMIGATION 0.019 0.95

AVOCADO 0.008 0.42

ORANGE 0.008 0.41

0.000

0.100

0.200

0.300

2007 2008 2009 2010

VOC Emissions (tons/day)

PERMETHRIN METHYL BROMIDE

1,3-DICHLOROPROPENE DISODIUM OCTABORATE TETRAHYDRATE

CHLOROPICRIN CYFLUTHRIN
42

 Figure 18. Changes in unadjusted emissions from selected commodities/sites in the South 

Coast NAA from 2007 to 2010. 

Table 21. Unadjusted 2010 May–October VOC emissions in NAA 5 by ARB emission 

inventory classification (tons per day, tpd). 

NAA 5 - 2010 Agricultural 

Applications

Structural 

Applications

METHYL BROMIDE EMISSIONS 0.189 0.002

NON-METHYL BROMIDE EMISSIONS 0.757 1.018

0.000

0.200

0.400

0.600

0.800

1.000

1.200

2007 2008 2009 2010

VOC Emissions (tons/day)

STRUCTURAL PEST CONTROL STRAWBERRY

LANDSCAPE MAINTENANCE COMMODITY FUMIGATION
43

PROJECTION OF 2012 VOC EMISSIONS AND FUMIGANT LIMITS 

DPR is required to limit VOC emissions of volatile organic compounds from pesticides in 

Ventura County during each annual May–October ozone season, and for the other NAAs if 

pesticide VOC emissions exceed 95 percent of the benchmarks specified in 3 CCR section 

6452.2. As shown in Table 22, pesticide VOC emissions are less than 95 percent of the 

benchmarks that trigger fumigant limits in the Sacramento Metro, San Joaquin Valley, 

Southeast Desert and South Coast NAAs. 

Table 22. Fumigant limit triggers and 2010 pesticide VOC emissions.

NAA

Benchmark and 

SIP Goal 

(tons/day)

Fumigant Limit Trigger 

(95% of Benchmark)

(tons/day)

2010

Emissions

(tons/day)

1 – Sacramento Metro 2.2 2.1 1.061

2 – San Joaquin Valley 18.1 17.2 16.837

3 – Southeast Desert 0.92 0.87 0.453

5 – South Coast 8.7 8.3 1.734

The maximum allowable annual ozone season pesticide VOC emissions (VOCMAX) are 

defined in regulation 3 CCR, section 6452.2. DPR limits emissions by restricting use of the 

highest VOC contributing pesticides. These are the fumigants methyl bromide, 1,3-

dichloropropene, chloropicrin, metam-sodium, metam-potassium, dazomet and sodium 

tetrathiocarbonate. DPR calculates the maximum allowable fumigant emissions (VOCFUM) 

as the difference between VOCMAX and projected nonfumigant pesticide emissions 

(VOCNF) during the ozone season. 

[1] VOCFUM = VOCMAX −VOCNF

The allowable fumigant use is then calculated from VOCFUM using the most recent method use 

fractions and application method adjustment factors as originally described in Barry et al. 

(2007). This procedure is defined in regulation (3 CCR section 6452.2) and requires DPR to 

develop an estimate of nonfumigant emissions in advance of an upcoming ozone season. For 

2012, the 2010 method use fraction data and the application method adjustment factors used to 

determine allowable fumigant use from VOCFUM are given in Appendix 1. 

DPR developed a forecasting method to estimate Ventura NAA NOCNF based on a statistical 

time series analysis (Spurlock, 2009). The time series model is updated each year to include the 

most recent available pesticide use report data. After updating, the revised time series model is 

used to forecast nonfumigant emissions which, in turn, are used to calculate allowable fumigant 

emissions and fumigant use as described above. Table 23 compares 2004–2010 NAA 4 

nonfumigant ozone seasons emissions, while Table 24 provides the forecast 2012 nonfumigant 

emissions and resultant allowable fumigant emissions based on the regulatory benchmark and 

the SIP goal. 
44

Table 23. May–October (ozone season) nonfumigant pesticide VOC emissions and percent of total adjusted emissions.

NAA

2004 

Emissions

(tons/day)

2005 

Emissions

(tons/day)

2006 

Emissions

(tons/day)

2007 

Emissions

(tons/day)

2008 

Emissions

(tons/day)

2009 

Emissions

(tons/day)

2010 

Emissions

(tons/day)

Mean

Percent of 

Total 

Emissions

4 – Ventura

Nonfumigants 0.622 (16%) 0.497 (14%) 0.508 (14%) 0.428 (13%) 0.487 (28%) 0.453 (22%) 0.476 (18%) 18%

Table 24. Projection for 2012 NAA 4 VOC emissions. The 2012 fumigant emission limit was determined by subtracting the forecast 

2012 nonfumigant emissions from the SIP goal and VOC regulation benchmark (Tao, 2011).

NonAttainment 

Area

SIP Goal and VOC

Regulation

Benchmark

(tons/day)

Forecast 2012

Nonfumigant 

Emissions 

(tons/day)

2012 Fumigant 

Limit

(tons/day)

2012 Fumigant 

Limit

(pounds)

2010 Adjusted 

Fumigant 

Emissions

(tons/day)

4 - Ventura 3.0 a 0.440 2.56 942,000 2.122

a The Ventura SIP Goal and VOC Regulation Benchmark for 2012 is shown.
45

REFERENCES

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Pesticide Volatile Organic Compound Emission Adjustments For Field Conditions And 

Estimated Volatile Organic Compound Reductions–Revised Estimates. On-line:

http://www.cdpr.ca.gov/docs/emon/pubs/ehapreps/analysis_memos/1955_sanders.pdf

Barry, T. 2008. September 28, 2008, memorandum to Randy Segawa: Development of SubChronic Air Concentration Estimates Associated with Single Fumigant Application. 

Federal Register. 1997. January 8, 1997, page 1170, Emission Reductions. 

Federal Register. 2008. July 18, 2008, page 41277, Revisions to the California State 

Implementation Plan; Pesticide Element; Ventura County.

Ibewiro, B. 2008. How to File Pesticide Use Reports for Field Fumigant Applications. On-line: 

http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/factshts/voc_pur.pdf

Johnson, B. 2011. October 11, 2011. Memorandum to R Segawa. Evaluation of 1,3-

Dichloropropene and Chloropicrin Field Studies With Regard to Volatile Organic Compound 

Program. 

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Confidential Statements of Formula. 

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Forecasting of Ventura County Nonfumigant Pesticide Volatile Organic Compound Emissions. 

On-line:

http://www.cdpr.ca.gov/docs/emon/pubs/ehapreps/analysis_memos/2151_segawa.pdf 

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http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/voc_calc_revision071805.pdf

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http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/intro.pdf
46

Tao, J. October XX, 2011 memorandum to Randy Segawa. Time Series Analysis and 

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http://www.cdpr.ca.gov/docs/emon/pubs/ehapreps/analysis_memos/XXXX_segawa.pdf 

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