SihTE OF CALIFORIJIA PETEWILSON. covarnar

i---+ 

### AIR 

### RESOURCES ~OARD 2020 L 

### STREET P.O. BOX 2815 SACRAMENTO. CA 95812 1-.

May 

### 11, 1995


### RECEIVED

Ms. Felicia Marcus Regional Administrator U.S. Environmental Protection Agency 75 Hawthorne Street San Francisco, Califcrnia 94105 

## MAY 

## 1.21995

Dear Ms. Marcus: Clarification of the Pesticide Element of the 1994 State Im~lementationPlan
I am writing to transmit a 

### clarification by the California Department of Pesticide Regulation (DPR) of the pesticide element of the California State Implementation Plan (SIP) for Ozone, submitted to the U.S. Environmental Protection Agency (U.S. EPA) on November 15, 1994. The enclosed letter from DPR clarifies that in the SIP, California has committed to adopt and submit to U.S. EPA by June 15, 1997, any regulat.ions necessary to achieve the emission reductions from pesticides specified in the letter. If there are any questions regarding this transmittal, please contact Mr. Dean Saito, Manager, Southern California Liaison Section, at (916) 322-8279, or Mr. Jim Nyarady of his staff at (916) 323-5184. Sincerely,

gvJames D. Boyd Executive Officer

inciosure

cc: 

### Dave Howekamp. 

### U.S. 

### EPA, Region 

### IX Andy Steckel,U.S. 

### EPA, Region 

### IX Jim Wells, Director, DPR Paul Gosselin. DPRState of California 

### Memorandum

rt( James D. Boyd, Executive Officer Air Resources Board 2020 

### L Street Sacramento, California 95814 Place :

From Oepartmenlof Pesticide Regulation - 1020 N Street, R~~~ 100 Sacramento, California 95814-5624

Subiecl 1994 State Implementation Plan

In the interest of expediting approval of California's 1994 State I-mplementationPlan (SIP)by the U.S. Environmental Protection Agency (U.S.EPA), 

### I am writing to clarify the pesticide element of the SIP, pursuant to U.S. EPA's April 21, 1995, letter to me signed by David P. Howekamp. The clarification is as follows: the Department of Pesticide Regulation commits to adopt and submit to U.S. EPA by June 15, 1997, any regulations necessary to reduce volatile organic compound emissions from agricultural and commercial structural pesticides by specific percentages of the 1990 base year emissions, by specific years, and in specific nonattainment areas I

(described in 40 CFR 81.3051, as listed in the following table: Reductions from 1990 Baseline

Because the Air Resources Board is responsible fo-submitting the SIP on behalf of the State, I am reques~:iny tyhat you formally sui~rnlt rhis clar-if ication of the SIP pe:,ticide elernel-itto the J EPA.

Ozone Nonattainment Area Sacrame~~to Metro San Joaquin Valley South Coast Southeast Desert
Ventura 1996 8% 8% 2002 16% 16% 1999 12% 12% 2005 20% 20% 8% 8% 8% 12%
12% 16% 16% 20% 20%

### James D. 

### Boyd

.- 

### May 9, 1995 Page 2



### If you have any questions, please feel free to contact me, or have your staff contact Paul Gosselin, of my staff, at

(916) 445-3984. Thank you for your assistance with this matter.

ORIGINAL SIGNED Bb



### James W. Wells Director

(916) 445-4000

cc: 

### David P. 

### Howekamp, U.S.

### EPA, Region IX Paul Gosselin bcc : 

### Jim Nyarady, ARB 

### Elin D. Miller, DPR

## Memorandum

To James 

### D. Boyd, Executive Officer California Air Resources Board 2020 

### L Street Sacramento, California 95814 oats ,November15, 1994

Place :

From Department of Pesticide Regulalion
- 1020 N Street

### , Room 100 Sacramento, California 95814-5624

SU~I~CI State Implementation Plan f~r Agricultural and Commercial Pesticides

The California Department of Pesticide Regulation has completed the State Implementation Plan for Agricultural and Commercial Structural Pesticides. 

### A copy of the Plan is enclosed for official submission to the United States Environmental Protection Agency.


### I have also included a copy of the public hearing notice and proofs of publication from various newspapers in California. Thank you for your assistance on this matter.

James W. Wells Director

(916) 445-4000 Enclosures1, : James 0. 3cyd, Executi~re 'Qff ic=z California Air Resources Board 2020 I, Street Sacramento, California

f- : Oeparfmenlof PesiWdeRtgulallo~ 

## - 1020 

### N Street, Room LOil Sacramento, California 95913

# -5624
-i~r: VolatiIe Orsanic Ccnpcund Emission Reduction Commitxeat

In August 1994, L!e Department a? Pesticide Regulaticn 

## (3~k) pr~osed a plan to rezuce volatile organic compcmc (VOC) emissions frcs aqicxltural and commercial struczural pesticides fmm199Q levels by 20 percent by the year 20CS. Tbe pmporral was subject to a public review process 

### which included 

## - notificaticn of incyeated parties, Weeregionally lccated workshops, and a formal public heariig. The pbllc review process ended on November 4. After consideration 

### &'public comment, DPR has decided to maintsFn its goal to reduce VOC 

### emissions from agricultural and commercial st=ctural pesticides by 20 percent from 1990 levels by the year 2005- The percent reduction will be based 

### on a linear extrapolation from the base year of 1990 ts the year 2005. Since pestici&s are a newly regulated source under the 

### Clean Air Act, the propmdocs not: have an 

### histarical basis to fully urderstand what reductions are feasible and the impacts 

### of regulatory measures. This raises general cmcern about the lack of data to determine what level 

### of reduction can be eqected 

### fmor these sources. However, 

### I am confident that the plan which establishes the goai to reduce pesticidal MCemissions by 20 percent is realistic and achiemble. -'Re anticipate refinements will 

### be necessary to the 

### plan and 

### to

the percent reduction goal 

### since the pceesundertakad to reduce pesticidal VCC smiosioma is contingent upcn using data which will 

### nor available until 1995. Tha plan relies 

### heavily 

### on use of information fnm

### the btacall-in and tke pesticide use reports to determine peaticidal VOC inventory emissions. The emission inventories willnot he 

### able to be calculated 

### until the 

### data call-in is completed in 1995. Once the emission invtrztorfea are calcdated. a thorough evaluation willbe conducted. 

### The evaluation of 

### tfis pesticidal VOC emission inventories willact

I

# _ .. .--

. -

.. . - - . - --

. .._ -. . --

. -- -- * CDFH BROHDCQST TEL: 916-322-6074 Nov 0%94 10:38 t40.003 P.01 

### C

d

James D. Boyd November 8, 1994 Page Two

the foundation to determine the validity of the percent reduction pal and the plan. Therefore, we consider the plan and the goal to reduce pesticidal VOC emissions by 20 percent an interim

. commitment. The plan to reduce agrjcultural and commercial structural pesticide VOC emissions willbe forwarzzd to your office by November 14 

### in order to meet the November 15 deadline- The plan will contain essentially the same 

### framework as the August 1994 proposal with some modifications. If you have any questions, please call me, or you may contact Paul Gosselin, of my staff, at 445-3984.

ORIGINAL SIGNED BY 

### PAULF. GOSSEUN

W-Wells Director (916)445-4000

cc: Paul H. Gosselin, Assietant DirectorSTATE IMPLEMENTATION PLAN FOR AGRICULTURAL AND COMMERCIAL STRUCTURAL PESTICIDES
BACKGROUND 

### This plan is designed to reduce volatile organic compound (VOC' emissions from agricultural and commercial structural pesticid? applications by a maximum of 20 percent from the 1990 baseline emission inventory to the year 2005. 

### The reduction in pesticidal VOC emission will occur on a linear basis extrapolated from ths 1990 baseline emission inventory. The plan will be implemented only in counties located in air districts which have formally adopted a State Implementation Plan which references VOC reductions from this plan. The plan offers the flexibility to achieve reductions of less than 20 

### percent by the year 2005 

### in air districts if less pesticidal VOC emission reductions are needed. The critical aspects of the plan are in effect and enforceable where applicable. These aspects include the implemeritation of :he pesticide product re-evaluationprocess, the collection of pesticide use reports, consultation with advisory groups, and promotion of integrated pest management programs. In the ever: that additional regulatory measures are necessary to achieve targeted VOC reductions from agricultural and commercial structural pesticide use, in accordance with the Department of Pesticide Regulation' s (DPR)California Environmental Quality Act functional equivalency regulatory program, potential environmental impacts will be considered along with reasonable mitigation measures and reasonable alternatives that would minimize or reduce any identified significant adverse environmental impact that reasonably could be expected to occrr as a result of the regulations. The basis for this plan is the concern about the release into :he atmosphere of VOCs from the use of pesticide products. The us? of pesticides may contribute to tropospheric ozone formation which is harmful to both human health and vegetation. "Pesticide 

### application" has been identified as a source of reactive orgaz:c compounds (ROGs) in many California air districts. ROGs are precursors to ozone formation. Based on the 1989 Emission Inventory, pesticides are estimated to account for from 0.3 tc 

### 32.1 percent of total ROGs in 41 

### counties in California. Thesi 41 

### counties are conta.inedin nine California air districts. Currently there are no data on the ROG content (also referreC zo

State Implementation Plar for Agricultural and Commercia1 Pestic: des November IS. 1994as the volatile organic compound, or VOC content) of pesticides formulated for agricultural or commercial structural use in California. The initial step of the plan establishes a method to accurately determine the VOC content of pesticide products and to calculate pesticidal VOC emissions. This plan will refer to the VOC content of a pesticide as a VOC Emission Factor. Pesticide product registrants are required to determine the VOC Emission Factors of their products either by analyzing products using the thermogravimetric analysis (TGA)method or by assuming all ingredients in the product except water are VOCs. The VOC Emission Factor will allow an accurate method to calculate pesticidal VOC emissions. California is fortunate to have a reporting system for pesticide use which, in conjunction with the VOC emission factor, allows for an accurate determination of pesticidal VOC emission. To determine the actual VOC contribution of individual agricultural and structural use pesticides, the VOC Emission Factor of each formulated product will be multiplied by the amount of that product used in a given time period. The Pesticide Use Report will be used as the reference for the amount of pesticide used. Additional VOC Emission Factors may be used to calculate relative emissions provided adequate data are provided. For example, data documenting that a change in a specific application technique of a specific pesticide from 1990 lowers emission could be a supplemental VOC Emission Factor. In cooperation with DPR, the California Air Resources Board (ARB) will develop a baseline inventory of estimated 1990 pesticidal VOC emissions based on 1991 pesticide use data, adjusted to represent the 1990 base year, and on the VOC emission potential data. This baseline inventory may be adjusted if empirical data are developed to determine the impact of temperature, treated substrate (foliage, soil, water, etc.), application technique, and other conditions on VOC emissions. The plan will reduce pesticidal VOC emissions in a way that minimizes disruption of pest management of agricultural and structural pests. The focus of the plan will be to utilize actual pesticide VOC emission data to guide changes in pest management practices to achieve VOC reductions while recognizing the ne-d for pest management. The plan will account for pesticidal VOC emission reductions through lower VOC Emission Factors (e.g., reformulation of pesticide products, alternative
State Implementation Plan for Agricultural and Commercial Pesticides November 15, 1994

### technologies that reduce emission) and changes in pesticide use practices (e.g.,increased adoption of integrated pest management techniques, use of lower VOC containing products)



### . The VOC Emission Factor data and the pesticidal VOC emission inventories will provide the basis to determine whether the 20 percent reduction goal is achievable, realistic, and justifiable. The data and inventories will provide the basis to determine what additional regulatory measures are needed to achieve targeted pesticidal VOC reductions.

PLAN 

### The purpose of this plan is to reduce agricultural and commercial structural use sources of pesticidal VOCs. It is not intended to apply to pesticides that are subject to consumer products' regulations in Title 17 of the California Code of Regulations (17CCR), sections 94507-94517. This plan is also not intended to apply to pesticides intended for use outside of California.
I. Re-evaluation of Pesticide Products
A. VOC Emission Factor 

### The first step of the plan involves determining the amount of VOC in each pesticide product. The amount of VOC in a pesticide is referred to as the- VOC Emission Factor. Authority exists for the collection of VOC Emission Factors through the re-evaluationprocess. The re-evaluation of agricultural and structural pesticides requires registrants of these products to submit data on the VOC Emission Factor of their products. The re-evaluationof agricultural and commercial structural pesticides began in April 1994 and will be completed by December 1995. The VOC Emission Factor of each product is determined either by conducting a specified analytical method or by assuming all ingredients in the formulation except water (water subtraction method) are VOCs. All registrants of agricultural and commercial structural use pesticides are required to submit VOC Emission Factor data for their product pursuant to a re-evaluationprocedure.

State Implementation Plan for Agricul turf1 and Commercial Pesticides November 15, 1994The requirements of the re-evaluation are described in an April 29, 1994 letter from DPR to registrants as amended by a June 9, 1994 addendum to the April 29, 1994 letter from DPR to registrants. The analytical method is the TGA method which is described in the protocol entitled, "Estimation of Volatile Emission Potential of Liquid Pesticides by Thermogravimetry." The data and information which must be submitted from the TGA study is listed on the "VOC Data Submission Form." This method was chosen after conducting workshops and consultation with analytical laboratories and the 

### ARB. The method provides an accurate and cost-effective means of determining volatility. In addition to the data and information on the VOC Data Submission Form, registrants are also required to submit an accurate statement of formula for each product included in the re-evaluation. The VOC Emission Factor of each product determined by the TGA method will be corrected for the water content of the product and the percentage of any exempt compounds. The exempt compounds are the same as those listed in the proposed federal implementation plan published in the Federal Register on May 5, 1994. The VOC Emission Factor of each product determined by the TGA method will also be corrected for the water content or any exempt chemicals present in any trade name inert ingredient in the primary pesticide product if DPR receives a .statementof formula for the trade name inert ingredient. In addition, the VOC Emission Factor of each product determined by the water subtraction method will also be corrected for the water content present in any trade name inert ingredient in the primary product if DPR receives a statement of formula for the trade name inert ingredient. If the trade name inert ingredient is purchased from another party, the other party may submit the statement of formula for that trade name inert ingredient directly to DPR along with a refekence that the data are being submitted pursuant to the re-evaluation of the primary pesticide product. If the required data and statement of formula for a product under re-evaluation are not received, the data package will be considered incomplete and the product will be given the highest VOC Emission Factor for the pesticide product.

State Implementation Plan for Agricultur$l and Commercial Pesticides November 15, 1994-. B. State Authority 

### Section 6220 of Title 3 

### of the California Code of Regulations (3 CCR) provides that the Director may, at any time, evaluate a registered economic poison to carry out the provisions of sections 12824, 12825, 12825.5, 12826, and 12827 of the Food and Agricultural Code (FAC)

. 

### Section 12824 requires the Director to endeavor to eliminate from use in the State any economic poison which endangers the agricultural or nonagricultural environment, and gives the Director authority to establish specific criteria to evaluate an economic poison with regard to the factors listed in section 12825. Section 12825 lists the factors the Director may consider in canceling or refusing to register a pesticide. Among these factors are (1) the economic poison has demonstrated serious uncontrollable adverse effects either within or outside the agricultural environment; and (2)when properly used, the economic poison is detrimental to vegetation except weeds, to domestic animals, or to the public health and safety. 3 

### CCR section 6221 was adopted to establish the criteria the Director may use to reevaluate pesticides. Included in these criteria are (1)public and worker health hazards, (2) environmental contamination, and (3) other information suggesting a significant adverse risk. 3 CCR section 6224 requires the Director to determine, during re-evaluation,whether additional restrictions on use are necessary or if actions such as suspension of use or cancellation of use are necessary.
11. Establishing the 

### 1990 Base Year Inventory and Tracking 

### The base year inventory will be created from the 1991 Pesticide Use Report and then adjusted by a factor to represent the 1990 base year. Under the Clean Air Act Amendments of 1990, the baseline inventory must be based on 1990 emissions. The Clean Air Act allows the use of other data if the data provide a more accurate basis to determine 1990 emissions. Full pesticide use reporting began in 1990. It is believed that the 1991 pesticide use report would be a more accurate source to determine 1990 pesticidal VOC emissions. The baseline inventory will be calculated by summing the estimated 1990 emissions of each agricultural and commercial

State Implementation Plan for Agricultural and Commercial Pesticides November 15, 1994structural use pesticide. Emissions will be calculated by multiplying the VOC Emission Factor value for each product by the adjusted use of that product in 1990. Emissions from products used in 1990 but with no reported use in 1991 will be estimated based on best available information. For products used in 1990 or 1991 that are no longer registered for use and thus not subject to the VOC data submission requirement, DPR will estimate a VOC Emission Factor value based on results of similar formulations or best available i.nf ormation. The same methodology will be used to determine pesticidal VOC emissions for subsequent years. By January 1996, data will be available to determine pesticidal VOC emissions for four years--1990 (adjusted) to 1993. The 1990 baseline year and subsequent year estimates may be further adjusted by additional VOC Emission Factors if additional information becomes available regarding the reactivity of compounds, the impact of temperature, moisture, deposition substrate, method of application, and other factors. Any additional VOC Emission Factor(s) will be pesticide product specific.
111. Reducing Pesticide VOC Emissions The goal of the DPR program is to reduce VOC emissions from the agricultural and structural use of pesticides by a maximum of 20 percent from 1990 to 2005 in air districts which have formally adopted a State Implementation Plan. A number of the critical aspects to achieve VOC emission reductions from the use of pesticides are in effect and enforceable. Subsequent program implementation will be based on an evaluation conducted in 1995 of the pesticidal VOC emission information and VOC Emission Factors.
A. Evaluation of Data
In 1996, the 1990 Baseline Emission Inventory and subsequent annual emission inventories will be analyzed to quantify the contribution of pesticides to VOC emissions and to create detailed pesticidal VOC emission inventories over time

(monthly or annually) in counties or portions of counties in each air district subject to this plan. Additionally, VOC ?missions data can be evaluated in relation to cropping pattern or key pest. The VOC Emission Factors will be

State Implementation Plan for Aqricultural and.Commercial Pesticides November IS, 1994reviewed in relation to the emission inventories. These lists will be used as a guide to identify pesticidal VOC reduction opportunities and as a basis for any additional regulatory measures.
B. Program Implementation The initial reductions in pesticidal VOC emissions will be gained from changes in pest management practices. Most of the changes will occur in the private sector in response to the information generated from this plan. Extensive consultation will be made with county agricultural commissioners (CACs),the U.S. Environmental Protection Agency (USEPA),and established advisory committees

(PesticideAdvisory Committee, Pesticide Registration and Evaluation Committee, Pest Management Advisory Committee)



### . The reductions in pesticidal VOC reductions will occur through: Switching use to lower VOC containing pesticides. The list of pesticide products and their VOC Emission Factor(s) will be distributed to CACs, commodity groups, University of California, pest control advisors, growers, pesticide registrants, and the Western Agricultural Chemical Association. A concerted effort will be made to facilitate the use of lower VOC containing pesticides.
2. Increased adoption of integrated pest managemeEt practices which can include certain reductions in the amount of pesticides used. 

### An ongoing effort in pest management has been to use the least amount of pesticide while maintaining control. Timing of pesticides to increase efficacy may also reduce additional applications.
3. Generic strategies to reduce pesticidal VOC emissions will be promoted. DPR will identify by crop pesticidal VOC reduction activities that have occurred since 1990. Reduction techniques will be publicized to CACs, pest control advisors, growers, and commodity groups to encourage continued and additional reductions.
4. For crops having pest management practices thaz result in high pesticidal VOC emissions, DPR will

State Implementation Plan for Aqricultural and Commercial Pesticides November 15, 1994identify and encourage substitution of viable alternative pesticides that reduce VOC emissions and identify strategies in concert with commodity groups and others (e.g.

### , Pest Management Advisory Committee) to increase adoption of Integrated Pest Management programs. 5. Registration and Promotion of Lower Containing VOC Pesticides A major avenue to achieve pesticidal VOC reductions will result from the availability of low VOC containing pesticide products. Lower VOC containing pesticide products can come from either reformulated pesticides or from new pesticide products which are alternatives. Mechanisms to ensure that the registration process at the federal and state level does not slow introduction of these products to the marketplace while protecting public health and the environment will be investigated.
6. Encourage development, documentation, and adoption of new technologies (e.g., application methods, application equipment, capture systems) that reduce VOC emissions. Adoption of validated technologies that reduce VOC emissions could result in additional VOC Emission Factor(s) being used in calculating pesticidal VOC emissions.
C. Development of Additional Regulations
A decision whether additional regulatory measures to ensure that reductions in pesticidal VOC emissions are achieved will be made by 1997. The determination that additional regulatory measures will be made if it is found that the existing program elements are not sufficient in achieving established VOC reductions and that additional VOC reductions from the use of pesticides are feasible. The exact structure of the additional regulatory measures will be based on the evaluation of VOC Emission Factors and emission data. However, such regulations would encompass the following points:
1. The regulatory provisions would only be applicable in counties located in air districts that adopted

State Implementstion Plan for Aqricultur:l andcommercial Pesticides November 15. 1994

### a State Implementation Plan which reference VOC reductions from this plan. Pesticide VOC emission inventories will be tracked utilizing the established methodology. The pesticidal VOC emissions will be tracked on a 

### county-by-countybasis within a regulated air district. Pesticidal VOC emissions resulting from control efforts for significant new pest infestations would be exempt from trend line analyses. Adequate time would be given for existing program efforts to take effect before regulatory measures are implemented. Clearly established pesticidal VOC reduction target levels will be established for the air district. The currently established target level is extrapolated on a linear basis from 1990 to 2005 to achieve a 20 percent reduction. After evaluation of pesticide VOC emission inventory data, the percent reduction goal may change. Regulatory measures, if necessary, would automatically go into effect if established pesticidal VOC reduction target levels are not achieved. A tiered set of restrictions, increasi,ngin severity, will be imposed in relation to target reduction levels. Pesticides which result in the highest pesticidal VOC emissions in that air district or county will be targeted for restriction. Restrictions on pesticide use will take into account the availability of alternatives that will result in less VOC emission, and whether the pesticide is part of a reduced risk practice.

State Implementation Plan for Agricultural and Commercial Pesticides November IS, 199411. 

### Pesticide products that have been reformulated to a 

### lower VOC 

### content will be exempt from prohibitions.
IV. Summary of Plan
April 1994 Initiate a re-evaluationof pesticide products to collect'the percent VOC content (VOC Emission Factor)

# . May 1995 Establish procedures to ensure timely registration of pesticides with low VOC content, in consultation with USEPA and the Pesticide Registration and Evaluation Committee.
December 1995 Complete re-evaluation. January 1996 Prepare and distribute the list of pesticide products and their VOC Emission Factors. Complete and distribute Pesticide Emission Inventories (1990 to 1993) for air districts subject to this plan. Analyze VOC Emission Factors and pesticide emission inventories to determine whether the 20 percent reduction goal is valid. Revisions to this plan may need to be made based on the analysis. August 1996 Distribute analysis of pesticidal VOC reduction successes. Voluntary strategies to increase pesticidal VOC reductions will be developed in conjunction with various groups (Pest Management Advisory Committee and Pesticide Advisory Committee)


## . November 1997 Evaluation of the pesticidal VOC emission inventories (1990 to 1995) will be made to determine the feasibility of achieving the target reduction goal. Alternatives' analysis will provide the basis as to whether additional pesticidal VOC reductions are feasible. A decision to develop additional regulatory measures will be made at this time.

State Implementation Plan for Agricul tural and -Commercial Pesticides November 15, 1994December 1998 Implementation of additional regulatory measures, 

### if necessary, will take place to ensure that targeted pesticidal VOC reductions will occur.

State Implementation Plan for Agricultural and Commercial Pesticides November 15, 1994Cnlqorniu Environrner~tal Protecliorl Agency I 

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### REGULATION J;IIIIC\ W.WCIIS. l)irrt~r,r

NOTICE OF PUBLIC HEARING DEPARTMENT OF PESTICIDE REGULATION

NOTICE ISHEREBY GIVENthatthe Departmentof Pesticide Regulation (DPR) will conduct a public hearingonthedraft pesticideelement of thestate implementation plan (SIP). The purposeof the hearingisto receivecomments onthedraft planto control agricultural and commercial structural pesticidal sources of volatile organic compounds (VOC). Followingthe hearing, DPR will adopt a commitment to adopt by November 1995final regulations basedonthe draft plan. This commitmentwill be submittedtothe U.S. EnvironmentalProtectionAgency by November 15, 1994 as a SIP revisionthatwill achieve a reductionof between 20and 45 percent in pesticideVOC emissions. Based oncomments receivedat and priortothe hearing, the commitment maydiffer fromthe draft plan. Itis importantto pointoutthat thefinal regulations will notbe adopted until 1995. Those regulationswill be noticed, public comments will be received, and additional hearings or workshops may beheldpriortoadoption. The public hearingwill beheldas follows:
Date: November4, 1994 Time: 10:OO a.m. Location: Departmentof Pesticide Regulation 1020N St. Room 102(Board Room) Sacramento, Califorriia Ba,ckqround
Thefederai Clean Air Act Amendments of 1990(CAAA;42 U.S.C. section 7401 et sea.) requires states to develop SIPSfor attaining and maintaining air quality standardsfor air pollutantssuchas ozone. Incooperationwith localair districts, theAir Resources Board periodically publishes an emission inventory of all sources of air pollutantsineach air basinand eachcounty withinthat basin. Pesticide application hasbeen identified as a source of VOCs inmany California air basins. VOCs are precursorsto tropospheric ozoneformation which is harmfulto both humanhealth and vegetation.

. ~Draft PesticideElementofthe State lmplementation Plan October 3, 1994 PageTwo

The drafLpesticide element ofthe SIP hasbeen prepared toaddressthefollowing:
The proposedrequirementsof Section 52.2960 of Title 40 ofthe Federal Code of Regulations (theproposed Federal Implementation Plan measurefor reducingVOCs from pesticides);
Attainment Demonstration--CAAA Section 182(c)(2)(A)requiresthe 1994SIPtodemonstrate attainment ofthefederal ozone standard by each nonattainmentarea's attainmentdate;
Post 1996Rate-of-Proqress--CAAASection 182(c)(2)(B)requires statestosubmita planthat providesfor a reductionof VOC emissions after 1996through 201 0.

Summarv of Plan
This draft planis designedtoreduce VOC emissions from agricultural and commercialstructural pesticide applicationsby20 percentfromthe 1990baseline emission inventorybytheyear 2005. However,thefinal planand regulations adopted byDPR maydiffer fromthedraftplan and may requirea reductionof between20 and 45percent inpesticideVOC emissions. The draft planincludes developing VOC contentdatafor eachformulated pesticide, establishingtarget VOC reductionlevels and dates, and identifyingvoluntary and mandatory measures toreduceVOCs. Itisexpectedthat mostofthe reductionswill occur as a result of ongoingactivities such ascontinued adoption of integrated pest management (IPM)programs, pesticide usersswitchingto lowVOCformulations, and registrationof new productsdesignedtobe used atvery low rates. Ifongoing activities andvoluntary measuresdo notmeetthe interim reductiongoals, mandatorymeasures will beadopted. Mandatory measureswould focus on pesticideswith greaterthan average VOC emissions and possiblyVOC content, and would be implemented intwophases depending ontheamount of reduction that has been achieved byvoluntary measures. Thefirst phasewould require a written recommendationbya pestcontroladvisor to be kept onfile forthe use of pesticides targeted for reduction. The recommendationmuststate thatthere are noother viable pest managementtechniques availablethat would result in lower VOC emissions. The second phase would prohibit useoftargeted pesticides inthe month(s)thatthe VOC reduction goal IS not being met.Draft Pesticide Element ofthe State Implementation Plan October 3, 1994 PageThree

The goal-will beto reduce pesticidalVOC emissions inawaythat minimizes disruption of pest managementof agriculturaland structural pests. Pesticidal productsthat have been reformulatedto lower aVOC contentorthat are partof a reducedrisk pest managementsystem will beexempt fromthe mandatory phase. Inaddition, significant pesticidalVOC emissions resultingfrom newinfestations may beexemptfrom the calculation of VOC emissions. Authority
The pesticideelement will be adopted underthe authorityofthe California Food and AgriculturalCode.
Review Period
The public review periodfor thedraft pesticide element of the SIP is from October 5, 1994to November4, 1994. You maysubmit written comments (or direct questions)tothe Department contact personlisted below. Written comments will beaccepted until 5:00 p.m. on Fridav, November 4, 1994. Atthe hearing, interested members of the public maypresent comments orally or in writing.
Availabilitv of Documents and Contact Person
Thedraftpesticide element canbeviewed atthefollowing locations at least 30 days priortothe scheduled hearing: Kern County Air Pollution Control District

2700 M Street, Suite290 Bakersfield, California 93301 (805)861-2593 Mojave Desert Air Quality Management District

15428Civic Drive, Suite 200 Victorville, California 92392 (61 9)245-1661 Sacramento MetropolitanAir Quality Management District

8475Jackson Road, Suite 215 Sacramento, California 95826 (91 6) 386-6180Draft Pesticide Element ofthe State Implementation Regulation October 3, 1994 Page Four

San DiegoAir PollutionControl District 9 1 50 ~hesa~eake Drive San Diego, California 92123-01096 (61 9) 694-3307 San JoaquinValley Unified Air Pollution Control District
+. 1999Tuolumne Street, Suite 200 Fresno, California 93721 (209)497-1075 South Coast Air Quality Management District

21865 East Copley Drive Diamond Bar, California 91765 (909)396-2000
Ventura CountyAir Pollution Control District

702 County Square Drive Ventura, California 93003 (805)645- 1400 Department of Pesticide Regulation
If you would like a copy of thedraft pesticide element or haveany questionsabout the hearing, please contact Mark Pepple, Environmental Monitoringand Pest Management Branch, Departmentof Pesticide Regulation, 1020 N Street, Sacramento, California 95814-5604, or call at (91 6) 324-41 00.

Paul H. Gosselin Assistant Director Division of Enforcement, Environmental Monitoring, and Data Management (91 6) 445-3984