Final Staff Report for Rule 4565

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

Revised Proposed New Rule 4565

(Biosolids, Animal Manure, and Poultry Litter Operations)

March 30, 2007

Prepared by: Sandra Lowe-Leseth, Air Quality Engineer

Reviewed by: Maria Stobbe, Planning Manager

George Heinen, Supervising Air Quality Engineer

Joven Nazareno, Senior Air Quality Engineer

Mike Buss, Senior Air Quality Engineer

Brian Clements, Senior Air Quality Engineer

Lucinda Roth, Senior Air Quality Specialist

Lori Sheriden, Air Quality Inspector

I. SUMMARY

A. Reasons for Rule Development and Implementation

In terms of state and federal standards, the California Air Resources Board (ARB) and 

United States Environmental Protection Agency (EPA) classified the San Joaquin Valley 

Air Basin (SJVAB) as a non-attainment area for ozone. The District is classified as a 

serious non-attainment area for the federal 8-hour ozone National Ambient Air Quality 

Standards (NAAQS). It is anticipated that attainment of the eight-hour standard will 

require the control measures cited in the District’s Extreme Ozone Attainment 

Demonstration Plan (Ozone Plan), which includes a control measure for 

composting/biosolids operations. Since Rule 4565 is a control measure in the District’s 

Ozone Plan, it is subject to Federal Register, Clean Air Act (CAA), and California Health 

and Safety Code (CH&SC) requirements. Additionally, anti-backsliding provisions commit 

the District to develop all control measures listed in the Ozone Plan (Federal Register 

Volumes 69 and 70). This rulemaking project is intended to satisfy the attainment goal 

listed in the Ozone Plan. Additionally, the rulemaking project will seek to obtain as much 

VOC emissions reduction from the source category as is expeditiously practicable, 

technologically feasible, and economically reasonable, as determined by the District's 

Governing Board. Furthermore, the rule is intended to satisfy the requirements identified 

in Table 1.
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Table 1: Anti-backsliding and Ozone Plan Commitments

Subject Reference Requirement

Antibacksliding69 Federal Register 

23955

Districts shall develop all control measures 

listed in the Ozone Plan until the District is 

designated as in attainment for the 8-hour 

NAAQS.

BACM Federal Register 

8/18/94

Provisions in attainment plans should include 

the application of best available control 

measures (BACM) to existing major stationary 

sources.

BARCT CH&SC 40919(a)(3)

Ozone attainment plans should provide for 

best available retrofit technology (BARCT) for 

existing permitted sources. 

Deadlines Ozone Plan Rule adoption by the 1st quarter of 2007.

All Feasible 

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all feasible control measures."

RACT

Federal Clean Air Act 

(CAA) Sections 

182(b)(2) and 182(f)

Ozone attainment plans shall assure that 

reasonable available control technology 

(RACT) for volatile organic compounds (VOC) 

is in use at sources and on source categories 

at or above the RACT threshold.

RACT 

Threshold

70 Federal Register 

30592-30596

The applicable RACT threshold for control 

measures shall be the threshold in effect on 

June 15, 2004. The Districts threshold on 

June 15, 2004 was 10 tons per year (tpy) for 

VOC. Therefore, 10 tpy is the RACT 

threshold for Proposed Rule 4565. 

Reductions Ozone Plan

The rule shall reduce VOC emissions by at 

least 14% from the baseline by 2010. 

Fourteen percent of the baseline used for the 

Ozone Plan (0.7 tpd) is 0.1 tpd.

Timeline CAA Section 

172(c)(1)

Ozone attainment plans shall implement 

control measures as expeditiously as 

practicable, and provide for attainment.
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B. Description of the Project 

The main objective of this rulemaking project is to limit VOC emissions from facilities that 

manage biosolids, animal manure or poultry litter. Biosolids are sewage sludge that has 

been treated to meet standards for land application under Part 503 of the Clean Water 

Act. Sewage sludge is treated in the wastewater process, generally through aerobic or 

anaerobic microbial activity for a specified time at a specified temperature. Sewage 

sludge requires treatment to ensure that its release into the environment is protective of 

human health and the environment as required by the Clean Water Act. 

II. CURRENT REGULATIONS

Currently, the District does not have any prohibitory rules that specifically regulate VOC 

emissions from facilities that manage biosolids, animal manure, and poultry litter. 

However, some composting facilities may already be subject to permit requirements as a 

new or modified source or as a source emitting significant air emissions under District 

Rule 2010 (Permits Required) and District Rule 2201 (New and Modified Stationary 

Source Review Rule). 

III. DISCUSSION

Biosolids, animal manure, and poultry litter are commonly managed in one of three ways: 

buried in landfill, applied to land to enrich the soil, or composted either alone or with other 

materials to make a soil amendment. When biosolids, animal manure, or poultry litter are 

composted with other materials like greenwaste or bedding, it is called co-composting. 

Looking at biosolids specifically, the California Association of Sanitation Agencies (CASA) 

surveyed facilities that generate biosolids. The 750,000 dry tons per year of biosolids in 

California are managed in the following ways:

 4% surface disposed

 5% incinerated or stored in temporary storage

 6% disposed of in landfills

 12% used as alternative daily cover (ADC) at landfills

 54% land applied

 16% composted

Rule 4565 would address VOC emissions from landfill, land application, composting, and 

co-composting operations. 

A. Section 1.0 Purpose/Section 2.0 Applicability

The purpose of the rule is to limit volatile organic compound (VOC) emissions from 

operations that manage biosolids, animal manure, or poultry litter. The rule applies to any 
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facility that landfills, land-applies, composts, or co-composts material containing one or 

more of the following: biosolids, animal manure, or poultry litter. Sewage treatment 

plants or other wastewater treatment facilities are not subject to this rule unless the 

operator landfills, land applies, composts, or co-composts the treated material (biosolids) 

on site.

B. Section 3.0 Definitions

This section lists definitions that pertain to the rule. During the course of rule 

development, adding and modifying definitions have improved rule clarity. The rule has 

changed the carbon dioxide respiration end points and the Solvita Maturity Index numbers 

for active, curing, and finished compost to match Test Methods for the Examination of 

Composting and Compost by the US Composting Council Research and Education 

Foundation (TMECC) Table 05.08-1 guidelines. Language was also added to the 

biosolids definition to clarify that biosolids that have completed the composting process 

are considered finished compost for purposes of this rule. This distinction was of concern 

to some landfill operators who may choose to use composted material as an alternative 

daily cover (ADC). 

C. Section 4.0 Exemptions

Except for records that verify the exemption, this section delineates the facilities that are 

not subject to rule. The types of exempt facilities include:

 Facilities subject to District Rule 4570 (Confined Animal Facilities) or specifically 

exempt under Rule 4570; 

 Composting/co-composting facilities whose throughput includes a total of less 

than 100 wet tons per year of biosolids, animal manure, and poultry litter; 

 Facilities that land apply less than 10,000 tons per year of biosolids, animal 

manure, or poultry litter; and 

 Operations that bag un-composted biosolids, animal manure, or poultry litter for 

sale.

As required under federal and state mandates with respect to districts that are in nonattainment of established air quality standards, any rule project seeks to obtain as much 

VOC emissions reduction from the source category as is expeditiously practicable, 

technologically feasible, and economically reasonable, as determined by the District's 

Governing Board. Therefore, any source subject to District Rule 4570 is already subject 

to VOC limits for its operations, including any landfill, land application, or composting/cocomposting operations. Facilities that are specifically exempt from Rule 4570 are smaller 

operations whose emissions are not significant, as determined during the rule project. 

The exempted compost/co-compost facilities are operations for which there is no 

established “best practices.” Providing an exemption for these facilities prevents the 
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inclusion of facilities that accept small amounts of biosolids, but may be accepting large 

amounts of greenwaste, which will be addressed later as a separate rule project.

District staff used two concepts to determine the maximum amount of material that could 

be land applied at a given facility before mitigation measures would be required. The 

concepts are the District’s RACT emission level and the research done by South Coast 

Air Quality Management District (SCAQMD) staff for Rule 1133.2 (Emission Reductions 

from Co-Composting Operations). Since there is no peer-reviewed data about biosolids 

and land application, the co-composting emission factor was used as a surrogate. 

As noted in Table 1 above, the RACT threshold for the District is 10 tons per year. 

SCAQMD Rule 1133.2 uses 1.78 pounds VOC per wet ton of material as an uncontrolled 

emission factor. During the background research for its rule, SCAQMD staff measured 

emissions as high as 2.36 pounds VOC per wet ton at a co-composting facility within the 

District’s boundaries. To calculate the amount of material corresponding to 10 tons VOC 

emissions per year, the 10 tons per year RACT limit was divided by the emission factor. 

Using the 1.78 figure yields about 11,200 wet tons of material per year and using the 2.36 

figure yields about 8,470 wet tons per year. District staff rounded the calculated amount 

of material land applied to 10,000 tons per year, which is equivalent to an emission factor 

of 2.0.

Some facilities bag un-composted animal manure or poultry litter for sale. District staff 

expects that emission from such facilities would be minimal, since, within 15 days of 

receipt, the material is placed in airtight bags or removed from the site. The facilities are 

not deliberately composting the material, so emissions from “incidental” composting would 

be minimal.

D. Section 5.0 Requirements

Section 5.0 of the rule addresses the specific requirements for landfill operations, land 

application operations, and composting/co-composting operations. This section also 

includes provisions for VOC control equipment and source testing. The paragraphs 

below outline the main rule requirements.

1. Landfill Operations

Within 24 hours of receipt, biosolids, animal manure, or poultry litter are required to be 

covered with either six inches of soil, six inches of finished compost, a waterproof 

covering, or any other alternative daily cover (ADC) that landfills are allowed to use under 

CH&SC Section 20690. In addition to covering the biosolids, landfill operators may 

choose an alternative mitigation measure that provides at least 10% VOC emission 

reduction. The District and EPA must approve this alternative mitigation measure. The 

procedure for approval is outlined in Section 6.3 of the rule. 

Under California rules for solid waste management, landfills must cover waste at the end 

of each working day, so this provision will not affect these operations. Although the state 

rule allows 24 hours, waste arriving at landfills is always moving. Once material arrives at 
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the landfill site, within a short time, other wastes are piled on top of the material or the 

material moved from the working face and compacted. Even the very last truckload of 

material received on a given day would be covered within a short amount of time, since, 

under California Code of Regulations (CCR) for solid waste management, the landfill 

operator is required to cover all landfilled material at the end of each operating day. This 

cover is called daily cover. In addition to certain materials used at specified depth, the 

CCR has a list of allowable alternative materials and depths that can be used as daily 

cover. This is “alternative daily cover” or ADC.

The CCR allows biosolids as ADC, meaning that biosolids can be used as the cover over 

the working face of the landfill required at the end of the working day. In a 1998 survey, 

the California Association of Sanitation Agencies (CASA) estimated that 12% of all 

biosolids generated in California are used as ADC. All of the landfills that reported using 

biosolids as ADC are located outside the District boundaries. This means that instituting 

this rule provision will not affect current landfill operations. The rule specifically limits the 

use of biosolids or biosolids-derived material as ADC. Operators must notify the District 

before using these materials. In approving biosolids as ADC, District staff must consider 

the use of the covers specified in Sections 5.1.1.1 through 5.1.1.4 compared with using 

biosolids or biosolids-derived material as well as other available controls. The notification 

by operators may also trigger Rule 2201 (New and Modified Stationary Source Review 

Rule) Best Available Control Technology (BACT), emission offsets, and public notification 

requirements.

Publicly owned treatment works (POTWs), i.e., sewage treatment plants, generate 

biosolids on-site and could conceivably landfill those biosolids on-site and therefore, the 

phrase “received at the facility” would have no meaning in this case. The January 4, 2007 

version of the rule mentions “movement from location of generation.” The phrase caused

more confusion than clarification, so it was removed from the requirements in the revised 

proposed rule.

2. Land Application

As noted at the beginning of Discussion section, the CASA survey found that 54% of all 

biosolids were land applied. This is the single largest use of biosolids and dwarfs the next 

three uses combined. Individual counties may prohibit or regulate land application of 

biosolids. More specifically, The Strategic County-wide Biosolids Plan for Santa Barbara 

noted that, in general:

 San Joaquin, Stanislaus, and Tulare counties ban land application of biosolids,

 Fresno, Kings, and Kern counties ban land application of Class B biosolids, and

 Madera County has significant regulations for land application of biosolids.
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According to a report by the Iowa State University and the University of Iowa Study 

Group, the following odor reductions were documented for land application:

 Injection with full soil coverage – 85%-90%

 Surface applied, incorporated immediately by plowing – 50%

 Surface applied, incorporation delayed by 3 hours – 0 – 10%

 Surface applied, incorporation delayed by 6 hours – 0 – 5%

 Surface applied, incorporation delayed by 12 hours – 0 – 5%

 Surface applied, incorporation delayed by 24 hours – 0 – 5%

In the same report, the study group found that covering liquid manure lagoons with 

chopped-straw has 75% odor reduction. Several of the components of odor are VOCs, 

and therefore, District staff has equated odor reduction to VOC emission reduction. 

In Rule 4565, operators who land-apply biosolids, animal manure, or poultry litter would 

be required to either inject the material at least three inches below the soil surface, or to 

apply the material and then incorporate it within three hours. Immediate incorporation 

may not always be practical. For example, when there has been significant rainfall in a 

short amount of time, it may not be possible to work the ground on that day. For those 

situations when the material cannot be injected or land-incorporated within the 3-hour 

timeframe, operators would be required to cover the material until the material could be 

injected or land incorporated. The three-hour timeframe was chosen to have at least a 

10% emission reduction of the emissions released before direct injection/land 

incorporation. In addition, some facilities receive materials before daybreak to reduce 

traffic during the day. A special provision has been included to address this situation. 

The provision allows materials received after 6 pm to be incorporated by 12:00 pm (noon) 

the following day due to safety issues that otherwise would occur when land incorporating 

at night.

Publicly owned treatment works (POTWs), i.e., sewage treatment plants, generate 

biosolids on-site and could conceivably land apply those biosolids on-site and therefore, 

the phrase “received at the facility” would have no meaning in this case. The January 4, 

2007 version of the rule mentions “movement of material from point of generation.” The 

phrase caused more confusion than clarification, so it was removed from the 

requirements of the rule.

3. Composting/Co-composting Facilities

Recognizing that there is no such thing as a typical composting facility, and not all options 

are feasible for all facilities, staff developed a menu approach for these facilities. 

Operators of composting facilities are required to choose a specified number of practices 

and technology from a list, which staff believes satisfies the CH&SC Code 40919(a)(3) 

requirement for BARCT and Federal Registry 8/18/94 requirement for BACM. In each 

case, facilities can use mitigation measures listed in the rule or develop mitigation 

measures of their own to comply with the rule requirements. The options in the rule 

include both management practice options (e.g., managing moisture content; covering 
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piles with finished compost between turnings) and technology options (e.g., use of 

aerated static piles and in-vessel composting systems). 

Furthermore, in order to acknowledge that some VOC mitigation measures are only costeffective for larger facilities, staff developed the concept of Class One and Class Two 

mitigation measures. Class One mitigation measures are considered BARCT and costeffective options for all facilities, regardless of size. These measures are management 

practices found to be best practices for all composting operations. Class Two mitigation 

measures are the technology options and achieve reductions greater than Class One 

mitigation measures, however they are not cost effective for facilities with throughputs of 

less than 100,000 wet tons per year. The estimated cost effectiveness of implementing 

Class Two mitigation measures for facilities with throughputs of at least 100,000 wet tons 

per year is about $9,800 to $41,300 per ton of VOC reduced. On the other hand, for 

facilities with throughputs less than 100,000 wet tons per year, the estimated cost 

effectiveness of implementing Class Two mitigation measures is between $48,000 to 

$860,000 per ton of VOC reduced. Appendix C of the Final Draft Staff Report details the 

costs and cost effectiveness analysis.

In general, aerobic composting conditions result in less VOC emissions than anaerobic 

composting conditions. Based on this premise, the Southwest Clean Air Agency 

(SWCAA) identified in their Hanaford Farm Best Available Control Technology 

Determination several composting parameters that minimize emissions by promoting 

aerobic composting conditions. These include:

 Scraping/cleaning of process areas—SWCAA stated that scraping or sweeping 

clean all process areas of compostable material each day is required to prevent 

material from being compacted. These compacted materials often give off 

offensive odors thus, presumably, are decaying anaerobically;

 Maintaining a minimum oxygen concentration of at least 5%, by volume, in the free 

air space of composting material and turn piles if low oxygen levels are detected;

 Maintaining a compost moisture content no greater than 70%-- SWCAA stated that 

when compost moisture exceeds 70%, the amount of free air space may be 

reduced to the point where anaerobic conditions are likely to develop. In addition, 

excessive amounts of water surrounding composting material can slow oxygen 

transfer to the point that anaerobic conditions develop on the surface of the 

material even when adequate oxygen exists within the free air space; and

 Maintaining carbon to nitrogen ratios of piles of at least 20:1. 

Additionally, staff believes that rapid processing or covering of organic waste material will 

minimize VOC emissions. This is based on discussions by the Dairy Permitting Advisory 

Group and Rule 4651 (Soil Decontamination). Staff believes that the same principals that 
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suggest minimizing exposed surface area of manure and contaminated soil results in 

minimization of VOC emissions would apply to compost piles.

For the Class Two mitigation measures, the rule contains supplementary requirements for 

the process. VOC emissions would be measured on the fourth day after initial pile 

formation for aerated static piles (ASPs) and in-vessel composting. The capture 

efficiency of an ASP or in-vessel process cannot be easily quantified, so the purpose of 

the testing is to assure that the process is capturing as much of the VOC generated by 

the process as possible.

4. VOC Emission Control Systems

The most commonly used VOC emission control device at composting facilities are 

biofilters. Currently, biofilters are used at over 200 composting facilities in Europe, over 

twenty composting facilities in the United States of America, and at least five composting 

facilities in California. 

The typical biofilter design consists of fans, ducts, media support (a bed liner), an air 

plenum, and the media (typically a blend of finished compost, soil, and/or wood chips). 

Wall ventilation and pit fans blow air from the building and pit through ducts into an air 

plenum below the biofilter media. The air passes through the media, where 

microorganisms treat the air before it is released to the atmosphere. A schematic of a 

biofilter is shown in Figure 1 below.

Figure 1- Sample Biofilter Design

As shown above, biofilters are technologically simple yet effective VOC controls. At Las 

Virgenes composting facility in Calabasas, CA, the biofilter routinely removes over 80% of 

the VOC (Peters). This is similar to results found by other researchers. Rule 4565 

requires operators to monitor the biofilter for five parameters: temperature, moisture, pH, 

appearance (visual inspection), and fugitive VOCs. Since the control over a biofilter is 

less direct than for thermal oxidizers, monitoring these parameters would allow the 

operator to determine that the biofilter is within the most optimal range for VOC removal.

Scrubbed

Exhaust Air

Enclosure 

with Compost

Pit

Air Duct

Air Plenum

Media Vent

Fan

Biofilter Set-Up
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While it is most likely that operators at composting facilities would choose biofilters as 

their VOC control device, Rule 4565 does allow for operational flexibility by also 

addressing controls for non-biofilters. Additionally, both biofilters and non-biofilters would 

be required to prove their control efficiency through source test every two years.

E. Section 6.0 Administrative Requirements

Section 6.0 has been designed to match the administrative requirements with 

requirements in other sections of the rule. For example, records required are in 

Section 6.1, test methods are in Section 6.2, etc. Furthermore, the records for exempt 

facilities are in Section 6.1.1, records for landfills are in Section 6.1.2, and so forth. 

Section 6.3 outlines the procedure for operators wishing to implement an alternative 

mitigation measure. This procedure mirrors the one in SCAQMD Rule 1133.2. Based 

on conversations with EPA Region IX staff, approval of the alternative mitigation 

measure would include EPA approval in addition to the APCO approval.

F. Section 7.0 Compliance Schedule

Landfill operations would be required to comply with all rule provisions within twelve (12) 

months of rule adoption. Land application facilities have a two tier approach based on 

amount of material incorporated. Facilities utilizing less than 100,000 wet tons per year 

would have 12 months to come into full compliance. Large facilities, meaning facilities 

that handle more than 100,000 wet tons per year of biosolids, animal manure, or poultry 

litter would most likely require more equipment to meet the proposed land application 

requirements. For these largest facilities, the operator would be in full compliance within 

18 months of rule adoption.

Operators of compost facilities with throughputs of less than 100,000 wet tons per year 

would comply within eighteen (18) months of rule adoption; operators of compost/cocompost facilities with throughputs of at least 100,000 wet tons per year would comply 

within thirty-six (36) months of rule adoption. For those facilities that plan to convert 

compost/co-compost operations to energy generation operations, extended compliance 

schedule is allowed if the operator meets specific provisions within defined timeframes. 

Composting/co-composting operations not part of the energy generation operation would 

be required to meet the same compliance schedule as if they were not part of an energy 

generation conversion. A composting/co-composting operation originally planned for 

energy generation operation that does not become part of the energy generation 

operation would be in-vessel operation with 90% control of VOC emissions.
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IV. COMPARISON BETWEEN PROPOSED NEW RULE 4565 and SCAQMD RULE 

1133.2

Staff noted that there are some significant differences between District Rule 4565 and 

SCAQMD Rule 1133.2. This should not be interpreted to mean that one rule is more 

stringent than the other but due, instead, to the following factors:

1. Technology has changed significantly since SCAQMD Rule 1133.2 was adopted;

2. Additional research projects regarding mitigation measures have been completed 

since SCAQMD Rule 1133.2 was adopted; and 

3. The socioeconomic climate of the SCAQMD is significantly different from that of the 

San Joaquin Valley Unified Air Pollution Control District.

Table 2 summarizes the significant differences between SCAQMD Rule 1133.2 and 

SJVUAPCD Rule 4565. Please note staff only included the significant differences, not all of 

the differences, between the two rules.

Table 2: Significant Differences

SCAQMD 

Rule 1133.2

SJVUAPCD Rule 

4565

Reason

Facilities Other Than 

Co-Composting

Rule does not 

apply to these 

operations

Management practices for 

facilities that landfill and 

land apply.

Management practices and 

control technology for large 

composting facilities; 

management practices only 

for other composting 

facilities

Knowledge of VOC control options has 

increased since Rule 1133.2 adoption 

and staff believes that cost-effective 

methods of controlling VOC emissions 

from these facilities exist.

Co-Composting 

Threshold for 

Applicability

Facilities with at 

least 1,000 to 

3,000 tpy 

throughput

Facilities that handle 100 

tpy or more of biosolids, 

animal manure, or poultry 

litter

Staff believes that there are reasonable, 

cost effective options for facilities with 

throughputs of at 100 tpy that would 

not impose an undue burden on 

operators.

Control 

Requirements

In-vessel 

composting with 

70 – 80% VOC 

control 

efficiency

VOC control efficiency 

10% -80% depending on 

type of operation and 

facility throughput

Management practices (mitigation 

measures) are effective, reasonable, and 

have been achieved in practice for smaller 

facilities.

In-vessel composting is not cost-effective for 

smaller or medium facilities and there are no 

known, unsubsidized facilities in the 

SCAQMD that would comply with such rule 

requirements.
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V. VOC EMISSION REDUCTION ANALYSIS

District staff estimates that current VOC emissions from land application and composting 

of biosolids, animal manure, and poultry litter is over 3,500 tons of VOC per year with 

estimated emission reduction of 1,430 tons per year when the rule is fully implemented. 

This represents about a 40% reduction in the baseline VOC emissions for this source 

category. The VOC emission reduction analysis is included in Appendix B of the Final 

Staff Report.

VI. COSTS AND COST EFFECTIVENESS ANALYSIS

The California Health and Safety Code 40920.6(a) requires the San Joaquin Valley 

Unified Air Pollution Control District to conduct a cost effectiveness analysis of available 

emission control options before adopting each BARCT rule. The purpose of conducting a 

cost effectiveness analysis is to evaluate the economic reasonableness of the pollution 

control measure or rule. The analysis also serves as a guideline in developing the control 

requirements listed in a rule.

District staff has evaluated costs and cost effectiveness for sources affected by Revised 

Proposed New Rule 4565. 

 For landfill operations and land application operations, no additional costs are 

expected as a result of following the rule requirements. 

 For composting facilities, the cost of instituting the Class One mitigation measures 

is estimated to have no cost impact, since the mitigation measures represent best 

practices for composting/co-composting operations. 

 For the largest composting facilities, meaning those that have throughput of at 

least 100,000 wet tons per year, total annualized costs range from about $5.8 

million to $24 million for all facilities to implement the Class Two mitigation 

measures. With estimated emission reductions of 595 tons VOC per year, District 

staff estimates that the cost effectiveness would range between $9,800 per ton 

VOC reduced and $41,000 per ton VOC reduced. 

 For composting facilities with throughput less than 100,000 wet tons per year, the 

cost effectiveness value ranges from $48,000 to $856,000. Therefore, District staff 

believes that it is not cost effective to require facilities with throughputs less than 

100,000 wet tons per year to implement Class Two mitigation measures. It should 

be noted, however, that the rule provides operators of small composting facilities 

with the flexibility to comply by implementing Class One measures only or a 

combination of a specified number of Class One and Class Two measures. 

Details of the analysis are in Appendix C of this staff report.
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VII. SOCIOECONOMIC IMPACT ANALYSIS

Pursuant to state law, District staff is required to analyze the socioeconomic impacts of 

any proposed rule or rule amendment that significantly affects air quality or strengthens 

an emission limitation. During the first workshop, District staff solicited volunteers from 

stakeholders, and manufacturers and vendors of control devices to participate as 

members of the socioeconomic focus group for the rule. District staff worked closely with 

the focus group to determine direct compliance costs of the proposed rule provisions. 

The District’s independent consultant participated with the focus group to identify and 

analyze the socioeconomic impacts of the proposed rule. District staff considered the 

socioeconomic analysis to further refine the proposed rule. The socioeconomic impact 

analysis report is attached to this staff report as Appendix D. A draft of the 

socioeconomic impact analysis report was posted for comment to interested parties on 

February 8, 2007. The final socioeconomic report was presented to the District 

Governing Board at the public hearing for the rule in order to disclose any expected 

economic impacts.

VIII. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Act (CEQA), District staff has 

investigated the likely environmental impacts of Rule 4565. Based on the lack of 

evidence to the contrary, District staff has concluded that the revised proposed rule will 

not have any significant adverse effects on the environment. Staff recommends filing a 

Notice of Exemption under the provisions of Public Resource Code 15061 (b)(3).

IX. RULE CONSISTENCY ANALYSIS

Pursuant to state Health and Safety Code, Section 40272.2, District staff has prepared a 

rule consistency analysis. The rule provisions are consistent with EPA policy and 

guidelines for sources subject to Rule 4565. Details of the rule consistency analysis are 

attached as Appendix E to this staff report.
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X. RULE DEVELOPMENT PROCESS

As part of the rule development process, District staff conducted public scoping meetings 

in March 2005 and public workshops in October 2006 and January 2007. Staff has 

conducted a socioeconomic focus group meeting in order to present, discuss, and solicit 

comments on the compliance costs and impact to businesses as part of the 

socioeconomic impact analysis. The proposed socioeconomic impact analysis was 

posted for written comment February 8, 2007. 

In addition to the workshops, staff has met with stakeholders to receive comments on the 

technical aspects and compliance costs of the proposed rule. The comments received 

from the public, affected sources, California Air Resources Board, and United States 

Environmental Protection Agency during the public workshop process and technical 

consultation meetings have been incorporated into the proposed rule as appropriate. 

Appendix A of the Final Staff Report outlines the significant comments received and the 

responses of District staff to the February 15, 2007 version of the rule.

Proposed New Rule 4565 and the Final Draft Staff Report, including the analyses 

mandated by CH&SC, were published before the public hearing for the District Governing 

Board to consider the adoption of the proposed rule. The notice of the public hearing for 

this rule project was published in a general circulation newspaper in each of the eight San 

Joaquin Valley counties, and was mailed to affected sources and interested parties. The 

public notice solicited written comments and identified the name and telephone numbers 

of the District staff who answered questions and responded to comments. The adoption 

schedule allowed the District meet the Ozone Plan commitment to adopt a rule by first 

quarter of 2007. 

XI. REFERENCES

1. Anit, Selvi, Artuz, Robert, Biofiltration of Air, http://www.rpi.edu/dept/chem.-

eng/Biotech-Environ/MISC/biofilt/biofiltration.htm.

2. Bartlett, Jerry Vice President Cedar Grove Composting Facility, e-mail 

correspondence.

3. California Air Resources Board 2005 Almanac, available through links at 

http://www.arb.ca.gov/app/emsinv/emseic_query.php?F_YR=2004&F_DIV=-

4&F_SEASON=A&SP=2005&SPN=2005_Almanac&F_AREA=CA&F_EICSUM=19

9.

4. California Air Resources Board 2003 Almanac, available through links at 

http://www.arb.ca.gov/app/emsinv/emssumcat_query.php?F_DIV=0&F_DD=Y&F_

YR+2002&F-SESON+A&SP=2003f&F_AREA=CO&F_CO=2003.

5. California Code of Regulations, Title 14 Division 7 available at 

http://www.ciwmb.ca.gov/Regulations/Title14.

6. CIWMB, SWIS database; Conversion Technologies for Municipal Residuals May 3, 

2001; Best Management Practices for Greenwaste Composting Operations July 
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15 Final Staff Report for Rule 4565

29, 2003; and Second Assessment of California's Compost and Mulch Producing 

Infrastructure May 2004, available through links at http://www.ciwmb.ca.gov.

7. Fondahl, Lauren, Biosolids Coordinator, EPA Region 9, e-mail correspondence 

10/14/04.

8. Garcia, Elizabeth Legislative and Regulatory Coordinator for Norcal e-mail 

correspondence and Norcal website at 

http://www.sunsetscavenger.com/jepson_prairie_organics.htm.

9. Iowa State University and The University of Iowa Study Group, Concentrated 

Animal Feeding Operations Air Quality Study, February 2002; available on-line at 

http://www.public-health.uiowa.edu/ehsrc/CAFOstudy.htm

10. Peters, Deborah, Communications and Media Coordinator Las Virgenes MWD, email correspondence.

11. San Joaquin Valley Unified Air Pollution Control District Co-composting Operation 

BACT Project #S-1032219, Application S-4212.

12. Sercu, Bram, Kristof Demeestere, et al, Degradation of Isobutanal at High Loading 

Rates in a Compost Biofilter, Journal of the Air and Waste Management 

Association, 2005, 55:1217-1227. ISSN 1047-3289.

13. Schmidt, David, Janni, Kevin, Nicolai, Richard, Biofilter Design Information, 

Biosystems and Agricultural Engineering Update, 2004, BAEU-18, 

http://www.manure.umn.edu/assets.

14. Sonoma Technology Inc (STI) Contract 903340 available through links at 

http://www.valleyair.org/Workshops/public_workshops_past.htm#Rule%204565%2

0(Composting/Biosolids%20Operations).

15. South Coast Air Quality Management District Rule 1133, Rule 1133 Technical 

Report, and Source Tests available through links at 

http://www.valleyair.org/Workshops/public_workshops_past.htm#Rule%204565%2

0(Composting/Biosolids%20Operations).

16. Southwest Clean Air Agency, Technical Support Document Little Hanaford Farms, 

SWCAA ID: 2228, April 19, 2005. 

17. van Lith, Chris, Leson, Gero, Michelsen, Richard, Evaluating Design Options for 

Biofilters, Journal of the AIr and Waste Management Association, 1997, 47:37-48. 

ISSN 1047-3289.

18. Wallace, Z, How to Interpret Compost Analysis, 2005, available at 

http://www.wallacez.freeserve.ca.uk/analysis.

19. Wheeler, PA, Stewart, I, Dumitrean, P, Donavan, B, Health Effects of Composting, 

2001, ISBN 1 857 05680 9, available through publications@wrcplc.co.uk.
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