Date: October 14, 2011 

From: Rynda Kay 

To: San Joaquin Valley Rule 4103 rulemaking file 

RE: Table 9-1, Final Staff Report and Recommendations on Agricultural Burning, dated May 

20, 2010 (corrected) 

“Table 9-1, Final Staff Report and Recommendations on Agricultural Burning, dated May 20, 

2010” posted to the docket on 7/11/2011 was posted with the "revised" staff report date 

inadvertently, instead of May 20, 2010. We include the table with the correct date here. The two 

table versions in the docket are otherwise identical in content.
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

9-2 Chapter 9: Determinations Required by State Law 

Revised Proposed Staff Report and 

Recommendations on Agricultural Burning

Table 9-1 - Crop Categories and Revised Proposed Recommendations 

*N/A: Not applicable. Practices for these crop types are either already in place or there were no 

technologically feasible alternatives to open burning for these crop types. 

Crop Categories and 

Crop type 

Current Method 

Potentially 

Feasible 

Alternative(s) 

Economically 

Feasible? Recommendations 

Vineyard Removal Materials 

Grape and Kiwi Crops Open Burn 

Possibly 

Biomass. 

Wire Issue. 

No Allow Burn 

Orchard Removal Matter 

Small Other Orchards 

- 15 acres or less 

(Currently at 20 acres 

or less) 

Open Burn / 

Biomass 

Biomass Yes 

Reduce Burn to 15 acres or 

less per location per year. 

No case by case 

determinations for additional 

acreage. 

Fig Crops 

Open Burn / 

Biomass 

Biomass. 

See ìSmall 

Other Orchards 

ñ 15 acres or 

lessî category. 

Reduce Burn to 15 acres or 

less per location per year. 

No case by case 

determinations for additional 

acreage.

Citrus Crops Open Burn 

Possibly 

Biomass. 

Capacity 

Issue. 

No Allow Burn 

Apple, Pear, and 

Quince Crops 

Open Burn 

None. Disease 

Issue. 

N/A Allow Burn 

Weed Abatement 

Ponding & Levee 

Banks Open Burn 

None. Mowing 

and Herbicide 

Issues. 

N/A Allow Burn. 

Other Materials 

Brooder Paper Landfill Landfill N/A Prohibit Burn 

Deceased Goats Burial Burial N/A Prohibit Burn 

Diseased Bee Hives Open Burn 

None. Disease 

Issue. 

N/A Allow Burn 

Rice Stubble 

Baling + Selling / 

Open Burn 

Baling + Selling 

/ Open Burn. 

Market and 

Water Issues. 

Immediate 

additional 

phase-down is 

not economically 

feasible: low 

market for rice 

straw 

Interim phase-down schedule 

would be modified: 

· Only 70% of acreage can 

be burned starting 6/1/08 

· 50% limitation (6/1/10) 

would be removed 

· Burning is prohibited 

starting 6/1/15 

Prunings 

Apple, Pear, and 

Quince Crops 

Open Burn 

None. Disease 

Issues. 

N/A Allow Burn. 

Fig Crops 

Soil 

Incorporation 

Soil 

Incorporation 

N/A Prohibit Burn. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

9-3 Chapter 9: Determinations Required by State Law 

Revised Proposed Staff Report and 

Recommendations on Agricultural Burning

Table 9-1 - Crop Categories and Revised Proposed Recommendations (Continued) 

Crop 

Categories and 

Crop type 

Current 

Method 

Potentially 

Feasible 

Alternative(s) 

Economically 

Feasible? Recommendations 

Surface Harvested Prunings 

Grape vines ñ 

other prunings 

from grape vines 

Soil 

Incorporation 

Soil 

Incorporation 

N/A Prohibit Burn 

Grape canes ñ 

defined as 

ìVineyard 

Materialsî 

Soil 

Incorporation 

Soil 

Incorporation 

N/A Prohibit Burn 

Raisin Trays ñ 

defined as 

ìVineyard 

Materialsî 

Open Burn 

None. 

Material Type 

& Recycling 

Issues. 

N/A Allow Burn 

Almond, Walnut, 

and Pecan 

Crops 

Open Burn / 

Shred / 

Biomass 

Shred / 

Biomass 

Yes. if 

custom 

shedding 

services are 

available 

and 

economical 

for smaller 

growers 

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 available in time for the 

operator to proceed with established postpruning cultural practices. 

*N/A: Not applicable. Practices for these crop types are either already in place or there were no 

technologically feasible alternatives to open burning for these crop types. 

9.2 FEDERAL & STATE COMMITMENTS FOR BIOMASS FACILITIES 

The District has determined that there were no long-term federal or state funding 

commitments for the operation of biomass facilities or development of alternatives to 

burning. The District supports legislation that will encourage, promote, and facilitate