Final Staff Report and Recommendations on Agricultural Burning



## Chapter 3

Technical and Economic Analysis of Affected Crop Categories and RecommendationsFinal Staff Report and Recommendations on Agricultural Burning This page intentionally blank



## .San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-1 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 

### Chapter 3: Technical and Economic Analysis of Affec ted Crop

Categories and Recommendations

In 2005 and 2007, District staff evaluated several alternatives to open burning for the crop categories identified in the CH&SC. While most of those crops and materials are already subject to the requirements o f Rule 4103 and are prohibited from being burned, there were no technologically or economically feasible alternatives available for some crops and materials at the time. District staff has reviewed the technologically feasible alternatives for each of the affected agricultural crop in the SJVAB. From those alterna tives, District staff has evaluated what appears to be the most viable and li kely method to open burning for many of the affected crops in the SJVAB. Fur ther discussion on emissions and costs for open burning and the alternatives for these crops are presented in the following chapters of this report. This chapte r analyzes the crop categories that are allowed to be burned until June 1, 2010 an d presents the findings for those crops.

During the research process, District staff has wor ked closely with the ag industry representatives and other agencies to address the b urn prohibition requirements for various crops. The ag industry representatives have conducted extensive research and effort to provide District staff with key information to help move this project forward. The information used for further analysis include economic data, costs for chipping and burning, descriptions of ope rations, and other related documents. The ag industry has made significant pro gress over the years in reducing emissions from open burning through resear ch, development, and implementation of viable alternative methods. Howe ver, there are concerns for some crops where growers have not been able to iden tify technologically or economically feasible alternatives.

The basis of the economic feasibility analysis is a comparison of compliance costs of the likely non-burning alternative to prof it rates (Return on Sales, or ROS) of the industry sector. To evaluate the econo mic feasibility of burn prohibitions on orchard pruning/removal operations for subject crops, the District engaged their regulatory economic consultant, Appli ed Development Economics, Inc. (ADE). ADE has familiarity with and constant access to comprehensive and applicable profitability and revenue data. Complia nce costs for non-burning disposal alternatives were estimated by District en gineers and ag industry representatives using a variety of data sources and methodologies. The development of compliance cost estimates is present ed in Chapter 6.

Profits for subject industry sectors were estimated by ADE by applying published profitability rates for crops to estimated revenues . Profit rates, production,San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-2 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning acreage, and prices were taken from the USDA Ag Cen sus 2007, University of California Cooperative Extension, and California Ag ricultural Commissioners’ Annual Report, as well as data compiled commerciall y by Dun and Bradstreet. While the profitability rates used in the analysis below are long-term averages from Dun and Bradstreet, it should be noted that in dustry stakeholders engaged in extensive effort and provided significant input regarding the recent profitability of certain crops. These data are presented in Appe ndix E and confirm the District’s conclusions on the significance of econo mic impacts (i.e., greater or less than 10% of profit) on each crop operation.

The analysis was conducted for each crop/operation (nut orchard prunings, citrus orchard removals, vineyard removals, and removal of other orchards such as stone fruit). The calculations are shown on the ta bles in Appendix E, and the results of the analysis are shown below.

Summary of Results, Economic Feasibility

Crop Operation Farm Scale,

Acres Cost/Profit, % Vineyard – Wine Grapes <100 55.2% – 82.0% Vineyard – Wine Grapes ≥ 100 46.9% – 69.6% Vineyard – Raisin & Table Grapes <100 22.6% – 33.6% Vineyard – Raisin & Table Grapes ≥ 100 19.2% – 28.6% Vineyard – Kiwi <100 11.1% – 16.6% Vineyard – Kiwi Vineyard

Removal

≥ 100 9.5% – 14.1%

Citrus <100 10.9% – 11.9%

Citrus Orchard

Removal ≥ 100 9.4% - 10.3%

Other orchards <100 7.0%

Other orchards Orchard

Removal ≥ 100 5.9%
Almond, Pecan, Walnut <100 10.0%
Almond, Pecan, Walnut Pruning ≥ 100 8.5%San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-3 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.1 VINEYARD REMOVAL MATERIALS

Summary and Recommendation

Table 3-1 Summary of Analysis

Vineyard

Removal

Materials Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Grapes (wine grapes only)

Farms Less

than100 acres Possibly

Biomass No. Wire

Issues. $762 -

$1,132 55.2%-82.0% No

Farms 100

acres or more Possibly

Biomass No. Wire

Issues. $762 -

$1,132 46.9%-69.6% No

Grapes (raisin and table grapes)

Farms Less

than100 acres Possibly

Biomass No. Wire

Issues. $762 -

$1,132 22.6%-33.6% No

Farms 100

acres or more Possibly

Biomass No. Wire

Issues. $762 -

$1,132 19.2%-28.6% No

Kiwi

Farms Less

than100 acres Possibly

Biomass No. Wire

Issues. $762 -

$1,132 11.1%-16.6% No

Farms 100

acres or more Possibly

Biomass No. Wire

Issues. $762 -

$1,132 9.5%-14.1% No

*Biomass power plants can accept vineyard removals given that wires are removed from the

vines.

Recommendation: District staff evaluated biomass power plants as an alternative to open burning of vineyard removal materials and other factors. The economic feasibility analysis is presented in Section E-1 of Appendix E. At this time, District staff recommends that vineyard removal materials continue to be allowed to be open burned based on the following reasons:

• There is currently no economically feasible altern ative to remove

the wire that is embedded in the cordon and canes t o prevent damage to the chipping equipment or prevent the wir es from going to the biomass power plants. Wire removal adds a s ignificant cost to the growers. Increasing the amount of materials going into

landfills is not considered a viable alternative as landfills are required to divert wood and green materials.

• Most chipping operators are not willing to chip an d haul away the vineyard removal materials or would charge a higher fee.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-4 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Description and Findings

Vineyards include both grape vines and kiwi vines b ecause both crops require support, such as the trellis systems to help keep t he fruits off the ground. Grape vines are used to produce table grapes, wine grapes or raisin grapes. The cultural practices and the type of trellis system u sed at a vineyard are based on the intended use of the grapes (table, wine, or rai sins) and other factors. In addition to the vine and trellis wire, a vineyard m ay contain cross arms, as well as metal or wooden stakes and posts. Treated stake s (sometimes with metal braces) cannot be chipped and must be taken to a la ndfill. The posts currently being used are predominantly made out of steel. Me tal stakes are removed before chipping and taken to a steel plant. The en d posts can also be made out

of redwood which can be burned.

According to ag representatives, disposal methods f or vineyard removal materials are the same for table, wine and raisins grapes. A grower will generally grow a crop to produce specifically table grapes, w ine grapes or raisin grapes. However, some vineyards provide the grower some fle xibility so that based on several factors, including market prices, a grower can determine well into the production year whether the grape crop will end up as table grapes, wine grapes or raisin grapes.

Depending on the disposal method with the vineyard removal materials, the materials that help support the vine can pose sever al issues for the grower during the removal process. In many cases, most of the foreign material can be removed from the vine. However, there are some sit uations where complete removal of the material, such as wire, can be diffi cult and expensive for the

grower. When too much wire is embedded into the vines, chip pers can refuse to chip the agricultural materials. If the wires were to be chipped along with the wood, the number of power plant operators that will accept such agricultural

materials can be limited.

According to biomass power plant operators, vineyar d removal materials are accepted. The only restriction with vineyard remov al materials is that wire is removed and treated posts are taken out. Substanti al amount of wire in the chipped material can cause problems for the biomass power plant. Other contamination (as long as not excessive) in the mat erial, such as dirt, need to be controlled but is not a major concern to the operat ors since some amount of dirt is expected of all agricultural fuel. It is genera lly not an issue if the chipped

materials are clean.

While growers can hire laborers to remove most of t he wires that connect the vines, it is not practical to remove the wire that is embedded into the cordon orSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-5 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning the canes. Ag representatives indicated that the r aisin vineyards are pruned in such a way that the remaining canes are wrapped aro und the vineyard wire to support the crop. In order to chip the materials f or fuel use at biomass power plants, ag representatives indicated that the wire must be cut more times (compare to open burn) and be removed completely fr om the vineyard or must be present only in very short lengths before it can be chipped. This presents an issue for vineyards where a cordon is created by wr apping the vine around the wire in the second year. As the vine grows, the wi re becomes more and more embedded in the vine, making it impossible to remov e. In some trellis systems, there may be as many as four wires embedded in the cordon. Ag representatives also indicated that chipping operat ors have reported the wire causing problems and getting wrapped around the mov ing parts of their machinery, and that biomass facilities prefer not t o receive material with wire because the wire causes havoc with their equipment.

Ag representatives have also indicated that getting the materials chipped according to the grower’s schedule has been an issu e because it could take weeks or months to have a field chipped, which may be too late to plant for the

next season.

3.2 ORCHARD REMOVAL MATTER FROM CITRUS, APPLE, PEAR

, QUINCE, AND FIG CROPS AND ORCHARD REMOVAL MATTER FR OM

A TOTAL OF 20 ACRES OR LESS

In 2007, ARB concurred with the District’s limited postponement to allow for the burning of orchard removal matter from 20 acres or less and other type of

orchard removals. Rule 4103 defines "Orchard Remov al Matter" as agricultural material generated by the removal of orchards. Thi s includes leaves, branches, trunks, roots, stumps and untreated branch support sticks. The rule prohibits burning of orchard removal material generated as a result of land use conversion from agricultural to nonagricultural purposes.

Since 2002, the Natural Resources Conservation Serv ice (NRCS) has encouraged growers to chip debris left from orchard or vineyard removals by providing a cost-share basis through the Environmen tal Quality Incentives Program (EQIP), which help reduce NOx, VOC, PM10, a nd PM2.5 emissions generated from open burning. The program also incl udes chipping of almond and walnut pruning, which will be discussed in Sect ion 3.7.3 of this chapter. According to NRCS staff, the payment rate has incre ased from $100 per acre to $150 per acre. In order for the growers to replant the field, the chipped orchard removal materials are typically removed from the fa rm to a biomass power plant or a composting facility. The chips could also be deposited on unpaved roads for dust control purposes. Based on NRCS data, the amo unt of chipped materialsSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-6 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning from the orchard and vineyard removal category aver aged about 270 acres in the SJVAB per year, from 2007 to 2009.

3.2.1 Orchard Removal Matter from a Total of 20 Acr es or Less

Summary and Recommendation

Table 3-2 Summary of Analysis

Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Orchard Removal Matter from 20 Acres or Less Catego ry*

Farms Less

than100 acres Biomass Yes $161 7.0% Yes

Farms 100

acres or more Biomass Yes $161 5.9% Yes

*Reduce Burn allowance to 15 acres per location per year. No case by case determinations for additional acreage.

Recommendation: District staff has completed the review process for the technologically feasible alternatives to open burning of orchard removal mat ter from a total of 20 acres or less. The economic feasibility analysis is present ed in Section E-2 in Appendix E. Biomass power plants appear to be the most tech nologically feasible alternative to open burning of orchard removal matt er; however, due to the limiting factor of increased cost per acre for smal ler acreage and availability of chipping operators, District staff believes that op en burning be allowed to

continue for small orchard removals. District staf f recommends that the current open burning limit be reduced to 15 acres or less o f orchard removal at a single location, per calendar year. District staff also r ecommends that there be no case by case determinations for additional acreage since the cost analysis shows that it becomes more expensive as the acreage becomes sm aller regardless of the

total size of the farm.

In addition chipping operator typically refuses sma ll jobs, making it difficult for many growers to remove small acreages of orchard re movals. The District has increasingly refused most requests for burns that a re over 15 acres. The District’s Compliance Department has indicated that several requests above 15 acres have been denied because the costs to chip an d remove the orchards were determined to be economically feasible.

District staff has found that limiting the acreage amount to 15 acres would be feasible based on the District’s cost analysis to c hip and haul the orchard removal materials to the biomass power plants, wher e the cost per acre appearsSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-7 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning to level out at about 15 acres or more. Further in formation on cost analysis can be found in the Costs section of this report. According to the burn applications, burn permits that were approved for less than 15 ac res make up for most of the burns, over 84%. According to some growers and chi pping operators, the cost per acre could level out to as low as 10 acres for some growers; however, District

staff believes that 15 acres is a reasonable limit based on the cost analysis and considering fluctuations in cost caused by location , fuel costs, and materials, and

other factors.

Description and Findings

Since June 2007, the District has provided limited burning allocation for orchard removal matter from 20 acres or less and has requir ed a case-by-case economic justification of the open burning alternatives from growers before evaluating and determining whether a burn permit may be issued for farms burning less than 20 acres but are greater than 100 cumulative acres. A RB concluded that the postponements will not substantially contribute to the violation of an applicable federal air quality standard, and discussed the imp ortant role of the District’s comprehensive smoke management program in preventin g impacts to nearby communities. However, ARB noted that orchard remov al of 20 acres or less from all other crop types must be implemented narrowly. This category includes all orchard type, except for citrus and pome fruits (ap ples, pears, and quince crops). As recommended above, figs would be considered as p art of this category.

Growers typically need to remove some orchards ever y few years to keep the farm productive. Growers, ag representatives and c hipping operators have expressed several concerns with the chipping of orc hard removal matter from small acreage. Generally, small acreage growers ar e not a priority for chipping operators because of amount of materials generated compared to the time it takes to travel and move the equipment to the field . Biomass power plant operators have indicated that the large chippers ar e doing jobs less than twenty acres with an understanding that the cost of chippi ng has gone up.

Chipping operators also charge a minimum fee (or mo ve-in fee) to the grower. As a result of the minimum charge, the per acre cos t for such small removals increases as the acreage becomes smaller. Based on the District’s cost analysis and information received from ag representatives, t he cost per acre appears to level out at a certain acreage. The fee could vary among chipping operators and is dependent on the availability of chipping contra ctors, storage at biomass power plants, the crop type and density, topography , soil type, and location. Given these considerations and the fact that most g rowers are already chipping the orchard removals above 20 acres, District staff has used a conservative estimate for chipping costs for the analysis.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-8 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Ag representatives have indicated that when chippin g operators work on small acreage jobs, growers are often forced to wait unti l the chipping operator plans to be in the area. This can cause significant delays in fumigation, land preparation, irrigation, and planting. Trees must be ordered a year in advance. When the land is not prepared in time for the trees to be pl anted, these young trees die, at a large cost to the grower.

For farms greater than 100 cumulative acres in the SJVAB, the District has required a case-by-case economic justification of t he open burning alternatives from growers before evaluating and determining whet her a burn permit may be

issued for less than 20 acres. District staff eval uated the economic feasibility of the alternatives based on the applications and copi es of receipts, written bids, or supporting information for the economic justificati on. District staff has found that the case-by-case economic justification varies sign ificantly, from net losses to the cost exceeding the ten-percent (10%) net profit thr eshold. Information provided by growers also supports the higher costs per acre for chipping of orchard removal for smaller acreages, which in the past has shown to be less economically feasible.

From June 2007 to February 2010, the District recei ved a total of 1088 applications for orchard removals of 20 acres or le ss per year. Of those applications, the District issued burn permits for 964 applicants of various farm sizes, including those that are greater than 100 cu mulative acres. However, based on the evaluation of the economic justificati ons, District staff issued burn permits for only 305 applications for farm over 100 cumulative acres. For the approved burn permits, the amount of acres burned r elative to the amount of acres farmed is equivalent to four percent (4%), or about 8,200 acres burned from a total of 196,400 acres. Based on this analy sis, the District has implemented narrowly the provisions for burning orc hard removals of 20 acres or

less.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-9 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.2.2 Fig Crops Orchard Removal Matter

Summary and Recommendation

Table 3-3 Summary of Analysis

*Analysis of fig crop will be considered as part of “Other Fruit Orchards”. Reduce Burn allowance to 15 acres per location per year. No case by case determinations for additional acreage.

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing of fig orchards and recommends that open burning of fig orchard removals be reduced to less than 15 acres at a sing le location, per calendar year after June 1, 2010. The economic feasibility analy sis is presented in Section E-2 of Appendix E. Fig orchard removals would be consi dered as part of the small other orchard removals category. District staff al so recommends that there be no case by case determinations for additional acreage.

Description and Findings

When fig orchards are removed, the trees are typica lly no longer productive and would be replaced with new fig orchards or are no l onger an economical crop and would be replaced with other crops. There are no fire blight issues or other concerns for fig crops. In addition, the orchard m aterials would be acceptable at biomass power plants as an additional fuel source. Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: District

Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS) Fig Crop*

Farms Less

than100 acres Biomass Yes $161 7.0% Yes

Farms 100

acres or more Biomass Yes $161 5.9% YesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-10 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.2.3 Citrus Crops Orchard Removal Matter

Summary and Recommendation

Table 3-4 Summary of Analysis

Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Citrus Crop*

Farms Less

than100 acres Biomass Some
operators $369 10.9%-11.9% No

Farms 100

acres or more Biomass Some
operators $369 9.4%-10.3% No

*Biomass power plants are willing to take citrus cr ops; however, the materials are typically

blended with other materials and are less desirable

.

Recommendation: District staff evaluated the factors currently impa cting citrus crops and the proposed alternative for disposal. The economic fe asibility analysis is presented in Section E-3 in Appendix E. For citrus crops, Di strict staff has considered biomass power plants as the most technologically an d viable alternative to open burning. Based on District staff’s analysis, it is not economically feasible to prohibit open burning for citrus crop. In addition , there appears to be uncertainty

in whether all of the citrus materials could be acc epted at biomass power plants at this time, due to the lack of future commitments to biomass plan operation.

District staff recommends that citrus orchard remov als continue to be allowed to be open burned. As recommended and supported by th e industry, District staff also recommends that growers allow a drying time of between eight to ten weeks for citrus materials as a best management practice before burning.

Description and Findings

The following citrus crops are all grown in the San Joaquin Valley: grapefruits, lemons, oranges (primarily Navels and Valencias), t angerines, and mandarins. According to the County Agricultural Commissioner’s Data for Calendar Year 2008, oranges make up about 82% of the harvested ac reage of citrus crops in the SJVAB. Growers typically remove old citrus orc hards in the year prior to planting. Based on the District’s data, orchard re movals from citrus crops are spread out through the year; however planting usual ly occurs between February and April.

Citrus is often grown in clay-like soil that adhere s to its roots. The extensive lifespan of citrus crops leads to the development o f an extensive root structureSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-11 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning that is difficult to free of soil debris when the r oot is removed. Clay soil, common to citrus orchards, is difficult to remove from the roots. Separating the roots from the trunk and then processing the trunk and the stu mp or root separately for the purpose of multiple uses increase the costs of oper ations, such as chipping and grinding. Furthermore, screening of chipped materi als to remove excessive clay from stumps increases the overall citrus orchard re moval costs to growers. It takes about six to eight weeks of drying time for a typical non-citrus orchard; citrus takes longer to dry. Growers would need to dry the material long enough so that a biomass facility will take the material a nd ration it.

In addition to the concerns noted above, growers, a g representatives and chipping operators have expressed several other con cerns with the chipping of citrus crop orchard removal matter. Key concerns i nclude 1) the reluctance or refusal of some power plants to accept citrus chips , 2) the additional processing and costs that are required to make the citrus chip s acceptable by the power plants, and 3) whether biomass operators will take citrus once the economy improves and they start getting more construction m aterial.

Biomass power plant operators recognize that citrus has been a problem in the past, but feel that this no longer seems to be the case as there have been considerable changes in processing the citrus mater ials. Biomass power plant operators have indicated that mixing citrus chips w ith chips from other crops helps promote better flow of the chips through thei r equipment. In the past, one of the issues was that clay soil could become trapp ed in the rootballs and damage the power plant boiler refractories. The st ringy nature of citrus tree chips could also clog conveyors and material handli ng equipment unless the chips were finely ground. Biomass power plant oper ators have indicated that from 2003 to 2005, the roots seemed to be a problem initially with citrus materials getting into the conveyor systems, but later it was determined that citrus needed a drying process of around six to eight weeks, mayb e shorter in hotter
temperatures.

According to CBEA, all of the facilities have worke d diligently with the orchard

removal contractors to resolve the issues with citr us wood and as a result, higher percentage of citrus material could now be accepted . Biomass power plants continue to fall short of their goals for more citr us orchard materials and a number of plants continue to be extremely short of wood fuel. Many are currently curtailed or operating at reduced loads and are in need of more fuel at this time. The District looks forward to working with the biomass industry to achieve long-term commitments toward the extensive use of agricultura l biomass.

For more information on biomass facilities, please refer to Chapter Eight of this
report.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-12 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.2.4 Apple, Pear, and Quince Orchard Removal Matte r

Summary and Recommendation

Table 3-5 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing of orchard removals for apple crops, pear crops, and quince crops and has determined that there are currently no feasible alternatives that would substitute open burning of these crops. There are two factors for this consideration: 1) biomass operators will not accept treated materials and 2) requiring that these crops transport materials in c losed containers is beyond what is required for other orchard removals and therefor e, costs are expected to be greater. For the second factor, District staff is not aware of any chipping operators that have closed containers for this purp ose. District staff recommends that open burning continue for these crops.

Description and Findings

As mentioned above for prunings from pome fruits, c rops such as apples, pears, and quince are susceptible to fire blight, a bacter iological disease that can spread through insects, wind, and mechanical device s and kills blossoms, shoots, limbs, and sometimes the entire tree. In m ost cases, the on-set of fire blight is unidentifiable and can be spread by conta ct or exposure to other healthy orchard material. For orchard removals, the equipm ents used to cut or remove the tree are also routinely sterilized with antibac terial agents to mitigate exposure to the disease or potential disease.

Similar to pruning, orchard removals from apple, pe ar, and quince crops need to be burned to combat further spread of fire blight w ithin orchards and to prevent potential infection of nearby orchards. As indicated by some operators and county ag commissioners, they are not aware of an e ffective treatment for fire blight. Growers have considered chipping the orcha rd removals and transporting the materials to biomass facilities. However, the primary concern with this Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: District

Percent of

Return on

Sales Industry

Stakeholder

Percent Return

on Sales

Apple, Pear, & Quince Crops None.

Disease

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-13 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning alternative is potentially spreading the disease to other orchards during transportation. In addition, biomass operators pre fer clean product and will not accept treated materials. As a result, burning is the preferred and most viable method used in the SJVAB to dispose of these crops in order to avoid potential exposure of the fire blight to healthy trees.

3.3 WEED ABATEMENT ACTIVITIES AFFECTING SURFACE WAT ERWAYS,

INCLUDING PONDING AND LEVEE BANKS

Summary and Recommendation

Table 3-6 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the weed abatement activities affecting surface waterways, including p onding and levee banks and recommends that open burning be allowed to continue as part of weed abatement activities affecting surface waterways, i ncluding ponding and levee banks. While chemicals and mowing are available fo r weed control in many locations, these alternatives are not viable becaus e of the slopes and remote

locations.

Description and Findings

It is noted in the May 19, 2005 Rule 4103 Final Sta ff Report, that although some weeds and locations lend themselves to Best Managem ent Practices (see Attachment 1 in Rule 4103), there remains a need fo r limited burning of some weeds. As mentioned earlier, this analysis does no t include the category for “other weeds and maintenance”. The CH&SC required the District to establish best management practices in 2005 for the control o f other weeds and maintenance, which includes ditch bank work, canal bank work, dodder weed, star thistle, tumbleweeds, noxious weeds, pesticide sacks, and fertilizer sacks. Since the implementation, landowners and irrigation districts have continued to do their part to reduce burning by seeking alternat ive ways to manage weeds. Weed

Abatement

Activities Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Surface Waterways – Ponding and

Levee Banks None.

Mowing

and

Herbicide

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-14 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning The best management practices in the rule were deve loped in collaboration with

affected sources and are alternatives that must be considered prior to any open burning. Landowners and operators have also opted for more mechanical and chemical control of weeds and only burned at times when conditions, such as remote locations or other requirements, prevent oth er alternative practices.

Since 2005, open burning is no longer allowed for w eed abatement activities from berms, fence rows, pasture, grass and Bermuda grass. However, open burning is currently allowed for weed abatement act ivities affecting surface waterways, including ponding and levee banks. The following materials are not considered to be part of the burn allowance for wee d abatement activities affecting surface waterways, ponding, and levee ban ks: 1) weeds that originate from outside and away from the surface waterways, p onding or levee banks and 2) any other debris or materials that are gathered from surface waterways, ponding, or levee banks, such as tree limbs or fore ign materials.

According to comments and information received from ag representatives and several agencies, there are currently no feasible a lternatives to burning all of the weeds along surface waterways, ponding and levee ba nks. Landowners and operators have considered using hand crews for remo ving weeds but found the alternative to be impractical. Landowners and oper ators typically mow and spray most of the weeds or use flame desiccation, for dir ect heating of residual weed foliage and over growth of weeds to assure the dest ruction of weed seeds. One operator discs specific sites as needed. In many r emote locations along surface waterways, ponding, and levee banks, fire is the on ly option for effective control of weed seeds and for safety of workers.

In addition, ag representatives and agencies have i ndicated that burning weeds is the most effective option to slope the banks to stabilize them and allow the water to flow easily, with less erosion. Rodents, such as gophers, have also been a concern around levees, including some ground squirrels that have bored through entire levees. Standing weeds make it near ly impossible to check the banks for rodents, which can cause ditch breaks or erosions and lead to flooding of surrounding areas. Complete prohibition to open burning in these areas could

also increase additional use of other chemicals for pest control.

The Federal EPA and the State and Regional Water Bo ards continue to push to eliminate the use of chemicals near any waterway. Recognizing these issues, many landowners and operators are controlling the u se of chemicals along surface waterways, ponding, and levee banks due to concerns over runoff of chemicals from land to waterways. Ag representativ es have provided a copy of the California’s Porter-Cologne Water Quality Act o f 1969 and related information from the federal EPA (attached as part of Appendix B), which further explains theSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-15 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning water regulations. The California Porter-Cologne W ater Quality Act regulates the discharge of waste into ambient waters, and authori zes Regional Boards to impose requirements on waste dischargers after cons ideration of several factors. Along with other responsibilities, the Regional Boa rds also regulate all pollutant or nuisance discharges that may affect either surfa ce water or groundwater. One of the purposes of the federal Water Pollution Cont rol Act (or Clean Water Act) is to restore and maintain the chemical, physical, and biological integrity of the nation's waters by preventing point and nonpoint po llution sources.

One operator indicated that the ability to burn occ asionally would reduce the amount of chemical needed. According to the operat or, the area of the banks by the water line make up about 0.2% of the agency’s t otal acreage and only a portion of that is burned annually.

3.4 OTHER MATERIALS

Other materials include brooder paper, deceased goa ts and diseased bee hives.

3.4.1 Brooder Paper

Summary and Recommendation

Table 3-7 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has found that the current and prima ry disposal method for brooder paper is landfilling. District staff considers lan dfills to be a viable alternative to open burning and will recommend that these material s be prohibited from being

burned. The District’s SMS data also shows an insi gnificant amount of emissions from open burning of brooder paper in the SJVAB in the last few years.

Description and Findings

A broad variety of fowl are raised in confined anim al facilities in the SJVAB. Poultry operators use brooder paper to protect thei r young birds during transportation and the first few weeks of life. In general, the paper needs to easily absorb poultry droppings and disintegrate fo r easier disposal. District staff Other

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Brooder Paper Landfill Yes N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-16 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning contacted four operators that raise poultry. Three of the operators indicated that they do not burn their brooder paper but put it in a dumpster for delivery to a landfill. A large operator that raises turkeys and chickens indicated that he

doesn't "... believe that burning brooder paper is a common prac tice in California." District staff also contacted an oper ator that burns the brooder paper used for raising ducks. The operator indicated tha t he has alternatives to burning the brooder paper including composting the brooder paper or taking it to a

landfill.

3.4.2 Deceased Goats

Summary and Recommendation

Table 3-8 Summary of Analysis

*N/A: not applicable

Recommendation:

District staff considers burial to be a viable alte rnative to open burning. District staff does not consider rendering to be a viable al ternative to open burning due to the many issues noted for that technology. District staff recommends that these materials be prohibited from open burning. The Dis trict’s SMS data also shows an insignificant amount of emissions from deceased goats being burned in the SJVAB in the last few years.

Description and Findings

Several published articles have noted that meat goa t production has been gaining in popularity in the United States in recen t years. Some goat operators

confirmed that there is increased demand for their products.

The discussion below on deceased goats differentiat es goats that expire from diseases (diseased) and goats that expire from othe r causes (not diseased).

Deceased goats that were not diseased - Whether goa ts are raised for their milk, their meat or their fur, goats are subject to fatal injury due to accidents, predatory animals, exposure to the elements, and other causes . Operators have experienced several particular issues in the past f ew years with the disposal of goats that have died from causes other than disease s. Issues have included the Other

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Deceased

Goats Burial Yes N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-17 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning die off of goats due to high summer temperatures an d the reluctance or refusal of rendering plants to accept goats due to concerns ov er the cost to collect the animals and possible diseases. Two goat operators noted that they did not know of any operators that used open burning to dispose of their goats. Instead, operators usually bury the goats on their property in as safe a manner as possible.

Deceased goats that were diseased - In the interest of protecting public health, several regulatory agencies have regulations affect ing the handling of diseased animals. Two diseases of particular concern are ma d cow disease and scrapie. Bovine spongiform encephalopathy (BSE), also known as mad cow disease is a fatal disease that causes progressive neurological degeneration in cattle. Scrapie is a fatal, degenerative disease affecting the central nervous system of sheep and goats.

The California Department of Food and Agriculture ( CDFA) regulates on-site carcass disposal in the case of animals suspected o f succumbing to contagious disease. The California Code of Regulations, Calif ornia Food and Agriculture, Division 5, Part 1, Chapter 1, Section 9141 require s that "Any person that has the care or control of any animal that dies from any co ntagious disease shall immediately cremate or bury the animal." Section 9 142 requires that "An animal which has died from any contagious disease shall no t be transported, except to the nearest crematory." And Section 9143 requires that "An animal which has died from any contagious disease shall not be used for the food of any human being, domestic animal, or fowl."

In addition, the Department of Resources Recycling and Recovery (CalRecycle) has prohibitions that impact the disposal of deceas ed goats. Section 17855.2 of California Code of Regulations Title 14, Natural Re sources, Division 7, CIWMB, Chapter 3.1, Compostable Materials Handling Operati ons and Facilities Regulatory Requirements, prohibits the composting o f unprocessed mammalian tissue except for certain specific instances.

In 1997, FDA published a final regulation designed to prevent the spread of BSE through animal feed. The 1997 FDA rule prohibits t he use of most mammalian protein in the manufacture of animal feeds given to ruminant animals, such as cows, sheep, and goats. The regulation also requir es process and control systems to ensure that feed for ruminants do not co ntain the prohibited mammalian tissue. In 2008, FDA published a regulat ion that strengthened the 1997 rule by prohibiting the tissues that have the highest risk for carrying the agent thought to cause BSE in animal feed.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-18 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning When goats die from unknown causes, some operators will try to discover the cause of death by taking the carcass to a veterinar ian for an examination in an

effort to determine the cause of death.

3.4.3 Diseased Bee Hives

Summary and Recommendation

Table 3-9 Summary of Analysis

*N/A: not applicable

Recommendation: Several key considerations for diseased bee hives a re that the diseases could be dormant in the frames and used equipment, as well a s develop resistance to chemicals used in the sterilization process. The C H&SC specifically identify this crop type as “diseased” bee hives. District staff believes that there are currently no technologically feasible alternatives to open bu rning of diseased bee hives at

this time. District staff recommends that diseased bee hives be allowed to

continue to be burned.

Description and Findings

Bees are a key component in the growing of crops. The importance of bees was noted in an article in the U.S. Department of Agric ulture's science magazine, "Agricultural Research." The author Kevin J. Hacke tt (ARS National Program Leader, Biological Control, Beltsville, Maryland) n oted in the March 2004 issue of Agricultural Research magazine that "The value of h oney bee pollination to U.S. agriculture is more than $14 billion annually, acco rding to a Cornell University study. Crops from nuts to vegetables and as divers e as alfalfa, apple, cantaloupe, cranberry, pumpkin, and sunflower all r equire pollinating by honey bees. For fruit and nut crops, pollination can be a grower's only real chance to increase yield. The extent of pollination dictates the maximum number of fruits." In light of this, it is vitally important to grower s that the supply and availability of bees are protected to the highest degree possible.

Artificial bee hives serve two purposes: production of honey and pollination of crops. The hives are commonly transported so the b ees can pollinate crops in Other

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Diseased

Bee Hives None. Disease

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-19 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning selected areas. Modern bee hives are usually const ructed of wood and consist of several parts which include the following:

• Bottom board - this has an entrance for the bees t o get into the hive.

• Brood box - is the most bottom box of the hive and is where the queen bee lays her eggs.

• Honey Super - same as brood box, but is the upper- most box where honey is

stored.

• Frames and Foundation - wooden frame and plastic s heet with honey comb impression where bees build wax honey combs.

• Inner and Outer Cover - As the name implies.

Beekeepers have experienced several problems in the past few years. A recent development is the problem of colony collapse disor der (CCD), a phenomenon where bees mysteriously abandon their hives. The U C Davis Department of Entomology website contains an article dated Oct. 1 6, 2007, about a lecture presented by UC Davis honey bee specialist Eric Mus sen . The article notes the following comment: "One-third of America's honey b ees vanished this past year due to the mysterious CCD, characterized by almost total hive abandonment. Nearly all adult worker bees unexpectedly fly away from the hive, abandoning the stored honey, pollen, larvae and pupae. Usually th ey leave in less than a week, and only the queen and a few young workers remain".

Section 29208 of California Code of Regulations Tit le 3, Food and Agricultural Code, Division 13, Bee Management and Honey Product ion, requires that "If American foulbrood is found in an apiary, the abate ment shall be by killing the bees in the infested colonies and disposing of the hives and their contents, together with any other infested comb, hives, and a ssociated appliances which are found in the apiary, in one of the following wa ys: If abatement is by burning, the person abating shall act in accordance with app licable air pollution control district or air quality maintenance district regula tions and state and local fire control laws. If the regulations or laws prohibit burning immediately, the diseased colonies shall be sealed and placed in an enclosed structure and thereafter burned on the first date allowed by the regulation or law. All the activities shall be reported to the inspector prior to burning, who may require that burning occur only under his or her supervision."San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-20 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.5 RICE STUBBLE (STRAW)

Until June 1, 2010, permits may be issued for the b urning of rice stubble up to 70% per year of the total acreage of rice farmed by the operator. Permits may also be issued for the burning of residual rice stu bble, spot burning of rice stubble, and burning of weeds and vegetative materi als on rice field levees and

banks.

Summary and Recommendation

Table 3-10 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing rice stubble. Due to the fluctuation in market demand for rice stubble, which impacts growers ability to effectively remove the material, and issues with water allocation, District staff recommends that op en burning of rice stubble be allowed to continue for burns at 70% per year of th e total acreage of rice farmed by the operator after June 1, 2010 and until June 1 , 2015. District staff will review the feasibility of a complete burn prohibiti on for rice stubble in 2015.

Description and Findings

Most of the rice grown in the SJVAB is grown in the northern part of the air basin. Rice is planted in the spring and harvested in the fall. Once the rice is harvested, the rice straw remains in the field for disposition . Reducing the amount of postharvest straw residue in the rice fields is importa nt to the successful production of the next crop. Burning has been the historical cul tural practice for removing straw and residues for the California rice industry . Burning rice straw helps prepare the field for the next rice crop as burning destroys any diseases in the rice straw of the current crop.

The farming operations for rice growers in the SJVA B are different from Sacramento Valley growers, where significant acres of rice are also farmed. Rice growers in the Sacramento Valley typically dis pose of their rice straw by Rice Stubble (Straw) Potentially

feasible

alternative Currently in

practice by operators? Increment

al Cost, $/acre at

20 acres

or more: District

Percent

of Return

on Sales Industry

Stakeholder

Percent

Return on

Sales

Rice Stubble (Straw) No. Market

and Water

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-21 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning incorporating the rice straw into the soil. Unlike Sacramento Valley where water allocations allow post-season irrigating, water can not be delivered to agricultural operations in the Northern SJVAB in the post-harves t season due to the annual distribution schedules designated by irrigation dis tricts. Due to the lack of available water in the post-harvest season, rice gr owers in the SJVAB do not use soil incorporation to dispose of their rice straw b ecause the residue may not breakdown by planting season. Most rice growers in the SJVAB do not have

access to water wells for their rice fields.

In 2007, District staff believed that rice growers could sell the rice straw to rice straw baling operators who would then sell it to th eir customers such as dairies. Therefore, the District prohibited open burning for 30% of rice stubble per year.

In 2009, District staff attended a meeting held by several rice growers that farm in the Escalon area. According to the growers, the ba ling alternative worked well

for the 2007 harvest as there was a market for the baled rice straw. However, rice growers stated that they were having difficult y in their efforts to comply with the 70% burn allowance for 2009. Specifically, the y were having difficulty in getting their rice straw baled and removed from the ir farms. The rice growers and a rice straw baling operator indicated that the y have conducted several searches on alternatives to burning the rice materi al and there is currently no market for baled rice straw. In November 2009, a v ariance was approved for a group of rice growers that farm in the Escalon area to allow them to burn the remaining 30% of their acreage. Growers noted in t heir variance application that there were no viable alternatives currently availab le for disposal of the rice

stubble.

According to the District’s burn data for rice stub ble, the annual burn acreage have fluctuated since 2006. This change is primari ly due to the market demand for rice stubble. However, open burning from rice stubble have been reduced by 42% since 2005, base on a three-year average from 2 007 to 2009. The market should continue to be assessed annually to ensure t hat rice stubble can continue to be used for other alternatives, such as dairies.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-22 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.6 Prunings from Apple, Pear, Quince, and Fig Crop s

3.6.1 Prunings from Apple, Pear and Quince Crops

Summary and Recommendation

Table 3-11 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing prunings from apples, pears, and quince c rops and do not believe that there are technologically feasible alternatives to open burning of these materials. Depending on the amount and size of materials, it m ay not be feasible to require that growers place the materials into plastic bags for burial. The chemicals are preventative measures to help control fire blight; however, chemicals are not the solution to ensure complete control since the bacte rial disease may develop

resistant strains. District staff recommends that prunings from apples, pears, and quince be allowed to be burned to help control the spread of fire blight.

Description and Findings

Pome fruit including apple, pear, and quince crops are susceptible to a disease called fire blight. Fire blight is a destructive b acterial disease that kills blossoms, shoots, limbs, and sometimes the entire tree. Inse cts, wind, and mechanical devices can spread fire blight. According to the a g representatives and an agricultural commissioner, fire blight can destroy an entire orchard in a single

season if left uncontrolled. The bacterium can be easily transmitted to susceptible tissue by contact. The equipments used to prune the tree are routinely sterilized with antibacterial agents when moving from one tree to the next to mitigate exposure to the disease or potenti al disease. The unrestricted

movement of infected tissue will cause the disease to spread rapidly and under certain environmental conditions (hot and wet). Co ntainment of the infected

tissue is an essential element for control.

Apple, pear, and quince prunings are burned to comb at further spread of fire blight within orchards and to prevent potential inf ection of nearby orchards. Prunings Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS) Apple, Pear, & Quince Crops None.

Disease

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-23 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Some operators and county ag commissioners have ind icated that they are not aware of an effective treatment for fire blight. C hemicals that are used to control the bacterial disease could prove ineffective if th e disease becomes resistant over time. According to an agricultural commission er, the options for controlling fire blight that is becoming resistant to chemical means of control with Streptomycin are burning on site or disposal by pla cing infected plant material in double plastic bags for burial.

3.6.2 Prunings from Fig Crops

Summary and Recommendation

Table 3-12 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered shredding as an alter native to open burning of prunings from fig crops and other factors currently impacting fig crops. Shredding the pruning materials on site appears to be a common practice and the most feasible alternative to open burning of pr unings from fig crops. Shredding the fig prunings and allowing it to decom pose should not be a significant fruit degradation concern for fig orcha rd removal as the chipped material should have decomposed or be reduced in si ze by the time of harvest. The current mowing and sorting practices would help reduce any excessive materials from the figs during harvest. As a resul t, District staff recommends that open burning be prohibited for prunings from fig cr ops.

Description and Findings

Most figs are harvested as a dried crop. Figs are dried on the tree and allowed to fall to the ground. Dried figs are mechanically swept into windrows and collected and harvests are repeated at two to three week intervals. This method of surface harvesting requires the orchard grounds to remain free of excess

debris that will hinder the harvest. The harvested figs are then transported to a dry location to be sorted before being sold.

According to ag representatives, there are no fire blight issues for figs and shredding the pruning material has become a common practice. Fig crops are typically pruned by hand during the winter. The pr uning materials are placed in Prunings Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Fig Crop Shredding Yes N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-24 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning the aisle of the tree rows and shredded in place. Operators typically mow the center of the tree rows a few times a year to manag e and maintain the orchard

floor.

3.7 SURFACE HARVESTED PRUNINGS

3.7.1 Prunings from Grape Vines and Grape Canes

Summary and Recommendation

Table 3-13 Summary of Analysis

Surface

Harvested Prunings – Vineyard

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Grape Vines Soil Incorporation Yes N/A N/A N/A Grape Canes Soil Incorporation Yes N/A N/A N/A *N/A: not applicable

Recommendation: As shredding and soil incorporation of prunings fro m grape vines and grape canes are already widely practiced, District staff considers soil incorporation to be a viable alternative to open burning and recomme nds that prunings from grape vines and grape canes be prohibited from open burning.

Description and Findings

This category does not include grape attrition. Ac cording to the District’s policy, attrition is vegetative materials not associated wi th pruning (as defined in Rule 4103) or orchard removals. Attrition materials incl ude the incidental cuttings of dead or broken branches, tree mortality, water spro uts or suckers, or other damage to tree crops. Attrition materials may be bu rned provided that the materials are listed on a valid burn permit and dai ly burn authorization is granted.

Grape vines are used to produce table grapes, wine grapes or raisin grapes. The grape canes and spurs from a grape vine are usu ally pruned once a year in the winter when the grape vine is dormant. Wine vi neyards now have high tensile wire to withstand the machines that go thro ugh the rows during pruning. The pruned grape canes and any other pruned materia l, such as spurs, are positioned in the center of the grape vine rows and shredded. Many growers typically shred their grape vine pruning material u sing a tractor and a shredder. Grape canes and other materials from the grape vine s do not include the prunings from kiwi crops, which are already subject to Rule 4103.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-25 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Figure 3-1 Illustration of Grape Vine and Cane

A head-trained vine with cane pruning

Bilateral cordon training with spur pruning

http://www .ipm.ucdavis.edu/PMG/GARDEN/FRUIT/CULTURAL/grtrainp rune.html

According to ag representatives and growers, the sh redding and soil incorporation of grape cane prunings and other prun ing materials from a grape vine have been long time traditional practices of g rowers. According to ag representatives, growers and biomass power plant op erators, they are not aware of anyone doing anything with grape canes and other pruning materials from vines, except for shredding them and incorporating the shredded material back

into the soil.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-26 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 3.7.2 Raisin Trays

Summary and Recommendation

Table 3-14 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for open burning of raisin trays and recommends that op en burning of raisin trays be allowed to continue. There is currently not enough research information for using raisin trays as fuel at biomass power plants. In a ddition, District staff believes

that the increase to 40% of mechanical harvest for raisin production in 2009 alone has also significantly reduced the amount of emissions from these materials. As growers continue to switch to mechan ical harvesting as an alternative to using raisin trays and open burning the material, District expects that open burning emissions from raisin trays will subside as well. According to the District’s burn data, growers have continued to reduce open burning of raisin trays. Since 2007, growers have reduced burning of raising trays by over 27%, or 0.11 tons. District staff recommends that growe rs implement the practices below to control open burning of raisin trays and t hat the District work with the ag industry to develop any additional measures.

Description and Findings

Raisin trays are used in producing raisins. There are several types of drying trays used for sun-dried raisins. Wooden trays wer e used in the past, but have been replaced by paper trays. Due to changes in fa rming practices and other factors, several new paper trays have been develope d. The types of paper trays available include regular paper, wet-strength paper and poly-coated paper. Both wet-strength paper and poly-coated paper trays are especially suited for protecting the raisin crop under wet conditions.

The traditional paper tray is approximately 24 inch es wide and 36 inches long although other sizes are available for certain situ ations. The continuous tray, which consists of tray material wound into rolls of specified widths, resulted from Surface

Harvested Prunings – Vineyard

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Raisin Trays None. Polymer &

Recycling Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-27 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning the development of mechanical harvest machines. Th e continuous paper is a heavier weight than individual trays.

Once the raisins have cured adequately and the mois ture in the rolls is acceptable, normally in late September, they are re ady to be collected. Raisins must be at 16 percent or less moisture content to m eet the industry’s incoming inspection requirements. There are several methods used for collecting the raisins and preparing them for the next step in the ir processing. After the raisins are collected, they are separated from the raisin t rays for further processing and delivery to a raisin handler. Once the raisins are removed from the raisin trays, the raisin trays are ready for some other use or di sposal.

Growers have continued to pursue alternative ways t o burning raisin trays for over 50 years. Ag representatives indicated that o nly about 50,000 acres of vineyards using raisin trays are expected by 2015 b ecause growers are transitioning to mechanical harvesting, which does not include the use of raisin trays. It is expected that there will be a continu al reduction in burning. The long term goal of the California raisin industry is to t ransition toward 100% mechanization of raisin harvest and drying 5 . Based on information received from the ag representatives, the historical use of paper raisin trays has been significantly reduced by over 52% since 1990. The table below is a summary of information provided by ag representatives and show s the progress made in reducing the use and open burn of raisin trays.

Table 3-15 Raisin Tray Paper Volume History

Year Total Amount of

Raisins in

Production (tons) Percentage of

Raisins

Mechanized (%) Amount of

Raisins

Produced on Raisin Trays (tons) Number of Raisin

Trays (four pounds of raisins per tray)

1990 395,000 5 375,000 188,000,000
2000 432,000 10 389,000 195,000,000
2009 300,000 40 180,000 90,000,000

According to ag representatives, some growers used recycling firms to dispose of their trays in the past. The trays were then shipp ed to China. The growers were typically charged a fee when the recycling firms pi cked up the trays at the growers site. However, China has cut off import of raisin trays because of the dollar’s value and the practice of sending raisin t rays to China is no longer a

feasible alternative.

District staff has considered soil incorporation an d biomass power plants as possible alternatives; however, the materials in th e raisin trays create severalSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-28 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning potential issues. Ag representatives have indicate d that some growers grind and soil incorporate their raisin trays. The raisin tr ays contain polymer (5%) so that the moisture on the ground can not be absorb effici ently through the raisin trays. The trays that are ground up and soil incorporated into the soil can create problems because the materials are slow to decompos e and some pieces will scatter around. Growers prefer clean fields for op erations, which also help keep rodents and pests away.

The raisin trays currently can not be recycled for use as fuel at biomass power plants due to the polymer in the material. Accordi ng to biomass power plant operators, both Madera and Mendota power plants are permitted to burn paper. Power plant operators indicated that they are willi ng to work with the District to address these issues. Power plant operators are de termining a way to incorporate raisin trays into their fuel and analys is is pending. Additional research is needed for the potential use of raisin trays as fuel for biomass power plants.

In efforts to help reduce and control the burning o f raisin trays, Ag representatives have developed and recommended the following practices for the burning of raisin trays:

1) All burning locations must be attended at all ti mes when the raisin trays are burning, by able bodied adults with adequate to ols or equipment to control a fire from escaping.

2) All burn locations must have adequate clearance to avoid escape. The burn area should be a “fire safety zone” away from dry fields, homes, shops, garages, utility poles or utility supply lin es, and other buildings or equipment. A rule to remember is to remove all combustible

materials from 30 or more feet around the burn area

.

3) Paper raisin trays must be burned in a container to avoid escape of burning embers or ash, such as a wire cage. A wire cage may be constructed out of hardware cloth or chicken wire p rovided that the mesh is no larger than a 1⁄2 inch opening. The cage should never be filled beyond half and should be placed in a “fire safe zone”. Using a burn barrel for burning anything is illegal.

4) Don’t burn on windy days.

5) Avoid burning near a highway or roadway. Ashes or heavy smoke can create a very dangerous situation for drivers and w inds caused by vehicles could cause the fire to escape from the fi re safety zone.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-29 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 6) Don’t cause a smoke nuisance to your neighbors.

District staff will work with the Ag stakeholders t o implement the recommended practices when burning raisin trays.

3.7.3 Almond, Walnut, and Pecan Prunings

Summary and Recommendation

Table 3-16 – Summary of Analysis

Recommendation: The economic feasibility analysis is presented in S ection E-4 in Appendix E. Based on the considerations and analysis for prunin gs from almonds, walnuts, and pecans, District staff recommends the following :

The District would provide limited burn allocation for surface harvested prunings from almonds, walnuts, and pecans according to the following:

1. Prohibit burning of prunings for each agricultur al operation whose total nut acreage (i.e., almonds, walnuts, and pecans) at all agricultural operation sites is 3,500 acres or more. 2. For each agricultural operation whose total nut acreage at all agricultural operation sites is less than 3,500 acres, a. Allow burning of up to 20 acres of prunings per year, and

b. Allow burning of additional prunings, provided:

i. The operator submits to the APCO before the pruning operation is completed, a representative cost estim ate(s) for shredding all prunings generated by the total nut a creage at the agricultural operation site. The cost estimate (s) shall reflect shredding in a time frame that allows the o perator to proceed with established post-pruning cultural prac tices.

ii. The APCO determines that either the submitted cost estimate(s) represent(s) an unreasonable financial impact to the operator, or that adequate shredding services a re not Surface

Harvested Prunings Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Almonds, Walnuts, and Pecans

Farms Less

than 100 acres Shredding Some Operators $38 10.0% Yes

Farms 100

acres or more Shredding Some Operators $38 8.5% YesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-30 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning available in time for the operator to proceed with established post-pruning cultural practices.

Description and Findings

Although the pruning methods will vary among grower s, nut crops in general would have similar or common practices. So, unless otherwise noted, the following description for nut crops applies to almo nds, walnuts, and pecans.

Nut trees are usually pruned after harvesting, eith er late or early in the year. In the past, growers generally open burned nut pruning s to dispose of the material. However, many growers have found alternative ways t o convert prunings into something useful such as soil amendment, dust contr ol on unpaved surfaces, compost material, or fuel for biomass power plants. According to published documents and stakeholder comments, most nuts growe rs are currently shredding the prunings and leaving the materials on the orchard floor. Stakeholder comments include growers, vendors, and custom shredders. The ability to shred the materials varies among growers of different size farms and regions. One top nut grower in the SJVAB has conti nued to help minimize impact on air quality through environmentally respo nsible efforts, which include a contract with a biomass power plant to take its orc hard removals and prunings. In 2008, another farm of several thousand acres ini tiated cultural practices and equipment necessary to shred all of the prunings ra ther than burn. District staff has also received comments from growers and custom shredders indicating that shredding of nut prunings has been a successful pro cedure in the farming operation, particularly for walnuts for one grower. However, there were also concerns from other growers regarding the burn proh ibition for the prunings of
nut crops.

A primary concern that some almond and walnut growe rs have is preventing the pruning material from interfering with the harvesti ng of the crop. Some of the existing shredding equipment currently shred the ma terials from one inch to a

few inches in size.

One problem that some growers have experienced with chipping is the build up of chipped material on the ground, which slows the decomposition process. This situation can then cause the chipped material to be picked up during harvest. Some growers till the shredded material to help the decomposition. A grower noted that all pecans are no till operations wherea s only a third of walnuts are no till operations. Although tilling could be done to bury the chipped material to promote faster decomposition, growers try to minimi ze the number of tractor passes in their orchards.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-31 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning According to ag representatives, the almond hullers indicated that the impact of almond prunings or chips has been problematic. The chips are picked up with the almonds during the harvest process. The chips pass by the “detwiggers” which remove the larger sticks and branches that ma y get knocked down during the typical harvest process (shaking, sweeping and pick-up). The product then goes to the almond hullers/shellers, which separate the hull and shell from the almonds. Growers want to keep the harvest as clean as possible in order to maximize the price they receive from the almond hul l processors that convert the hulls into animal feed. In order to keep the groun d surface free of pruning material at harvest time, many growers have mostly relied on removing the pruning material from the field and open burning th e pruning material.

Ag representatives also provided the following info rmation to the District. The hull has significant feed value to dairies, and hul ls with 15% fiber content or less are considered “prime hull” and receive the highest value. The next product is

“hull and shell” which is limited to a fiber conten t of between 15% and 29%. And lastly, the shell or any product that has greater t han 29% fiber content has little value and hardly any market. The almond hullers th at the ag representatives spoke to estimate a five percent to 11% loss in pri me hull revenue due to the presence of chips. Prices vary from year to year, but prime hull sells for significantly more than hull and shell. During a s urvey that the ag representatives conducted in 2009 for the purposes of developing comments for Rule 4103, prime hull was selling for $75 per ton, while hull and shell was selling for $45 to $50 per ton. Chips are high fiber conte nt and when picked up with the hulls during the hulling process, they can signific antly shift the fiber content. One huller estimated that the 4,000 tons out of 35,000 expected tons were shifted from “prime hull” to “hull and shell” due to the ex istence of chips. This was an 11.4% loss amounting to $120,000 in lost revenue. Another huller lost an estimated five percent of their “prime hull sales” due to the existence of the chips.

For walnuts, the hulls are not used for feed; howev er, growers still need to keep the harvest clean in order to minimize any negative impacts during the processing of the nuts. According to the ag repres entatives, the walnut growers and walnut processors have indicated that the prima ry issue is that the chips plug the lines at the processor, especially under wet co nditions. Walnuts are typically harvested from mid-September through mid-November. About half of the time, rains during the fall begin before the harvest can be completed. Since the prunings occur in the winter, it is impossible to g et a chipper into the orchard until after the rains subside. The chips do not decompos e in the six to seven months between the pruning and the beginning of harvest. This is where the plugging occurs. The wet chips impede the ability to move t he walnuts through the ductwork at a huller/dehydrator and processor, as t he chips are picked up with

the walnuts.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-32 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Ag representatives stated that walnut processors ha ve also expressed concern with the chips being left in the orchard due to con cerns over food safety. Since the chips are an organic material, they are subject to mold growth. If this mold is picked up during harvest, it can create a significa nt food safety issue in terms of the potential for aflatoxin. Food safety has becom e the number one issue of concern for the tree nut industry, and any issue th at would confound food safety would be problematic.

As the trees are pruned late in the year, the groun d is usually too wet to run heavy equipment in the field in order to chip the p runings. Growers will then wait for the ground to dry but they can only wait for a limited time as they need to spray and irrigate their fields early in the year a nd the pruning material can interfere with these operations. This gives the gr owers a short window of opportunity to have their prunings chipped. Some g rowers usually find it more conducive to their operations to gather the pruning s and burn them.

For growers that shred the pruning material as an a lternative method to open burning, the practice varies among nut growers. In addition, the pruning practice for the growers in the northern region appears to b e different than the southern region. Growers could shred the prunings by rentin g, purchasing, or borrowing special equipment, or by hiring a custom shredder. These options depend on the availability of the custom shredder or the equipmen t. Costs for the options above also vary; however, District staff has analyzed the cost of hiring a custom shredder as the likely alternative (see section on Costs for analysis) for growers that own smaller farms. Custom shredders currently charge a two hour minimum fee to shred nut prunings. The average charge is a round $260 per hour for a total of $520 for two hours. Purchasing a special shredding equipment that can shred the material into fine pieces to address the issue with the chips being picked up during harvest season could cost over $30 0,000 and is an expensive option and less likely for a small grower.

Ag representatives, custom shredders, and growers h ave mentioned that there is a shredder in the market which can shred the prunin gs into smaller pieces, thereby reducing problems during the harvest season . The shredder can also operate in all weather conditions, including the ra ining season. The vendor of the shredding equipment has indicated that 48 of those shredders are currently available for the industry and that previous shredd ing equipments have been sold mostly to growers where some also provide custom sh redding service. One of the custom shredder indicated that most growers tha t farm over 3500 acres typically shred their own material and that it woul d be more costly for a grower that farms less than that to purchase the same shre dder.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-33 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning District staff conducted an analysis to determine w hether it would be viable for growers to purchase a shredder instead of hiring a custom shredder. The following information was used to conduct this anal ysis:

1. Harvesting ends in October and cultivation begin s around January/February. District staff estimated that th e available months during the pruning season are November, December, a nd January (three months). 2. According to a custom shredder, the specific shr edding equipment can cover eight to ten acres per hour. District staff estimated nine (9) acres per hour for the shredding equipment. 3. One working day equates to about eight (8) hours . Average number of working days per month is 22 days. District staff estimated that two hours are used to prepare the equipment before and after operation and six hours are used to shred (process) the pruning mater ial.

The calculations for one shredder are as follow:

1. Total Number of Acres Processed Per Month

Hours Processed Per Day x Acres Processed Per Hour x Averaged Number of Days Per Month:

6 hrs/day x 9 acres/hr x 22 days/month = 1188 acres /month

2. Total Number of Acres Processed During the Pruni ng Season (Three Months)

Total Acres Per Month x Three Seasonal Months:

1188 acres/month x 3 months = 3564 acres

Based on the calculations, one shredder can cover a pproximately 3500 acres.

District staff believes that it would be reasonable for a grower that farms 3500 acres or more to purchase an equipment to address h eavy to light prunings from the nut orchards. As mentioned by the vendor and c ustom shredder, many growers that own their own shredding equipment also provide custom shredding service to other growers.

District staff conducted further analysis on the co st benefit of purchasing the shredding equipment for a farm over 3500 acres. Th e analysis below is intended to compare the two methods for the shredding altern ative and is not representative of the incremental cost. The analys is is based on the following

factors:San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-34 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning 1. Hiring a Custom Shredder:

• Per custom shredder, the average charge is $520 fo r two hours

minimum.

• Equipment can process eight to ten acres per hour, or 16 to 20 acres minimum (Averaged: 18 acres).
(Reference: http://www.panerofarms.com/why-flory-powertrack.htm l )

• Based on the above information, minimum averaged c ost per acre is $29.

2. Purchasing a Shredding Equipment:

• Per vendor and custom shredder, the estimated cost of purchasing the shredding equipment range from $315,000.

• Labor rate of $14.74 per hour for machine operator s, which includes payroll overhead of 34%.
(Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

• Price for on-farm delivery of diesel is $2.50 per gallon, which

includes a 2.25% sales tax on diesel fuel.
(Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

• Fuel use for a shredding machine with similar hors epower is 12 to 15 gallons per hour. District staff estimates that the averaged amount of fuel (diesel) required to operate the shr edder for one hour is 14 gallons (References: http://www.jgpress.com/archives/_free/001555.html and http://www.neequip.com/KFNA/BROCHURES/PDF_BRO/Cramb o_2005E.pdf )

• Annual maintenance is calculated as two percent of the purchase price. (Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

• Other additional costs include property insurance and property taxes (cash overhead). According to the 2008 Almonds costs and Returns Study

, the cash overhead contributes to about 9.5% of th e capital recovery. (Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

Based on the best available information and analysi s above, the following calculations use 3564 acres per year for an equival ent comparison of the cost of purchasing a shredder and the cost of hiring a cust om shredder.

The calculation for hiring a custom shredder is as follows:

1. Total Annual Cost of Hiring a Custom ShredderSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-35 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Minimum Averaged Cost Per Acre x Number of Acres:

$29/acre x 3564 acres = $103,356

The calculations for purchasing a shredder are as f ollows:

1. Total Annualized Capital Costs of the Shredder

The District uses the following formula to calculat e an equivalent annual cost from a capital cost using a capital recovery factor as shown below:

A = [P x i(1 + i) n ] / [(1 + i) n – 1]

Where: A = Equivalent annual cost of control

P = Capital cost of the control equipment, includin g installation cost

I = Interest rate (used 10% as a conservative esti mate)

n = Equipment life (used 10 years as a conservativ e estimate)

[$325,000 x 10%(1 + 10%)^10yrs] / [(1 + 10%)^10yrs – 1] = $51,265

2. Total Annual Cost of Diesel Fuel

[Estimated Amount of Fuel (in Gallons) Used Per Hou r x Hours Processed Per Day x Averaged Number of Days Per Month] x Cost of Fuel Per Gallon:

[14 gallons/hr x 6 hrs/day x 22 days/month x $2.50 /gallon] x 3 months = $13,365

3. Total Annual Cost of Hiring a Machine Operator

Labor Rate Per Hour x Total Number of Work Hours Pe r Day x Averaged Number of Days Per Month x Three Seasonal Months:

$14.74/hr x 8 hrs/day x 22 days/month x 3 months = $7,783

4. Total Annual Cost of Maintenance

Cost of the Shredder x Two Percent of the Cost of t he Shredder:San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-36 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning $315,000 x 2% = $6,300 5. Total Annualized Cost of Property Insurance and Property Taxes

Total Annualized Costs of the Shredder x 9.5 Percen t for the Cash Overhead (Insurance and Taxes):

$52,892 x 9.5% = $4,883

Table 3-17 and Table 3-18 summarizes the annualized cost estimates for the purchase of a shredder and the annual costs of hiri ng a custom shredder.

Table 3-17 – Annualized Cost Estimates for the Purc hase of a Shredder Description Costs Total Capital Cost $315,000

Total Annualized Capital Cost of the Shredder (10% - 10 years) $51,265 Annual Operation & Maintenance Costs Total Annual Cost of Diesel Fuel $13,365 Total Annual Cost of Hiring a Machine Operator $7,7 83 Total Annual Cost of Maintenance $6,300 Total Annualized Cost of Property Insurance & Taxes $4,883 Total Annual Operation & Maintenance Costs $32,331

Net Annual Costs (Annualized Capital Cost + Annual O&M Costs) ($/year) $83,596

Table 3-18 – Annual Cost Estimates for a Custom Shr edder Description Costs Averaged Cost Per Acre $29

Total Annual Cost for 3564 acres $103,356

Net Annual Costs ($/year) $103,356

Based on the analysis above, the estimated savings from purchasing a shredder is close to $20,000 per year.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-37 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning According to GrowingProduce.com, the 2009 Top Nut G rowers make up about 228,000 of nut acreages in California. Out of the 25 Top Nut Growers, 18 of those growers are in the District’s burn permit dat abase or the Conservation Management Practices (CMP) database. The 18 grower s make up about 183,154 acres of nut crops. Pistachios contribute to about 16% of the total acreage in the SJVAB, therefore the estimated acrea ge for almonds and walnuts for SJVAB growers is 154,327 acres, which is about 20% of the total nut acreage in the SJVAB. Twelve of those growers are over 3,5 00 total farm acres of nut crops and contributes to over 94% of the top acreag es on the list, or about 212,000 total nut acreages. At least two growers i n this group are either shredding the pruning material or taking the materi al to the biomass power plant. Based on the 2007, 2008 & 2009 Top Nut Growers tabl es, District staff expects that at least 80 percent of the farms in the top 25 list could buy their own shredding equipment. At the bottom of the 80 perce nt range, the total nut acreages average about 3460 acres.

According to the custom shredders, the average char ge to shred the prunings is a minimum of two hours. The recommended shredder, which can shred the materials to finer pieces to address issues with th e chips not being decomposed by harvest season or being picked up during harvest , can process eight to ten acres per hour. Due to the two hours minimum that custom shredder charges the grower, District staff believes that the cost o n a per acre basis would increase as the acreage becomes smaller. Therefore, the 20 acres limit within the two

hour timeframe is reasonable.

District staff is aware of at least three custom sh redders in the SJVAB that operate a total of five of those shredders and anot her two contractors that do custom shredding. There are also several types of other shredding equipment available, where some may require more passes in or der to shred the prunings into acceptable sizes.

The Jack Rabbit equipment is typically used to remo ve the material from the orchard. Transporting the material to composting f acilities appear to be less common among growers compared to shredding the mate rial onsite or taking the material to the biomass power plants. According to biomass power plant operators, some biomass power plants purchase some, but not all, of these prunings. The preferred alternative at this time f or most pruning material is to shred and leave the material on the ground, since i t can be more efficient than chipping and transporting the material offsite. So me growers have found that shredding and incorporating the materials back into the ground helps replenish the soil with nutrients. Several growers are also moving towards lighter pruning, which are about one-fifth of what they used to be. Since 2007, the amount of almond prunings burned has been reduced by over 22, 000 acres, or 76 tons ofSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-38 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning PM2.5. The amount of burn acres from walnut prunin gs has also been reduced by over 5,500 acres, or over 13 tons of PM2.5. The category for pecan prunings has shown a slight change in open burning; however, prunings are also shredded and left on the ground. The overall amount of emis sions reduced since then could be even higher as a result of lighter pruning s.

Over the past ten years, NRCS has encouraged grower s to chip or shred the prunings from almond and walnut orchards by providi ng a cost-share basis through the Environmental Quality Incentives Progra m (EQIP). According to NRCS staff, it is uncertain how long this program w ill last. Many of the growers shred the material on site through this program, wh ich helps reduce Nox, VOC, PM10, and PM2.5 emissions generated from open burni ng. According to NRCS, the program resulted in an average of 120,333 acres of almond and walnut prunings chipped per year in the SJVAB from 2007 to 2009. Along the same years, the average amount of almond and walnut prun ings burned from the District’s database was 68,802 acres per year. Acc ording to the County Agricultural Commissioner’s data for Calendar Year 2008, the total harvested acreage for both of those crops in the SJVAB was 75 3,515 acres. The total harvested acreage for pecans is 611 acres, or 0.08% of the total nut harvested acreage. See table below for a summary of the alte rnative methods for almond and walnut prunings. Pecans are not included in th e analysis below because NRCS data only addresses almonds and walnuts.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-39 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations

Final Staff Report and Recommendations on Agricultural Burning Table 3-19 – Analysis of Alternative Methods for Al mond and Walnut

Prunings Surface Harvested Prunings from Almond and Walnut C rops Acres Total Harvested Acreage for Almonds 625,814 Total Harvested Acreage for Walnuts 127,701 Total Harvested Acreage for Almonds and Walnuts 753 ,515

Estimated Acreage Pruned per Year 1 376,758 Chipped/Shredded Acreage of Almond & Walnut Pruning s per year (NRCS) 120,592

Open Burned Acreage of Almond & Walnut Prunings per year (District) 68,802

Estimated Acreage from Alternative Disposal of Almo nd & Walnut Prunings 2 187,364

1 Assume Pruning is done in alternate years: [(753,51 5) / 2] = 376,758. The 2008 Almonds Costs and Returns Study and 2007 Walnuts Costs and Returns Study use alternate years for pruning of mature orchard. Both studies analyzed the alternat ive method of chipping and shredding onsite and indicated that the practices will vary among gr owers and regions.

2 The remaining acreage is likely to be voluntary dis posal through alternative methods to open burning, such as shredding, chipping, biomass fuel, or other methods, and without the EQIP

program.

Based on the table above, if growers prune the harv ested orchards during the dormant period every other year, the actual amount of acres pruned per year would be about 376,758 acres. Based on the analysi s above, about 18% of the acreage pruned per year is contributed to open burn ing, while most of the growers are using other alternative practices rathe r than open burn.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

3-40 Chapter 3: Analysis of Affected Crop Categories and Recommendations

Final Staff Report Recommendations on Agricultural Burning This page intentionally blank.