Appendix H 

REVISED 

Proposed Revision to the Pesticide Element of the 1994 Ozone 

SIP for the Ventura County Nonattainment Area 

(August 13, 2007)
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August 13, 2007 Appendix H – Revised 1 

REVISED 

Proposed Revision to the Pesticide Element of the 1994 Ozone SIP for the 

Ventura County Nonattainment Area 

In the 1994 Ozone SIP, the Department of Pesticide Regulation (DPR) 

committed to obtain Reactive Organic Gas (ROG) emission reductions from 

pesticides in the five 1-hour ozone nonattainment areas. For the Ventura County 

nonattainment area (Ventura), the target was a 20 percent ROG emission 

reduction from the 1990 base year emissions by 2005 (see 62 Federal 

Register 1169-1170; January 8, 1997). 

In all nonattainment areas, DPR’s proposed fumigant regulations will achieve all 

of the ROG reductions from pesticides that are required by the 1994 Ozone SIP. 

DPR’s proposed regulation expects to achieve all the reductions in 2008. 

Reductions will be achieved by instituting a regulatory cap on pesticide emissions 

and placing annual limits on fumigant emissions to ensure the overall pesticide 

emission cap is not exceeded. The measures include changing to application 

methods with lower emissions. Monitoring studies demonstrate that emissions 

differ between methods of applications. Emissions can be significantly reduced 

through tarping, irrigating after applications, or applying through drip irrigation 

systems. Changing to these applications can provide a feasible means for 

meeting the overall emission limits for fumigants. Quantifying the difference in 

emission rates associated with different fumigant application methods also 

accounts for the revisions to earlier estimates of pesticide ROG emissions, 

including revisions to the baseline estimates. Widescale adoption of low 

emission practices will assist in meeting the pesticide emission cap, but will not 

likely meet the entire demand. The measures anticipate a mechanism to 

allocate, track and oversee fumigant emissions. 

Land use changes in Ventura have created difficulties in meeting the fumigant 

cap in the proposed 2008 Pesticide Plan. Overall pesticide ROG emissions, and 

fumigant emissions in particular, have increased over the last several years in 

the Ventura nonattainment area, from approximately 3.3 tpd in 1991 to an 

estimated 4.8 tpd in 2004. Fumigants represent 80-90% of the overall pesticide 

emissions in Ventura. The increased emissions are due to changes in Ventura 

cropping patterns. Crops that require annual fumigation are replacing crops that 

require minimal fumigation. For example, fumigant use for strawberries accounts 

for most of the pesticide ROG emissions in the Ventura nonattainment area, and 

strawberry acreage has increased from 4,500 acres in 1996 to 10,300 acres in 

2004 (McPhail 1997, 1999, 2001, 2003, 2006; Figure 1). Smaller acreage 

increases occurred for raspberries and fresh market tomatoes that require annual 

fumigation. The increased strawberry, raspberry, and tomato acreage coincides 

with a decrease in acreage for crops that require less fumigation, such as citrus 

(grapefruit, lemon, orange) and most vegetables (broccoli, cabbage, carrot, 

cauliflower, celery, lettuce, parsley, spinach). Under the proposed measures, 

Ventura would be required to reduce its pesticide emissions in 2008 by 46% 
August 13, 2007 Appendix H – Revised 2 

(2.2 tpd) based on 2004. Adoption of Best Available Control Technology (BACT) 

will not allow all of the planted acres to remain economically viable and to meet 

pesticide emission cap. 

Figure 1 

Trends of harvested acres in Ventura 

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

1996 1998 2000 2002 2004 2006

Year

Harvested Acres

Citrus

Raspberries

Strawberries

Vegetables

Tomatoes

DPR estimates that approximately 83% of the fumigant emissions in the Ventura 

nonattainment area come from applications that already employ Best Available 

Control Technology (BACT), such as tarping, intermittent irrigation following 

fumigation, or application using drip irrigation systems (Barry, et al. 2007). 

Comments received on the proposed regulations indicate that BACT adoption 

may be greater than currently estimated. However, even if all fumigant 

applications adopted BACT, an additional 34% (1.3 tpd) fumigant emission 

reduction from 2008 levels would be needed to achieve the overall pesticide SIP 

commitment. To achieve this reduction, growers and applicators will need to 

employ some combination of acreage reduction, application rate reduction, and 

shifting applications outside the May – October window. The likely scenario 

would be that land would not remain in agricultural production. DPR estimates 

that 5,800 – 7,500 acres would be lost if the 1.3 tpd ROG reduction is achieved 

solely through acreage reduction (Spurlock 2007). 

A draft analysis of the proposed regulations predicts that most growers will 

reduce fumigant application rates to achieve the needed ROG reductions in 

Ventura, with the fumigated area reduced by several hundred acres (Goodhue, et 

al. 2007). The reduced application rates would cause a decrease in yields, with 

the most likely scenario leading to a loss of $11 million, and a maximum loss of 
August 13, 2007 Appendix H – Revised 3 

$31 million. Separate analyses by ARB (Dean 2007) and the California 

Strawberry Commission (Murai 2007) estimated losses of up to $80 million and 

$286 million, respectively, based on a 10,000 acres reduction. 

In the short term, the loss of these high value crops would likely have a negative 

economic impact on the farm economy and farm employment in Ventura. 

Growers would be expected to recuperate that loss by converting the land to 

other uses. Although it is unknown what the new uses would be, a reasonable 

possibility is that a significant number of acres would be converted to nonagricultural uses (such as housing developments). The conversion of agricultural 

land to other uses would likely result in various adverse environmental impacts, 

the extent of which cannot be analyzed at this time. 

An extensive amount of research is being conducted by federal and state 

agencies as well as commodity groups on ways to reduce pesticide emissions. 

ARB has funded some of these approaches. With the enactment of the 2007-08 

budget, DPR will restore its Pest Management Alliance grant program that funds 

pesticide use reduction programs. These efforts will lead to improved BACT but 

not in time for the 2008 season. DPR expects that, as further research is 

completed over the next few years, the ability for growers in Ventura County to 

further reduce pesticide emissions will also increase. 

To avoid the potential impacts described above, ARB proposes to revise the 

Pesticide Element of the 1994 Ozone SIP for Ventura only. This SIP revision 

would substitute emission reductions from other sources of ROG for a portion of 

the emission reductions committed to in the 1994 SIP for pesticides. There 

would be no “backsliding” from the overall 1994 SIP commitments for Ventura, 

because all the ROG emission reductions committed to in the 1994 SIP would 

still be achieved. What would change is the source of the emission reductions – 

a portion of the ROG reductions for Ventura would come from other emission 

sources instead of pesticides. 

ARB staff has calculated the amount of ROG emission reductions that have been 

achieved in Ventura since 1994. This analysis shows that all of the ROG 

reductions committed to (except for those anticipated to come from pesticides) 

have already been achieved in Ventura County (Table 1). Plus, between 2005 

and 2008, an additional 1.9 tpd of ROG reductions will be achieved from 

California’s on-going mobile source and consumer product emission control 

program (Table 2), beyond the reductions committed to in the 1994 SIP. 
August 13, 2007 Appendix H – Revised 4 

Table 1 

2008 Emission Reductions Compared to 

1994 SIP Emission Reduction Commitment 

in Ventura County APCD* 

Emission Reduction Commitment** 4.11 

 

Enhanced Vehicle Inspection and 

Maintenance 0.98 

On-Road Measures 1.08 

Off-Road Measures 0.90 

Consumer Product Measures 1.16 

Total 1994 SIP New Measure Emission 

Reductions Achieved 4.11 

* All emissions are reported in the 1994 SIP emission 

inventory currency. Does not include DPR, or local 

(stationary or area-wide) commitments 

** Commitment for Emission Reductions in 2005. 

Table 2 

Decline in ROG Emissions from California’s 

On-going Mobile Source and Consumer Product 

Emission Control Program* 

 2005 2008 Change 

On-road Emissions 11.4 9.0 2.4 

Off-road Emissions 4.0 4.1 -0.1 

Consumer Product Emissions 5.7 6.1 -0.4 

Total 21.1 19.3 1.9 

 

* Does not include pesticide emissions, or local (stationary or 

area-wide) emissions under the jurisdiction of the Ventura 

County Air Pollution Control District. Does not include 

benefits of new measure commitments identified in Table 1, 

above. All emissions are reported in the 1994 SIP emission 

inventory currency. 

Notes: ARB did not have emission reduction commitments 

beyond 2005 in Ventura County. As such, all declines in 

baseline achieved through California's on-going mobile source 

control program are surplus to the emission reduction 

commitments in the 1994 SIP for Ventura County. 

ARB staff’s May 7, 2007 Proposed State Strategy proposed to revise the 1994 

Ozone SIP to substitute 1.0 tpd of ROG emission reductions from California’s ongoing mobile source emission control program for 1.0 tpd of the ROG emission 

reductions committed to for pesticides in the 1994 Ozone SIP in Ventura County 

in 2008. 
August 13, 2007 Appendix H – Revised 5 

ARB received written comments and heard testimony at its June 22, 2007 public 

meeting on the State Strategy expressing concern about the impact the 

additional pesticide emissions could have on ozone formation, and about the 

toxic air contaminants that would result from the continued use of fumigants. 

ARB also heard testimony that failure to provide substitute emissions for the 

entire shortfall – estimated by industry representatives at 1.9 tpd -- would result 

in adverse economic impacts for strawberry farmers, and could force some fields 

out of production. 

Potential Impacts on 8-hour Ozone Planning in Ventura County 

Ventura County is designated as nonattainment for the federal 8-hour ozone 

standard, classified as a “moderate” nonattainment area with an attainment date 

of June 15, 2010. Effectively this means Ventura must attain the standard in 

2009, since nonattainment areas must show attainment for a complete ozone 

season prior to the attainment date, and the ozone season in California is year 

round. Because a 2009 attainment requirement allows little time for the 

implementation of new controls to ozone-forming emissions, attainment by 2009 

is largely dependent on reductions from the existing control program. Preliminary 

photochemical modeling results indicate that Ventura will not attain the standard 

in 2009. Ventura District staff has indicated that they may recommend that their 

Board request reclassification as a “serious” ozone nonattainment area. Such a 

“bump up” would give the area a June 15, 2013 attainment deadline and would 

require attainment in 2012. 

The photochemical modeling indicates that ozone formation in Ventura responds 

to both NOx and ROG reductions. ARB staff’s estimates indicate that Ventura 

needs NOx reductions of approximately 16 tons per day (tpd) and ROG 

reductions of 7 tpd in order to attain the standard in 2012. Existing State and 

local controls will reduce emissions by approximately 11 tpd NOx and 6 tpd ROG 

by 2012. The measures in the proposed State Strategy will provide an additional 

5 tpd NOx and 1 tpd ROG. Since Ventura is impacted by air pollution transport 

from the South Coast, Ventura’s air quality will also benefit from emission 

reductions in the South Coast Air Basin. As mentioned previously, 80 to 

90 percent of the pesticides applied in Ventura County are fumigants. Nearly half 

of the fumigants applied are methyl bromide, and methyl bromide is a low 

reactivity ROG (Carter, et al. 2007). Given these emission reductions and the 

low reactive nature of methyl bromide, preliminary analysis still shows a very 

close attainment demonstration for 2012. 

ARB staff is revising its ROG substitution proposal for Ventura County, as 

described below, in light of the reductions needed to ensure expeditious 

attainment of the federal 8-hour ozone standard, and in light of the comments 

received in response to the original proposal. 
August 13, 2007 Appendix H – Revised 6 

1) In the May 7, 2007 proposal, staff recommended the substitution of 1.0 tpd 

ROG reductions. Staff is now recommending that ARB provide 1.3 TPD in 2008, 

reflecting updated DPR estimates of the ROG emission reduction shortfall. 

2) In the May 7, 2007 proposal, staff did not identify an end-date for the use of 

substitute ROG emissions. Staff is now recommending a phase-down that 

provides 1.3 tpd of ROG reductions starting in 2008, declining to zero by 2012. 

This will provide DPR with the time necessary to identify and construct additional 

pesticide measures to achieve the remaining necessary reductions, and will help 

ensure that reductions are in place by the 2012 “serious” area attainment 

deadline. The proposed ROG substitution schedule shown below reflects this 

phase-out. 

Table 3 

Proposed Commitment for 

Surplus Emission Reductions 

Used to Meet the 1994 Pesticide SIP Commitment

Year ROG (tons per day) 

2008 1.3 

2009 1.0 

2010 0.6 

2011 0.3 

2012 0.0 

This proposed revision will ensure that all of the pesticide reductions required 

under the 1994 SIP commitment will be achieved, by 2012, as a result of the 

pesticide use and application controls included in the proposed 2007 State 

Strategy.
August 13, 2007 Appendix H – Revised 7 

References 

Barry, T., F. Spurlock, and R. Segawa. 2007. Pesticide Volatile Organic 

Compound Emission Adjustments for Field Conditions and Estimated Volatile 

Organic Compound Reductions – Initial Estimates. Memorandum to John 

Sanders, April 6, 2007. California Department of Pesticide Regulation. 

Carter, W. P.L., and I.L Malkina, 2007. Investigation of Atmospheric Ozone 

Impacts of Selected Pesticides. Report to the California Air Resource Board. 

Dean, B. 2007. Consultation on Draft Regulations on Fumigants. Memorandum 

to Linda Irokawa-Otani, April 18, 2007. California Air Resources Board. 

Goodhue. R.E., R.E. Howitt and P.H. Howard. 2007. Effects of 2007 Proposed 

Fumigant Use Regulations on Sacramento Valley, San Joaquin Valley, and 

Ventura County Agriculture, Draft Report, June 28, 2007. Report to the California 

Department of Food and Agriculture. University of California, Davis, Department 

of Agricultural and Resource Economics. 

McPhail, W.E. 1997. Annual Crop Report, 1996, October 15, 1997. Ventura 

County Agricultural Commissioner. 

McPhail, W.E. 1999. Annual Crop Report, 1998, September, 23, 1999. Ventura 

County Agricultural Commissioner. 

McPhail, W.E. 2001. Annual Crop Report, 2000, August 2001. Ventura County 

Agricultural Commissioner. 

McPhail, W.E. 2003. Annual Crop Report, 2002, July 15, 2003. Ventura County 

Agricultural Commissioner. 

McPhail, W.E. 2006. Annual Crop Report, 2005, July 5, 2006. Ventura County 

Agricultural Commissioner. 

Murai, M. 2007. Comments on the 2007 SIP – Appendix H, June 20, 2007. Letter 

to Robert Sawyer, California Air Resources Board. California Strawberry 

Commission. 

Spurlock, F. 2007. Ventura County Acreage Reduction Estimates. Memorandum 

to Randy Segawa, August 2, 2007. California Department of Pesticide 

Regulation.