i---+ 

SihTE OF CALIFORIJIA PETE WILSON. covarnar 

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 1.2 1995 

Dear Ms. Marcus: 

Clarification of the Pesticide Element 

of the 1994 State Im~lementation Plan 

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 

inc iosure 

cc: Dave Howekamp. U.S. EPA, Region IX 

Andy Steckel, U.S. EPA, Region IX 

Jim Wells, Director, DPR 

Paul Gosselin. DPR 
State of California 

Memorandum 

rt( James D. Boyd, Executive Officer 

Air Resources Board 

2020 L Street 

Sacramento, California 95814 

Place : 

From Oepartmenl of 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-mplementation Plan (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:,t icide elernel-it to 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 

T o James D. Boyd, Executive Officer 

California Air Resources Board 

2020 L Street 

Sacramento, California 95814 

oats ,November 15, 1994 

Place : 

From Department of Pesticide Regulalion - 102 0 N Street , Room 10 0 

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 

Enclosures 
1, : James 0. 3cyd, Executi~re 'Qff ic=z 

California Air Resources Board 

2020 I, Street 

Sacramento, California 

f- : Oeparfmenl of PesiWde Rtgulallo~ - 1020 N Street, Room LOil 

Sacramento , California 95 913 - 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 

fmm 199Q levels by 20 percent by the year 20CS. Tbe pmporral 

was subject to a public review process which included 

- notificaticn of incyeated parties, Wee regionally 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 propm docs 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 MC emissions by 

20 percent is realistic and achiemble. 

-'Re anticipate refinements will be necessary to the plan and to 

the percent reduction goal since the pcees undertakad 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 bta call-in and tke pesticide use reports 

to determine peaticidal VOC inventory emissions. The emission 

inventories will not he able to be calculated until the data 

call-in is completed in 1995. Once the emission invtrztorfea are 

calcdated. a thorough evaluation will be conducted. The 

evaluation of tfis pesticidal VOC emission inventories will act 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 will be 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 

PAUL F. GOSSEUN 

W- Wells 

Director 

(916) 445-4000 

cc: Paul H. Gosselin, Assietant Director 
STATE 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-evaluation process, 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.ined in nine California air districts. 

Currently there are no data on the ROG content (also referreC zo 

State Implementation Plar for 

Agricultural and Commerci a1 Pes ti c: des 

November IS. 1994 
as 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 (17 CCR), 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-evaluation process. 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-evaluation of 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-evaluation procedure. 

State Implementation Plan for 

Agricul turf1 and Commercial Pesticides 

November 15, 1994 
The 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 .statement of 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 

Agri cul tur$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, 1994 
structural 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 

Aqricul tural and. Commercial Pesticides 

November IS, 1994 
reviewed 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 

(Pesticide Advisory 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 

Aqricul tural and Commercial Pesticides 

November 15, 1994 
identify 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 Implements tion Plan for 

Aqricul tur:l and commercial 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-county basis 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,ng in 

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 

Agricul tural and Commercial Pesticides 

November IS, 1994 
11. 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-evaluation of 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, 1994 
December 1998 Implementation of additional regulatory measures, 

if necessary, will take place to ensure that 

targeted pesticidal VOC reductions will occur. 

State Implementation Plan for 

Agri cul tural and Commercial Pesticides 

November 15, 1994 
Cnlqorniu Environrner~tal Protecliorl Agency I Sf ate 01' ~l'alifor;tia 

J:~II)c.\ bl S(roc k. ,\,,I VCI~JII, /,I, /,,I! WO,I~",,,,,(,I /?,,I,,, I~,,,, -- I'cIC* ~'Il\Ol~, (;,4,~,~vtl,~, 

DEI'A K'I'M tlN'I' OF I'ESTICI DE REGULATION 

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

NOTICE OF PUBLIC HEARING 

DEPARTMENT OF PESTICIDE REGULATION 

NOTICE IS HEREBY GIVEN that the Department of Pesticide Regulation (DPR) will 

conduct a public hearing on the draft pesticide element of the state implementation 

plan (SIP). The purpose of the hearing is to receive comments on the draft plan to 

control agricultural and commercial structural pesticidal sources of volatile organic 

compounds (VOC). Following the hearing, DPR will adopt a commitment to adopt 

by November 1995 final regulations based on the draft plan. This commitment will 

be submitted to the U.S. Environmental Protection Agency by November 15, 1994 

as a SIP revision that will achieve a reduction of between 20 and 45 percent in 

pesticide VOC emissions. Based on comments received at and prior to the hearing, 

the commitment may differ from the draft plan. It is important to point out that 

the final regulations will not be adopted until 1995. Those regulations will be 

noticed, public comments will be received, and additional hearings or workshops 

may be held prior to adoption. 

The public hearing will be held as follows: 

Date: November 4, 1994 

Time: 10:OO a.m. 

Location: 

Department of Pesticide Regulation 

1020 N St. 

Room 102 (Board Room) 

Sacramento, Califorriia 

Ba,ckqround 

The federai Clean Air Act Amendments of 1990 (CAAA; 42 U.S.C. section 7401 

et sea.) requires states to develop SIPS for attaining and maintaining air quality 

standards for air pollutants such as ozone. In cooperation with local air districts, 

the Air Resources Board periodically publishes an emission inventory of all sources 

of air pollutants in each air basin and each county within that basin. Pesticide 

application has been identified as a source of VOCs in many California air basins. 

VOCs are precursors to tropospheric ozone formation which is harmful to both 

human health and vegetation. . ~ 
Draft Pesticide Element of the 

State lmplementation Plan 

October 3, 1994 

Page Two 

The drafLpesticide element of the SIP has been prepared to address the following: 

The proposed requirements of Section 52.2960 of Title 40 of the 

Federal Code of Regulations (the proposed Federal Implementation 

Plan measure for reducing VOCs from pesticides); 

Attainment Demonstration--CAAA Section 1 82(c)(2)(A) requires the 

1994 SIP to demonstrate attainment of the federal ozone standard by 

each nonattainment area's attainment date; 

Post 1996 Rate-of-Proqress--CAAA Section 182(c)(2)(B) requires 

states to submit a plan that provides for a reduction of VOC emissions 

after 1996 through 201 0. 

Summarv of Plan 

This draft plan is designed to reduce VOC emissions from agricultural and 

commercial structural pesticide applications by 20 percent from the 1990 baseline 

emission inventory by the year 2005. However, the final plan and regulations 

adopted by DPR may differ from the draft plan and may require a reduction of 

between 20 and 45 percent in pesticide VOC emissions. The draft plan includes 

developing VOC content data for each formulated pesticide, establishing target 

VOC reduction levels and dates, and identifying voluntary and mandatory measures 

to reduce VOCs. It is expected that most of the reductions will occur as a result 

of ongoing activities such as continued adoption of integrated pest management 

(IPM) programs, pesticide users switching to low VOC formulations, and 

registration of new products designed to be used at very low rates. If ongoing 

activities and voluntary measures do not meet the interim reduction goals, 

mandatory measures will be adopted. Mandatory measures would focus on 

pesticides with greater than average VOC emissions and possibly VOC content, 

and would be implemented in two phases depending on the amount of reduction 

that has been achieved by voluntary measures. The first phase would require a 

written recommendation by a pest control advisor to be kept on file for the use of 

pesticides targeted for reduction. The recommendation must state that there are 

no other viable pest management techniques available that would result in lower 

VOC emissions. The second phase would prohibit use of targeted pesticides in the 

month(s) that the VOC reduction goal IS not being met. 
Draft Pesticide Element of the 

State Implementation Plan 

October 3, 1994 

Page Three 

The goal-will be to reduce pesticidal VOC emissions in a way that minimizes 

disruption of pest management of agricultural and structural pests. Pesticidal 

products that have been reformulated to lower a VOC content or that are part of a 

reduced risk pest management system will be exempt from the mandatory phase. 

In addition, significant pesticidal VOC emissions resulting from new infestations 

may be exempt from the calculation of VOC emissions. 

Authority 

The pesticide element will be adopted under the authority of the California Food 

and Agricultural Code. 

Review Period 

The public review period for the draft pesticide element of the SIP is from 

October 5, 1994 to November 4, 1994. You may submit written comments (or 

direct questions) to the Department contact person listed below. Written 

comments will be accepted until 5:00 p.m. on Fridav, November 4, 1994. At the 

hearing, interested members of the public may present comments orally or in 

writing. 

Availabilitv of Documents and Contact Person 

The draft pesticide element can be viewed at the following locations at least 

30 days prior to the scheduled hearing: 

Kern County Air Pollution Control District 

2700 M Street, Suite 290 

Bakersfield, California 93301 (805) 861 -2593 

Mojave Desert Air Quality Management District 

15428 Civic Drive, Suite 200 

Victorville, California 92392 (61 9) 245-1 661 

Sacramento Metropolitan Air Quality Management District 

8475 Jackson Road, Suite 21 5 

Sacramento, California 95826 (91 6) 386-6 1 80 
Draft Pesticide Element of the 

State Implementation Regulation 

October 3, 1994 

Page Four 

San Diego Air Pollution Control District 

9 1 50 ~hesa~eake Drive 

San Diego, California 921 23-01 096 (61 9) 694-3307 

San Joaquin Valley Unified Air Pollution Control District +. 

1999 Tuolumne Street, Suite 200 

Fresno, California 93721 (209) 497-1 075 

South Coast Air Quality Management District 

2 1865 East Copley Drive 

Diamond Bar, California 91 765 (909) 396-2000 

Ventura County Air Pollution Control District 

702 County Square Drive 

Ventura, California 93003 (805) 645- 1400 

Department of Pesticide Regulation 

If you would like a copy of the draft pesticide element or have any questions about 

the hearing, please contact Mark Pepple, Environmental Monitoring and Pest 

Management Branch, Department of Pesticide Regulation, 1020 N Street, 

Sacramento, California 9581 4-5604, or call at (91 6) 324-41 00. 

Paul H. Gosselin 

Assistant Director 

Division of Enforcement, Environmental 

Monitoring, and Data Management 

(9 1 6) 445-3984