Final Staff Report and 

Recommendations on Agricultural Burning 

Chapter 3 

Technical and Economic 

Analysis of Affected Crop 

Categories and Recommendations 
Final Staff Report and 

Recommendations on Agricultural Burning 

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Chapter 3: Technical and Economic Analysis of Affected 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 of 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 alternatives, District staff has 

evaluated what appears to be the most viable and likely method to open burning 

for many of the affected crops in the SJVAB. Further discussion on emissions 

and costs for open burning and the alternatives for these crops are presented in 

the following chapters of this report. This chapter analyzes the crop categories 

that are allowed to be burned until June 1, 2010 and presents the findings for 

those crops. 

During the research process, District staff has worked closely with the ag industry 

representatives and other agencies to address the burn 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 operations, and other related 

documents. The ag industry has made significant progress over the years in 

reducing emissions from open burning through research, development, and 

implementation of viable alternative methods. However, there are concerns for 

some crops where growers have not been able to identify 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 profit rates (Return on Sales, or 

ROS) of the industry sector. To evaluate the economic feasibility of burn 

prohibitions on orchard pruning/removal operations for subject crops, the District 

engaged their regulatory economic consultant, Applied Development Economics, 

Inc. (ADE). ADE has familiarity with and constant access to comprehensive and 

applicable profitability and revenue data. Compliance costs for non-burning 

disposal alternatives were estimated by District engineers and ag industry 

representatives using a variety of data sources and methodologies. The 

development of compliance cost estimates is presented 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, 
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acreage, and prices were taken from the USDA Ag Census 2007, University of 

California Cooperative Extension, and California Agricultural Commissioners’ 

Annual Report, as well as data compiled commercially 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 industry stakeholders engaged 

in extensive effort and provided significant input regarding the recent profitability 

of certain crops. These data are presented in Appendix E and confirm the 

District’s conclusions on the significance of economic 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 tables 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% 
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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 alternative to remove 

the wire that is embedded in the cordon and canes to prevent 

damage to the chipping equipment or prevent the wires from going 

to the biomass power plants. Wire removal adds a significant 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 and haul away the 

vineyard removal materials or would charge a higher fee. 
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Description and Findings

Vineyards include both grape vines and kiwi vines because both crops require 

support, such as the trellis systems to help keep the 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 used at a vineyard are based on 

the intended use of the grapes (table, wine, or raisins) and other factors. In 

addition to the vine and trellis wire, a vineyard may contain cross arms, as well 

as metal or wooden stakes and posts. Treated stakes (sometimes with metal 

braces) cannot be chipped and must be taken to a landfill. The posts currently 

being used are predominantly made out of steel. Metal stakes are removed 

before chipping and taken to a steel plant. The end posts can also be made out 

of redwood which can be burned. 

According to ag representatives, disposal methods for vineyard removal 

materials are the same for table, wine and raisins grapes. A grower will generally 

grow a crop to produce specifically table grapes, wine grapes or raisin grapes. 

However, some vineyards provide the grower some flexibility 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 several 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 situations where complete 

removal of the material, such as wire, can be difficult and expensive for the 

grower. When too much wire is embedded into the vines, chippers 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, vineyard removal materials are 

accepted. The only restriction with vineyard removal materials is that wire is 

removed and treated posts are taken out. Substantial amount of wire in the 

chipped material can cause problems for the biomass power plant. Other 

contamination (as long as not excessive) in the material, such as dirt, need to be 

controlled but is not a major concern to the operators since some amount of dirt 

is expected of all agricultural fuel. It is generally not an issue if the chipped 

materials are clean. 

While growers can hire laborers to remove most of the wires that connect the 

vines, it is not practical to remove the wire that is embedded into the cordon or 
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the canes. Ag representatives indicated that the raisin vineyards are pruned in 

such a way that the remaining canes are wrapped around the vineyard wire to 

support the crop. In order to chip the materials for 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 from 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 wrapping the vine around the 

wire in the second year. As the vine grows, the wire becomes more and more 

embedded in the vine, making it impossible to remove. In some trellis systems, 

there may be as many as four wires embedded in the cordon. Ag 

representatives also indicated that chipping operators have reported the wire 

causing problems and getting wrapped around the moving parts of their 

machinery, and that biomass facilities prefer not to 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 issue 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 FROM 

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 Removal Matter" as agricultural 

material generated by the removal of orchards. This 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 Service (NRCS) has 

encouraged growers to chip debris left from orchard or vineyard removals by 

providing a cost-share basis through the Environmental Quality Incentives 

Program (EQIP), which help reduce NOx, VOC, PM10, and PM2.5 emissions 

generated from open burning. The program also includes chipping of almond 

and walnut pruning, which will be discussed in Section 3.7.3 of this chapter. 

According to NRCS staff, the payment rate has increased 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 farm 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 amount of chipped materials 
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from the orchard and vineyard removal category averaged about 270 acres in the 

SJVAB per year, from 2007 to 2009. 

3.2.1 Orchard Removal Matter from a Total of 20 Acres 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 Category* 

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 matter from a total of 20 acres or 

less. The economic feasibility analysis is presented in Section E-2 in Appendix 

E. Biomass power plants appear to be the most technologically feasible 

alternative to open burning of orchard removal matter; however, due to the 

limiting factor of increased cost per acre for smaller acreage and availability of 

chipping operators, District staff believes that open burning be allowed to 

continue for small orchard removals. District staff recommends that the current 

open burning limit be reduced to 15 acres or less of orchard removal at a single 

location, per calendar year. District staff also recommends 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 smaller regardless of the 

total size of the farm. 

In addition chipping operator typically refuses small jobs, making it difficult for 

many growers to remove small acreages of orchard removals. The District has 

increasingly refused most requests for burns that are over 15 acres. The 

District’s Compliance Department has indicated that several requests above 15 

acres have been denied because the costs to chip and 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 chip and haul the orchard 

removal materials to the biomass power plants, where the cost per acre appears 
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to level out at about 15 acres or more. Further information 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 acres make up for most of the 

burns, over 84%. According to some growers and chipping 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 required 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. ARB concluded that the 

postponements will not substantially contribute to the violation of an applicable 

federal air quality standard, and discussed the important role of the District’s 

comprehensive smoke management program in preventing impacts to nearby 

communities. However, ARB noted that orchard removal 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 (apples, pears, and quince crops). 

As recommended above, figs would be considered as part of this category.

Growers typically need to remove some orchards every few years to keep the 

farm productive. Growers, ag representatives and chipping operators have 

expressed several concerns with the chipping of orchard removal matter from 

small acreage. Generally, small acreage growers are 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 are doing jobs less than twenty 

acres with an understanding that the cost of chipping has gone up. 

Chipping operators also charge a minimum fee (or move-in fee) to the grower. 

As a result of the minimum charge, the per acre cost for such small removals 

increases as the acreage becomes smaller. Based on the District’s cost analysis 

and information received from ag representatives, the 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 contractors, storage at biomass 

power plants, the crop type and density, topography, soil type, and location. 

Given these considerations and the fact that most growers are already chipping 

the orchard removals above 20 acres, District staff has used a conservative 

estimate for chipping costs for the analysis. 
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Ag representatives have indicated that when chipping operators work on small 

acreage jobs, growers are often forced to wait until 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 planted, 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 the open burning alternatives 

from growers before evaluating and determining whether a burn permit may be 

issued for less than 20 acres. District staff evaluated the economic feasibility of 

the alternatives based on the applications and copies of receipts, written bids, or 

supporting information for the economic justification. District staff has found that 

the case-by-case economic justification varies significantly, from net losses to the 

cost exceeding the ten-percent (10%) net profit threshold. 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 received a total of 1088 

applications for orchard removals of 20 acres or less per year. Of those 

applications, the District issued burn permits for 964 applicants of various farm 

sizes, including those that are greater than 100 cumulative acres. However, 

based on the evaluation of the economic justifications, 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 relative 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 analysis, the District has 

implemented narrowly the provisions for burning orchard removals of 20 acres or 

less. 
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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 single location, per calendar year 

after June 1, 2010. The economic feasibility analysis is presented in Section E-2 

of Appendix E. Fig orchard removals would be considered as part of the small 

other orchard removals category. District staff also recommends that there be no 

case by case determinations for additional acreage.

Description and Findings

When fig orchards are removed, the trees are typically no longer productive and 

would be replaced with new fig orchards or are no longer 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 materials 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% Yes 
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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 crops; however, the materials are typically 

blended with other materials and are less desirable. 

Recommendation: 

District staff evaluated the factors currently impacting citrus crops and the 

proposed alternative for disposal. The economic feasibility analysis is presented 

in Section E-3 in Appendix E. For citrus crops, District staff has considered 

biomass power plants as the most technologically and 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 accepted at biomass power plants 

at this time, due to the lack of future commitments to biomass plan operation. 

District staff recommends that citrus orchard removals continue to be allowed to 

be open burned. As recommended and supported by the 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), tangerines, and mandarins. 

According to the County Agricultural Commissioner’s Data for Calendar Year 

2008, oranges make up about 82% of the harvested acreage of citrus crops in 

the SJVAB. Growers typically remove old citrus orchards in the year prior to 

planting. Based on the District’s data, orchard removals from citrus crops are 

spread out through the year; however planting usually occurs between February 

and April. 

Citrus is often grown in clay-like soil that adheres to its roots. The extensive 

lifespan of citrus crops leads to the development of an extensive root structure 
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that is difficult to free of soil debris when the root 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 stump or root separately for the 

purpose of multiple uses increase the costs of operations, such as chipping and 

grinding. Furthermore, screening of chipped materials to remove excessive clay 

from stumps increases the overall citrus orchard removal 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 and ration it. 

In addition to the concerns noted above, growers, ag representatives and 

chipping operators have expressed several other concerns with the chipping of 

citrus crop orchard removal matter. Key concerns include 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 chips acceptable by the power 

plants, and 3) whether biomass operators will take citrus once the economy 

improves and they start getting more construction material. 

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 materials. Biomass power plant 

operators have indicated that mixing citrus chips with chips from other crops 

helps promote better flow of the chips through their equipment. In the past, one 

of the issues was that clay soil could become trapped in the rootballs and 

damage the power plant boiler refractories. The stringy nature of citrus tree 

chips could also clog conveyors and material handling equipment unless the 

chips were finely ground. Biomass power plant operators 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, maybe shorter in hotter 

temperatures. 

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

removal contractors to resolve the issues with citrus 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 citrus 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 agricultural biomass. 

For more information on biomass facilities, please refer to Chapter Eight of this 

report. 
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3.2.4 Apple, Pear, and Quince Orchard Removal Matter 

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 closed containers is beyond what 

is required for other orchard removals and therefore, 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 purpose. District staff recommends 

that open burning continue for these crops. 

Description and Findings

As mentioned above for prunings from pome fruits, crops such as apples, pears, 

and quince are susceptible to fire blight, a bacteriological disease that can 

spread through insects, wind, and mechanical devices and kills blossoms, 

shoots, limbs, and sometimes the entire tree. In most cases, the on-set of fire 

blight is unidentifiable and can be spread by contact or exposure to other healthy 

orchard material. For orchard removals, the equipments used to cut or remove 

the tree are also routinely sterilized with antibacterial agents to mitigate exposure 

to the disease or potential disease. 

Similar to pruning, orchard removals from apple, pear, and quince crops need to 

be burned to combat further spread of fire blight within orchards and to prevent 

potential infection of nearby orchards. As indicated by some operators and 

county ag commissioners, they are not aware of an effective treatment for fire 

blight. Growers have considered chipping the orchard 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/A 
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alternative is potentially spreading the disease to other orchards during 

transportation. In addition, biomass operators prefer 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 WATERWAYS, 

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 ponding and levee banks and 

recommends that open burning be allowed to continue as part of weed 

abatement activities affecting surface waterways, including ponding and levee 

banks. While chemicals and mowing are available for weed control in many 

locations, these alternatives are not viable because of the slopes and remote 

locations. 

Description and Findings

It is noted in the May 19, 2005 Rule 4103 Final Staff Report, that although some 

weeds and locations lend themselves to Best Management Practices (see 

Attachment 1 in Rule 4103), there remains a need for limited burning of some 

weeds. As mentioned earlier, this analysis does not include the category for 

“other weeds and maintenance”. The CH&SC required the District to establish 

best management practices in 2005 for the control of 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 alternative 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/A 
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The best management practices in the rule were developed 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 other alternative practices. 

Since 2005, open burning is no longer allowed for weed abatement activities 

from berms, fence rows, pasture, grass and Bermuda grass. However, open 

burning is currently allowed for weed abatement activities affecting surface 

waterways, including ponding and levee banks. The following materials are not 

considered to be part of the burn allowance for weed abatement activities 

affecting surface waterways, ponding, and levee banks: 1) weeds that originate 

from outside and away from the surface waterways, ponding 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 foreign materials. 

According to comments and information received from ag representatives and 

several agencies, there are currently no feasible alternatives to burning all of the 

weeds along surface waterways, ponding and levee banks. Landowners and 

operators have considered using hand crews for removing weeds but found the 

alternative to be impractical. Landowners and operators typically mow and spray 

most of the weeds or use flame desiccation, for direct heating of residual weed 

foliage and over growth of weeds to assure the destruction of weed seeds. One 

operator discs specific sites as needed. In many remote locations along surface 

waterways, ponding, and levee banks, fire is the only option for effective control 

of weed seeds and for safety of workers. 

In addition, ag representatives and agencies have indicated 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 nearly 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 Boards continue to push to 

eliminate the use of chemicals near any waterway. Recognizing these issues, 

many landowners and operators are controlling the use of chemicals along 

surface waterways, ponding, and levee banks due to concerns over runoff of 

chemicals from land to waterways. Ag representatives have provided a copy of 

the California’s Porter-Cologne Water Quality Act of 1969 and related information 

from the federal EPA (attached as part of Appendix B), which further explains the 
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water regulations. The California Porter-Cologne Water Quality Act regulates the 

discharge of waste into ambient waters, and authorizes Regional Boards to 

impose requirements on waste dischargers after consideration of several factors. 

Along with other responsibilities, the Regional Boards also regulate all pollutant 

or nuisance discharges that may affect either surface water or groundwater. One 

of the purposes of the federal Water Pollution Control 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 pollution sources. 

One operator indicated that the ability to burn occasionally would reduce the 

amount of chemical needed. According to the operator, the area of the banks by 

the water line make up about 0.2% of the agency’s total acreage and only a 

portion of that is burned annually. 

3.4 OTHER MATERIALS 

Other materials include brooder paper, deceased goats 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 primary disposal method for brooder 

paper is landfilling. District staff considers landfills to be a viable alternative to 

open burning and will recommend that these materials be prohibited from being 

burned. The District’s SMS data also shows an insignificant 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 animal facilities in the SJVAB. 

Poultry operators use brooder paper to protect their young birds during 

transportation and the first few weeks of life. In general, the paper needs to 

easily absorb poultry droppings and disintegrate for 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/A 
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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 practice in 

California." District staff also contacted an operator that burns the brooder paper 

used for raising ducks. The operator indicated that 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 alternative to open burning. District 

staff does not consider rendering to be a viable alternative to open burning due to 

the many issues noted for that technology. District staff recommends that these 

materials be prohibited from open burning. The District’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 goat production has been 

gaining in popularity in the United States in recent years. Some goat operators 

confirmed that there is increased demand for their products. 

The discussion below on deceased goats differentiates goats that expire from 

diseases (diseased) and goats that expire from other causes (not diseased). 

Deceased goats that were not diseased - Whether goats 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 few years with the disposal of 

goats that have died from causes other than diseases. 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/A 
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die off of goats due to high summer temperatures and the reluctance or refusal of 

rendering plants to accept goats due to concerns over 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 affecting the handling of diseased 

animals. Two diseases of particular concern are mad 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 of succumbing to contagious 

disease. The California Code of Regulations, California Food and Agriculture, 

Division 5, Part 1, Chapter 1, Section 9141 requires that "Any person that has the 

care or control of any animal that dies from any contagious disease shall 

immediately cremate or bury the animal." Section 9142 requires that "An animal 

which has died from any contagious disease shall not 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 deceased goats. Section 17855.2 of 

California Code of Regulations Title 14, Natural Resources, Division 7, CIWMB, 

Chapter 3.1, Compostable Materials Handling Operations and Facilities 

Regulatory Requirements, prohibits the composting of 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 the use of most mammalian 

protein in the manufacture of animal feeds given to ruminant animals, such as 

cows, sheep, and goats. The regulation also requires process and control 

systems to ensure that feed for ruminants do not contain the prohibited 

mammalian tissue. In 2008, FDA published a regulation 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. 
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When goats die from unknown causes, some operators will try to discover the 

cause of death by taking the carcass to a veterinarian 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 are that the diseases could be 

dormant in the frames and used equipment, as well as develop resistance to 

chemicals used in the sterilization process. The CH&SC specifically identify this 

crop type as “diseased” bee hives. District staff believes that there are currently 

no technologically feasible alternatives to open burning 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 Agriculture's science magazine, 

"Agricultural Research." The author Kevin J. Hackett (ARS National Program 

Leader, Biological Control, Beltsville, Maryland) noted in the March 2004 issue of 

Agricultural Research magazine that "The value of honey bee pollination to U.S. 

agriculture is more than $14 billion annually, according to a Cornell University 

study. Crops from nuts to vegetables and as diverse as alfalfa, apple, 

cantaloupe, cranberry, pumpkin, and sunflower all require 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 growers 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 bees 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/A 
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selected areas. Modern bee hives are usually constructed of wood and consist 

of several parts which include the following: 

• Bottom board - this has an entrance for the bees to 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 sheet 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 disorder (CCD), a phenomenon 

where bees mysteriously abandon their hives. The UC Davis Department of 

Entomology website contains an article dated Oct. 16, 2007, about a lecture 

presented by UC Davis honey bee specialist Eric Mussen. The article notes the 

following comment: "One-third of America's honey bees 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 they leave in less than a week, 

and only the queen and a few young workers remain".

Section 29208 of California Code of Regulations Title 3, Food and Agricultural 

Code, Division 13, Bee Management and Honey Production, requires that "If 

American foulbrood is found in an apiary, the abatement 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 associated appliances which 

are found in the apiary, in one of the following ways: If abatement is by burning, 

the person abating shall act in accordance with applicable air pollution control 

district or air quality maintenance district regulations 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." 
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3.5 RICE STUBBLE (STRAW) 

Until June 1, 2010, permits may be issued for the burning 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 stubble, spot burning of rice 

stubble, and burning of weeds and vegetative materials 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 open burning of rice stubble be 

allowed to continue for burns at 70% per year of the 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 prohibition 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 important to the successful production of 

the next crop. Burning has been the historical cultural 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 SJVAB are different from 

Sacramento Valley growers, where significant acres of rice are also farmed. 

Rice growers in the Sacramento Valley typically dispose 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/A 
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incorporating the rice straw into the soil. Unlike Sacramento Valley where water 

allocations allow post-season irrigating, water cannot be delivered to agricultural 

operations in the Northern SJVAB in the post-harvest season due to the annual 

distribution schedules designated by irrigation districts. Due to the lack of 

available water in the post-harvest season, rice growers in the SJVAB do not use 

soil incorporation to dispose of their rice straw because 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 their 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 baling 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 difficulty in their efforts to comply with 

the 70% burn allowance for 2009. Specifically, they were having difficulty in 

getting their rice straw baled and removed from their farms. The rice growers 

and a rice straw baling operator indicated that they have conducted several 

searches on alternatives to burning the rice material and there is currently no 

market for baled rice straw. In November 2009, a variance 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 their variance application that 

there were no viable alternatives currently available for disposal of the rice 

stubble. 

According to the District’s burn data for rice stubble, the annual burn acreage 

have fluctuated since 2006. This change is primarily 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 2007 to 2009. The market 

should continue to be assessed annually to ensure that rice stubble can continue 

to be used for other alternatives, such as dairies.
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3.6 Prunings from Apple, Pear, Quince, and Fig Crops 

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 crops 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 may 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 bacterial 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 bacterial disease that kills blossoms, 

shoots, limbs, and sometimes the entire tree. Insects, wind, and mechanical 

devices can spread fire blight. According to the ag 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 potential disease. The unrestricted 

movement of infected tissue will cause the disease to spread rapidly and under 

certain environmental conditions (hot and wet). Containment of the infected 

tissue is an essential element for control. 

Apple, pear, and quince prunings are burned to combat further spread of fire 

blight within orchards and to prevent potential infection 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/A 
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Some operators and county ag commissioners have indicated that they are not 

aware of an effective treatment for fire blight. Chemicals that are used to control 

the bacterial disease could prove ineffective if the disease becomes resistant 

over time. According to an agricultural commissioner, the options for controlling 

fire blight that is becoming resistant to chemical means of control with 

Streptomycin are burning on site or disposal by placing 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 alternative 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 prunings from fig crops. 

Shredding the fig prunings and allowing it to decompose should not be a 

significant fruit degradation concern for fig orchard removal as the chipped 

material should have decomposed or be reduced in size by the time of harvest. 

The current mowing and sorting practices would help reduce any excessive 

materials from the figs during harvest. As a result, District staff recommends that 

open burning be prohibited for prunings from fig crops.

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 pruning 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/A 
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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 manage 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 from grape vines and grape 

canes are already widely practiced, District staff considers soil incorporation to 

be a viable alternative to open burning and recommends that prunings from 

grape vines and grape canes be prohibited from open burning. 

Description and Findings

This category does not include grape attrition. According to the District’s policy, 

attrition is vegetative materials not associated with pruning (as defined in Rule 

4103) or orchard removals. Attrition materials include the incidental cuttings of 

dead or broken branches, tree mortality, water sprouts or suckers, or other 

damage to tree crops. Attrition materials may be burned provided that the 

materials are listed on a valid burn permit and daily 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 usually pruned once a year in 

the winter when the grape vine is dormant. Wine vineyards now have high 

tensile wire to withstand the machines that go through the rows during pruning. 

The pruned grape canes and any other pruned material, such as spurs, are 

positioned in the center of the grape vine rows and shredded. Many growers 

typically shred their grape vine pruning material using a tractor and a shredder. 

Grape canes and other materials from the grape vines do not include the 

prunings from kiwi crops, which are already subject to Rule 4103. 
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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/grtrainprune.html 

According to ag representatives and growers, the shredding and soil 

incorporation of grape cane prunings and other pruning materials from a grape 

vine have been long time traditional practices of growers. According to ag 

representatives, growers and biomass power plant operators, 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 District May 20, 2010 

 Revised July 21, 2010 

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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 open 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 addition, 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 mechanical 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 growers implement the practices 

below to control open burning of raisin trays and that 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 were used in the past, but have 

been replaced by paper trays. Due to changes in farming practices and other 

factors, several new paper trays have been developed. 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 inches wide and 36 inches long 

although other sizes are available for certain situations. 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/A 
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the development of mechanical harvest machines. The continuous paper is a 

heavier weight than individual trays. 

Once the raisins have cured adequately and the moisture in the rolls is 

acceptable, normally in late September, they are ready to be collected. Raisins 

must be at 16 percent or less moisture content to meet the industry’s incoming 

inspection requirements. There are several methods used for collecting the 

raisins and preparing them for the next step in their processing. After the raisins 

are collected, they are separated from the raisin trays 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 disposal. 

Growers have continued to pursue alternative ways to burning raisin trays for 

over 50 years. Ag representatives indicated that only about 50,000 acres of 

vineyards using raisin trays are expected by 2015 because growers are 

transitioning to mechanical harvesting, which does not include the use of raisin 

trays. It is expected that there will be a continual reduction in burning. The long 

term goal of the California raisin industry is to transition toward 100% 

mechanization of raisin harvest and drying5

. 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 shows 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 shipped to China. The growers were 

typically charged a fee when the recycling firms picked 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 trays to China is no longer a 

feasible alternative. 

District staff has considered soil incorporation and biomass power plants as 

possible alternatives; however, the materials in the raisin trays create several 
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potential issues. Ag representatives have indicated that some growers grind and 

soil incorporate their raisin trays. The raisin trays contain polymer (5%) so that 

the moisture on the ground can not be absorb efficiently 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 decompose and some pieces will 

scatter around. Growers prefer clean fields for operations, 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. According to biomass power plant 

operators, both Madera and Mendota power plants are permitted to burn paper. 

Power plant operators indicated that they are willing to work with the District to 

address these issues. Power plant operators are determining a way to 

incorporate raisin trays into their fuel and analysis 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 of 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 times when the raisin trays 

are burning, by able bodied adults with adequate tools 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 lines, 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 provided 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 winds caused by 

vehicles could cause the fire to escape from the fire safety zone. 
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6) Don’t cause a smoke nuisance to your neighbors. 

District staff will work with the Ag stakeholders to 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 Section E-4 in Appendix E. 

Based on the considerations and analysis for prunings 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 agricultural 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 estimate(s) for 

shredding all prunings generated by the total nut acreage at 

the agricultural operation site. The cost estimate(s) shall 

reflect shredding in a time frame that allows the operator to 

proceed with established post-pruning cultural practices. 

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 are 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% Yes 
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available in time for the operator to proceed with established 

post-pruning cultural practices. 

Description and Findings

Although the pruning methods will vary among growers, nut crops in general 

would have similar or common practices. So, unless otherwise noted, the 

following description for nut crops applies to almonds, walnuts, and pecans. 

Nut trees are usually pruned after harvesting, either late or early in the year. In 

the past, growers generally open burned nut prunings to dispose of the material. 

However, many growers have found alternative ways to convert prunings into 

something useful such as soil amendment, dust control on unpaved surfaces, 

compost material, or fuel for biomass power plants. According to published 

documents and stakeholder comments, most nuts growers 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 continued to help minimize 

impact on air quality through environmentally responsible efforts, which include a 

contract with a biomass power plant to take its orchard removals and prunings. 

In 2008, another farm of several thousand acres initiated cultural practices and 

equipment necessary to shred all of the prunings rather than burn. District staff 

has also received comments from growers and custom shredders indicating that 

shredding of nut prunings has been a successful procedure in the farming 

operation, particularly for walnuts for one grower. However, there were also 

concerns from other growers regarding the burn prohibition for the prunings of 

nut crops. 

A primary concern that some almond and walnut growers have is preventing the 

pruning material from interfering with the harvesting of the crop. Some of the 

existing shredding equipment currently shred the materials 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 whereas 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 minimize the number of tractor 

passes in their orchards. 
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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 may 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 hull processors that convert the 

hulls into animal feed. In order to keep the ground surface free of pruning 

material at harvest time, many growers have mostly relied on removing the 

pruning material from the field and open burning the pruning material. 

Ag representatives also provided the following information to the District. The 

hull has significant feed value to dairies, and hulls 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 content of between 15% and 29%. And 

lastly, the shell or any product that has greater than 29% fiber content has little 

value and hardly any market. The almond hullers that the ag representatives 

spoke to estimate a five percent to 11% loss in prime 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 survey 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 content and when picked up with the 

hulls during the hulling process, they can significantly 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 existence 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; however, 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 representatives, the walnut growers 

and walnut processors have indicated that the primary issue is that the chips plug 

the lines at the processor, especially under wet conditions. 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 get a chipper into the orchard until 

after the rains subside. The chips do not decompose 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 the walnuts through the 

ductwork at a huller/dehydrator and processor, as the chips are picked up with 

the walnuts. 
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Ag representatives stated that walnut processors have also expressed concern 

with the chips being left in the orchard due to concerns 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 significant food safety issue in terms of 

the potential for aflatoxin. Food safety has become the number one issue of 

concern for the tree nut industry, and any issue that would confound food safety 

would be problematic. 

As the trees are pruned late in the year, the ground is usually too wet to run 

heavy equipment in the field in order to chip the prunings. 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 and the pruning material can 

interfere with these operations. This gives the growers a short window of 

opportunity to have their prunings chipped. Some growers usually find it more 

conducive to their operations to gather the prunings and burn them. 

For growers that shred the pruning material as an alternative method to open 

burning, the practice varies among nut growers. In addition, the pruning practice 

for the growers in the northern region appears to be different than the southern 

region. Growers could shred the prunings by renting, purchasing, or borrowing 

special equipment, or by hiring a custom shredder. These options depend on the 

availability of the custom shredder or the equipment. 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 around $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 $300,000 and is an expensive 

option and less likely for a small grower. 

Ag representatives, custom shredders, and growers have mentioned that there is 

a shredder in the market which can shred the prunings into smaller pieces, 

thereby reducing problems during the harvest season. The shredder can also 

operate in all weather conditions, including the raining season. The vendor of the 

shredding equipment has indicated that 48 of those shredders are currently 

available for the industry and that previous shredding equipments have been sold 

mostly to growers where some also provide custom shredding service. One of 

the custom shredder indicated that most growers that farm over 3500 acres 

typically shred their own material and that it would be more costly for a grower 

that farms less than that to purchase the same shredder. 
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District staff conducted an analysis to determine whether it would be viable for 

growers to purchase a shredder instead of hiring a custom shredder. The 

following information was used to conduct this analysis: 

1. Harvesting ends in October and cultivation begins around 

January/February. District staff estimated that the available months 

during the pruning season are November, December, and January (three 

months). 

2. According to a custom shredder, the specific shredding 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 material. 

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 Pruning 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 approximately 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 heavy to light prunings from 

the nut orchards. As mentioned by the vendor and custom shredder, many 

growers that own their own shredding equipment also provide custom shredding 

service to other growers. 

District staff conducted further analysis on the cost benefit of purchasing the 

shredding equipment for a farm over 3500 acres. The analysis below is intended 

to compare the two methods for the shredding alternative and is not 

representative of the incremental cost. The analysis is based on the following 

factors: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-34 Chapter 3: Technical and Economic 

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Final Staff Report and 

Recommendations on Agricultural Burning

1. Hiring a Custom Shredder: 

• Per custom shredder, the average charge is $520 for 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.html)

• Based on the above information, minimum averaged cost 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 operators, which 

includes payroll overhead of 34%. 

(Reference: http://coststudies.ucdavis.edu/files/almondvs08sprink.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/almondvs08sprink.pdf) 

• Fuel use for a shredding machine with similar horsepower is 12 to 

15 gallons per hour. District staff estimates that the averaged 

amount of fuel (diesel) required to operate the shredder for one 

hour is 14 gallons (References: 

http://www.jgpress.com/archives/_free/001555.html and 

http://www.neequip.com/KFNA/BROCHURES/PDF_BRO/Crambo_2005E.pdf)

• Annual maintenance is calculated as two percent of the purchase 

price. (Reference: http://coststudies.ucdavis.edu/files/almondvs08sprink.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 the 

capital recovery. (Reference: 

http://coststudies.ucdavis.edu/files/almondvs08sprink.pdf)

Based on the best available information and analysis above, the following 

calculations use 3564 acres per year for an equivalent comparison of the cost of 

purchasing a shredder and the cost of hiring a custom shredder. 

 

The calculation for hiring a custom shredder is as follows: 

1. Total Annual Cost of Hiring a Custom Shredder 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

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Minimum Averaged Cost Per Acre x Number of Acres: 

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

The calculations for purchasing a shredder are as follows: 

1. Total Annualized Capital Costs of the Shredder 

The District uses the following formula to calculate 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, including 

installation cost 

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

n = Equipment life (used 10 years as a conservative 

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 Hour 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 Per 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 the Shredder: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-36 Chapter 3: Technical and Economic 

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$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 Percent 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 hiring a custom shredder. 

Table 3-17 – Annualized Cost Estimates for the Purchase 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 $7,783

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 Shredder 

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 District May 20, 2010 

 Revised July 21, 2010 

3-37 Chapter 3: Technical and Economic 

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Recommendations on Agricultural Burning

According to GrowingProduce.com, the 2009 Top Nut Growers 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 database or the Conservation 

Management Practices (CMP) database. The 18 growers make up about 

183,154 acres of nut crops. Pistachios contribute to about 16% of the total 

acreage in the SJVAB, therefore the estimated acreage 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 3,500 total farm acres of nut 

crops and contributes to over 94% of the top acreages on the list, or about 

212,000 total nut acreages. At least two growers in this group are either 

shredding the pruning material or taking the material to the biomass power plant. 

Based on the 2007, 2008 & 2009 Top Nut Growers tables, 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 percent range, the total nut 

acreages average about 3460 acres. 

According to the custom shredders, the average charge 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 the 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 on 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 shredders in the SJVAB that 

operate a total of five of those shredders and another two contractors that do 

custom shredding. There are also several types of other shredding equipment 

available, where some may require more passes in order to shred the prunings 

into acceptable sizes. 

The Jack Rabbit equipment is typically used to remove the material from the 

orchard. Transporting the material to composting facilities appear to be less 

common among growers compared to shredding the material 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 for most pruning material is to 

shred and leave the material on the ground, since it can be more efficient than 

chipping and transporting the material offsite. Some 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 of 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

3-38 Chapter 3: Technical and Economic 

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Categories and Recommendations 

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PM2.5. The amount of burn acres from walnut prunings 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 emissions reduced since then 

could be even higher as a result of lighter prunings. 

Over the past ten years, NRCS has encouraged growers to chip or shred the 

prunings from almond and walnut orchards by providing a cost-share basis 

through the Environmental Quality Incentives Program (EQIP). According to 

NRCS staff, it is uncertain how long this program will last. Many of the growers 

shred the material on site through this program, which helps reduce Nox, VOC, 

PM10, and PM2.5 emissions generated from open burning. 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 prunings burned from the 

District’s database was 68,802 acres per year. According to the County 

Agricultural Commissioner’s data for Calendar Year 2008, the total harvested 

acreage for both of those crops in the SJVAB was 753,515 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 alternative methods for almond 

and walnut prunings. Pecans are not included in the analysis below because 

NRCS data only addresses almonds and walnuts. 
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Recommendations on Agricultural Burning

Table 3-19 – Analysis of Alternative Methods for Almond and Walnut 

Prunings 

Surface Harvested Prunings from Almond and Walnut Crops 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 Year1 376,758 

Chipped/Shredded Acreage of Almond & Walnut Prunings per year 

(NRCS) 

120,592 

Open Burned Acreage of Almond & Walnut Prunings per year 

(District) 

68,802 

Estimated Acreage from Alternative Disposal of Almond & Walnut 

Prunings2

187,364 

1

Assume Pruning is done in alternate years: [(753,515) / 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 alternative method of chipping and shredding onsite 

and indicated that the practices will vary among growers and regions. 

2

The remaining acreage is likely to be voluntary disposal 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 harvested 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 analysis above, about 18% of the 

acreage pruned per year is contributed to open burning, while most of the 

growers are using other alternative practices rather than open burn. 
San Joaquin Valley Unified Air Pollution Control District 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

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