SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 1 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

APPENDIX C 

Cost Effectiveness Analysis 

For Revised Proposed New Rule 4566 

August 18, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 2 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 3 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

COST EFFECTIVENESS ANALYSIS FOR 

REVISED PROPOSED NEW RULE 4566 (ORGANIC MATERIAL COMPOSTING 

OPERATIONS) 

I. SUMMARY 

Cost effectiveness is a metric used to compare the relative cost between various control 

techniques and rules. The cost effectiveness of a rule is estimated by dividing the 

annualized cost of a control by the estimated emission reductions. 

Revised Proposed New Rule 4566 (Organic Material Composting Operations) would 

require operators who manage these materials to reduce VOC emissions through 

mitigation measures, which include the watering system, finished compost cover, and 

engineered emission control systems. In the case of composting operations, smaller 

facilities, which have fewer resources and lower total emissions, would be required to 

implement the watering system requirements. Medium facilities, that have greater 

resources and higher total emissions, would be required to implement both the watering 

system and finished compost cover requirements or an alternative mitigation measure 

that achieves equivalent VOC reductions. Large facilities would be required to 

implement an engineered control system that demonstrates at least 80% reduction, by 

weight, in VOC emission for organic material undergoing active composting. 

District staff has received cost information from stakeholders and vendors during the 

rule development process to aid District staff with the cost effectiveness analysis. The 

proposed rule requirements have been revised to mitigate significant impacts to the 

operators based on the cost-effectiveness of the control measures. 

II. REQUIREMENTS OF COST EFFECTIVENESS ANALYSIS 

The San Joaquin Valley Unified Air Pollution Control District conducts a cost 

effectiveness analysis of available emission control options before adopting each Best 

Available Retrofit Control Technology (BARCT) rule pursuant to California Health and 

Safety Code 40920.6(a). The purpose of conducting a cost effectiveness analysis is to 

evaluate the economic reasonableness of the pollution control measure or rule. The 

analysis also serves as a guideline in developing the control requirements listed in a 

rule. Absolute cost effectiveness of a control option is the added annual compliance 

cost in dollars per year divided by the emission reduction achieved in tons VOC 

reduced per year. This report presents the District staff's analysis of the absolute cost 

effectiveness of Revised Proposed New Rule 4566. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 4 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

For composting operations, the additional annual costs will be developed as follows: 

 Additional Cost = Cost to Implement Control ($/wet-ton) 

 × Throughput (wet-ton/year) 

= $/year 

Absolute Cost Effectiveness = Additional Cost ($/year) 

 Reductions (ton-VOC/year) 

= $/ton-VOC 

Incremental cost effectiveness is intended to measure the change in costs, in dollars 

per year, and emissions reductions, in tons of VOC reduced per year, between two 

progressively more effective control options or technologies. Incremental cost 

effectiveness examines the additional costs and emission reductions that can be 

achieved by adding a second control to the primary control. Because the incremental 

reductions from the controlled source operation are typically low, incremental cost 

effectiveness produces a much higher cost-to-reduction ratio than the primary control 

and should not be compared to the absolute cost effectiveness value. 

Revised Proposed New Rule 4566 would provide operators with the flexibility to comply 

with the VOC control requirements using equipment and resources appropriate for their 

facilities or developing mitigation measures of their own provided they demonstrate that 

such measures would achieve specified VOC emission reductions. Since operators 

have this flexibility, District staff assumed that the operators will choose the option with 

the best cost effectiveness for their particular operation. 

III. SOURCES OF COST DATA 

Since the September 2010 public workshop, District staff has continued to refine the 

draft rule requirements and work with the affected operators to update the cost data for 

the proposed mitigation measures, specifically for the watering system and finished 

compost cover application. Costs for composting operations were taken from two 

general categories of sources: composting operators in the San Joaquin Valley and 

vendors of composting emission control systems. The vendors who provided data are 

Engineered Compost Systems (ECS), W.L. Gore & Associates (GORE), and Managed 

Organic Recycling (MOR). The Valley operators who provided data are from Tulare 

County Compost and Biomass (Tulare), HWY 59 (Merced), Mt Vernon Composting & 

Recycling (Bakersfield), Community Recycling and Resource Recovery (Lamont), the 

City of Modesto Compost Facility, Recology Grover Environmental Products (Vernalis), 

E&J Gallo Compost Facility (Fresno). 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 5 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

A. Cost Data for Stockpile Requirements 

Based on discussion with the composting industry, the operators are already complying 

or would be able to comply with the proposed stockpile requirements. Currently, two 

existing composting operations with less than 100,000 wet tons per year (tpy) of organic 

material would be affected by the more stringent 10-day stockpile limit. As mentioned 

in the staff report, CalRecycle has more stringent stockpile requirements for chipping 

and grinding operations; however, there are currently no CalRecycle stockpile 

requirements for a site that is regulated as a compostable material handling operation 

or facility. The affected operators have indicated that they would be able to comply with 

the stockpile requirements most of the time unless there are any unforeseen events, 

such as equipment breakdown, where operators would need to cover the organic 

material with a tarp or implement other alternative mitigation measures. 

B. Cost Data for Composting Requirements 

1. Watering System Mitigation Measure 

District staff received several cost estimates from the industry operators, which are 

based on site-specific requirements. Operators provided costs data for additional 

equipment and infrastructure necessary to implement the watering system 

requirements, such as sprinkler piping, water pumping equipment, power/fuel, and 

water. Since the costs are based on site-specific conditions, there is a wide range of 

cost estimates to implement the control method. For example, one facility may have 

rights to water, while another would need to purchase the water needed for this control 

method. Staff assumed that the additional costs include increased labor, fuel, 

equipment, and maintenance. 

2. Finished Compost Cover Mitigation Measure 

The industry operators’ cost estimates were based on site-specific requirements, which 

include a wide range of cost estimates to implement the control method. For the 

finished compost cover control method, operators provided costs including possible 

additional front-end loaders, dump trucks, and conveyors. While some facilities may 

need the additional heavy equipment, other facilities may be able to use existing 

equipment for the control measures. It is assumed that the finished compost cover 

control method include increased labor, fuel, equipment, maintenance, and decreased 

amount of available finished compost for all applicable facilities. A loss of production 

revenue has also been factored into the cost estimates. 

To mitigate the impact of the draft rule and allow operators time to adjust to the 

practices, the draft rule would allow five years for full implementation, rather than a 

phase-in period. The five years would allow operators the flexibility to work around their 

operation and generate enough finished compost for the mitigation measure. The draft 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 6 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

would also allow operators to generate the finished compost cover using overs or 

finished compost, as defined in the revised proposed new rule. 

Figure 1 below shows the surface area of the finished compost windrow during the 

active phase as it marginally increases in volume and returns to its initial formation. As 

the material composts, moisture and carbon are lost so that the normal compost pile is 

reduced by 60 to 70% in volume by the end of the compost cycle. In addition, the 

windrow turners produce a consistent pile footprint. The data below are based on the 

field study results. 

Figure 1 - Comparison of Feedstock During Active Curing

0

10

20

30

40

50

60

70

2 3 4 5 7 10 15 22

Day

Surface Area (m2)

Finished Compost

Typical Windrow

Source: Appendix D to study results report (SJVAPSA, 2011) 

3. Engineered Control Systems 

District staff received cost estimates from several vendors in 2008 and most recently in 

2010, many of which have been involved with the rulemaking process since 2007. Brief 

descriptions of information received from the vendors are given below. Inclusion of 

these vendors in this report does not imply or serve as an endorsement of any vendor 

or product by the District. 

Engineered Compost Systems (ECS) provided cost estimates (T. O’Neill, e-mail 

correspondence to District, 2008) for the AC ComposterTM and CompDogTM (inflatable 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 7 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

form) cover systems (negative ASPs vented to biofilter). The key assumptions are as 

follows: 

• Capital costs of equipment, construction and start-up of control system 

(annualized over 10 years at 10%). 

• Annual cost also includes operation and maintenance (O&M) of all 

equipment, labor, electrical power, and fuel. 

• Paved surface for the AC ComposterTM system to be built, unpaved for 

the CompDogTM cover system. 

• Concrete pushwalls for both AC ComposterTM and CompDogTM cover 

systems. 

• Aeration vented to biofilter for both AC ComposterTM and CompDogTM 

cover systems. 

• Water management control system for separation of leachate and storm 

water to be built. 

• Covered bunker or enclosed reception area to be built 

• Water and electricity in place 

Gore & Associates, Inc. (GORE) provided cost estimates (B. Fuchs, e-mail 

correspondence to District, 2008) for a GORETM Cover System technology (positive 

ASPs with cover). The key assumptions are as follows:

• Annualized capital costs of equipment, construction and start-up of control 

system over 10 years at 10%, 

• Annual cost also includes operation and maintenance (O&M) of all 

equipment, labor, electrical power, and fuel, 

• Paved surface for the GORETM Cover System to be built, 

• Water management control system for separation of leachate and storm 

water to be built, 

• Paved tipping area to be built, 

• Water and electricity in place 

Managed Organic Recycling (MOR) provided cost estimates (J. Bouey, e-mail 

correspondence to District) for a positive ASP with cover system. The key assumptions 

are as follows:

• Annualized capital costs of equipment, construction and start-up of control 

system over 10 years at 10%, 

• Annual cost also includes operation and maintenance (O&M) of all 

equipment, labor, electrical power, and fuel, 

• Paved surface for the covered system to be built, 

• Water management control system for separation of leachate and storm 

water to be built, 

• Paved tipping area to be built, 

• Water and electricity in place 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 8 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

According to the vendors, the cost estimates are highly variable depending upon site 

specific requirements. For the purpose of this analysis, the cost estimates associated 

with the capture and control systems assume a flat and buildable site with all utilities in 

place. The District staff obtained as much data as available to establish the range of 

costs to implement an “engineered control system”. The collected cost estimations are 

for the purposes of the District’s rulemaking process for Rule 4566 only. The budgetary 

pricing from the mentioned vendors are the most current and best available information 

obtained at the time. 

4. Other Cost Data 

Other cost information that District staff has considered in the revised cost analysis are 

as follows: 

Tipping Fees: 

o Composting: City of Modesto indicated that tipping fees are around $18.35 

per ton for organic material (City of Modesto, public comment letter dated 

January 4, 2008). Discussion with CalRecycle also indicated an average of 

about $18 per ton for compost tipping fees, which could vary depending on 

source and type of material. However, tipping fees have been observed as 

high as $35 for facilities processing materials generated outside of the 

Valley. 

o Landfills: Landfill tip fees within the region currently range from $25 per ton 

to $30 per ton for organic material (an average of about $27.50 per ton) 

o Compost Alternative: Stanislaus Resource Recovery Facility is a Waste-toEnergy plant that charges a tipping fee of $28 per ton for organic material. 

As mentioned in the final staff report, composting helps local government agencies 

meet state solid waste diversion goals to preserve landfill capacity by reducing the 

amount of organic material sent to landfills for disposal. While diversion of materials 

from landfill disposal to composting will help ease the burden on landfills and achieve 

associated environmental benefits, the increase in composting will also increase VOC 

emissions associated with the operations and possibly NOx emissions from increased 

trucking of organic materials from outside of the SJVAB. The draft rule would seek to 

balance air quality goals with diversion goals by also considering the impact of the 

proposed mitigation measures to the industry on a cost per wet ton of organic material. 

 

IV. COSTS AND COST EFFECTIVENESS ESTIMATES 

Revised Proposed New Rule 4566 would require operators to comply with specific 

mitigation measures, based on the throughput categories for organic material 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 9 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

composting operations. Each of the throughput categories were determined based on 

the following: 

• Technological and economic feasibility of implementing the mitigation measures. 

• The additional cost to operators to implement the mitigation measures. 

The watering system requirements would apply to a composting operation with an 

organic material receiving volume of less than 200,000 tpy. For a composting operation 

with an organic material receiving volume of greater than or equal to 200,000 tpy and 

less than 750,000 tpy, an operator would be required to comply with both the watering 

system and the finished compost cover requirements. An operator that compost 

750,000 tpy or more or organic material would be required to implement a mitigation 

measure that demonstrates at least 80% reduction, by weight, in VOC emissions. Any 

facilities below 750,000 tpy also have the option to implement an equally effective 

alternative mitigation measure. 

District’s throughput determinations and cost analysis for the mitigation measures are 

presented below. 

A. Cost Analysis for Stockpile Requirements 

District staff did not receive information about additional costs to compost the materials 

within 10 days. For the stockpile holding times for composting operations with less than 

100,000 wet tpy of organic material, operators have indicated that it would be feasible 

to comply with the 10-day stockpile holding time and therefore, District staff considers 

any additional costs to be insignificant and did not conduct further analysis on the 

absolute cost-effectiveness. 

District staff also did not conduct a cost effectiveness analysis for composting 

operations with 100,000 wet tpy or more of organic materials since all of the operators 

already meet the three-day stockpile requirements. 

B. Cost Analysis for Watering System Requirements 

Table 1 summarizes the cost information received from operators for site-specific costs 

to implement the watering system requirements. The costs reflect the limited resources 

of the smaller facilities and a necessity to purchase equipment and water to implement 

the watering system requirements, resulting in a higher, per-ton implementation cost. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 10 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

Table 1: Watering System Costs

Feedstock Throughput (wet ton/yr) Range in Cost to Implement ($/wet ton)

Throughput < 200,000 $2.23 to $4.30 

200,000 ≤ Throughput < 750,000 $0.66 to $1.07 

Throughput ≥ 750,000 No facilities 

However, the additional costs, on per wet ton basis, shows that it is feasible for all of 

the facilities to implement the watering system. District staff has continued to work with 

the composting operators to reconcile the incremental cost for the watering system. 

Table 2 below shows a conservative estimate of what operators would incur as added 

costs to their existing operation. 

Table 2: Watering System Costs

Feedstock Throughput (wet ton/yr) Estimated Incremental Cost ($/wet ton)

Throughput < 200,000 $0.19 

200,000 ≤ Throughput < 750,000 $0.36 

Throughput ≥ 750,000 No facilities 

For composting operations with less than 200,000 tpy of organic material, the total 

annualized costs for the watering system would be about $95,107 per year, depending 

on availability and use of water. Based on 244 tons per year of VOC emission 

reductions, the cost effectiveness for composting operations with less than 200,000 tpy 

of organic material would be $390 per ton VOC reduced. 

 

The cost effectiveness analysis for composting operations with 200,000 tpy or more 

and less than 750,000 tpy of organic material is included with the finished compost 

cover analysis in the following section, since the costs to implement the watering 

system is even lower for this category. 

C. Cost Analysis for Finished Compost Cover Requirements 

Table 3 summarizes the cost information received from operators for site-specific costs 

to implement the requirement for a finished compost cover. These costs reflect the 

limited resources of the smaller facilities and a necessity to purchase additional 

equipment, resulting in a higher, per-ton implementation cost. Larger facilities may 

have greater equipment inventories and could possibly implement the rule requirements 

with existing resources. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 11 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

Table 3: Finished Compost Cover Costs

Feedstock Throughput (wet ton/yr) Range in Cost to Implement ($/wet ton) 

Throughput < 200,000 $7.88 to $10.81 

200,000 ≤ Throughput < 750,000 $3.33 to $3.53 

Throughput ≥ 750,000 No facilities 

 

Based on the costs above, it is not feasible for composting operations with less than 

200,000 tpy of organic material to implement the finished compost cover. 

For composting operations with 200,000 tpy or more and less than 750,000 tpy of 

organic material, the total annualized costs for the watering system and finished 

compost cover would range from $2,055,214 per year to $2,169,134 per year. The 

range in costs is based on different operational methods and equipment at the facilities. 

Based on a total of 859 tons per year of VOC emission reductions, the cost 

effectiveness for composting operations in this category ranges from about $2,393 to 

$2,525 per ton VOC reduced. 

D. Cost Analysis for Engineered Control Systems

Various engineered control systems have demonstrated at least 80% reduction, by 

weight, in VOC emissions. Table 4 summarizes the cost information received from 

vendors for hypothetical site-specific costs to install their specific control system. These 

costs reflect possible factors that could influence the installation and operation of the 

control system. In general, the cost per ton is lower for larger facilities since common 

equipment costs, like fans and ducting can be spread over a greater throughput. 

Revised Proposed New Rule 4566 would require any composting operation with an 

organic material receiving volume of 750,000 tpy or more to install an engineered 

control system. An operator may consider installing other technologies in lieu of using 

an engineered control system, provided that it is demonstrated to achieve the same or 

better control efficiency. Based on the data below, the trend shows that the cost of the 

systems becomes more cost effective as the throughput of the organic material 

increases. 

Table 4: Engineered Controls Costs

Feedstock Throughput (wet ton/yr) Cost Averages by Throughput ($/wet ton)

25,000 $16.03 

50,000 $13.41 

100,000 $11.13 

200,000 $9.71 

If all of the facilities were required to implement the engineered controls, the costs are 

estimated from $10 million per year to $17 million per year. Based on 2,174 tons per 

year of VOC emission reductions, the cost effectiveness ranges from about $4,724 to 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 12 Final Staff Report with Appendices 

For Revised Proposed New Rule 4566

$7,802 per ton VOC reduced. However, the cost to implement the engineered control 

systems is well above the cost to dispose the organic material at the landfill and would 

not be economically feasible for the operators to implement at this time. For 

composting operations that have the capacity to compost 750,000 tpy or more of 

organic material, the draft rule would require installation of the engineered control 

systems, since the costs are expected to decrease. 

Table 5 summarizes the Cost Effectiveness information based on draft rule 

requirements. The low - high range reflects the information received to date from 

stakeholders on possible implementation costs. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis 

C - 13 Final Staff Re

For Revised Pr

*N/A: Not applicable. There currently no facilities that process more than 750,000 tons per year of organic Therefore, no additional emissions reduction is expected from this category. 

Table 5 Cost Effectiveness Summary 

Facility 

Receiving 

Volume 

Actual 

Waste 

Received Control Method 

Emission 

Reductions 

Additional 

Cost (to 

Industry) 

Additional 

Cost (to 

Industry) 

Cost 

Effectiveness 

(wetton/year) (ton- VOC/year) ($/year) Low End ($/year) High End ($/ton-VOC Red) Low End 

Processes 

≥

750,000 N/A Engineered Controls N/A N/A N/A N/A 

Windrow 

Composting 

(Processes 

≥

200,000 tpy 

and < 750,000 

tpy) 

557,618 

Active Windrow (Finished 

Compost Cover and 

Watering System on 

Active - 60% control) 

859 2,055,214 2,169,134 2,393 

Curing Phase Windrow 

(No Control) 

No emissions reduction. 

Windrow 

Composting 

(Processes < 

200,000 tpy) 

500,565 

Active Phase Windrow 

(Watering System – 19% 

control) 

244 95,107 

Curing Phase Windrow 

(No Control) 

No emissions reduction. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: Cost Effectiveness Analysis August 18, 2011 

C - 14 Final Staff Report with Appendices

 For Revised Proposed New Rule 4566 

V. REFERENCES 

San Joaquin Valleywide Air Pollution Study Agency [SJVAPSA]. (2011). Comparison of 

Mitigation Measures for Reduction of Emissions Resulting from Greenwaste 

Composting. Fresno, CA: San Joaquin Valleywide Air Pollution Study Agency. 

Retrieved from 

http://www.valleyair.org/busind/pto/emission_factors/Criteria/Criteria/Composting/Comp

ost%20Study%20Draft%20Report.pdf (Report) and 

http://www.valleyair.org/busind/pto/emission_factors/Criteria/Criteria/Composting/Comp

ost%20Study%20Appendices.pdf (Appendices)