Final Staff Report and 

Recommendations on Agricultural Burning 

Chapter 8 

Air Quality Impacts of Continued 

Open Burning and Alternatives 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

Final Staff Report and 

Recommendations on Agricultural Burning 

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

Revised July 21, 2010 

8-1 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

Chapter 8: Air Quality Impacts of Continued 

Open Burning & Alternatives

8.1 SMOKE MANAGEMENT SYSTEM 

Open burning of agricultural crops and materials is managed by the District’s 

Smoke Management System (SMS). The SMS uses a combination of real-time 

meteorological information and computer modeling to determine the allowable 

amount and location of agricultural burning. Under the SMS, the amount of 

burning allowed to take place on any given day would be based on several 

factors such as the local meteorology, the air quality conditions, the atmospheric 

holding capacity, the amount of burning already approved in a given area, and 

the potential impacts on downwind populations. The District’s use of the SMS is 

intended to limit emissions to levels below the federal ambient air quality 

standards and to better distribute emissions temporally and spatially for flexibility 

of burn days for growers while minimizing the impact on the public. 

Under the SMS, the SJVAB is classified into three regions (north, central, and 

south), the number of which will be determined by the topographical, geological 

and meteorological conditions in the San Joaquin Valley Air Basin (SJVAB). 

Burning is allocated by region, depending upon each region’s carrying capacity 

for smoke on each day. Not every burner who wants to burn on a given day may 

be able to do so. Therefore, the District established a system for prioritizing 

burning within each region. The SMS analyzes the daily impact of open burning 

on air quality in 103 zones in the SJVAB. 

Because of the general locations where agricultural and prescribed burning 

activities tend to occur, combined with the topography, geology, and weather 

conditions in the SJVAB, it is expected that the regions will fall into three 

categories: (a) regions where only prescribed burning will occur; (b) regions 

where only agricultural burning will occur; and (c) regions where both prescribed 

and agricultural burning will occur. In regions where only agricultural burning will 

occur, the allocation will be on a first come, first served basis. However, burners 

who do not receive an allocation on a particular day will be placed on a waiting 

list for the following day(s). The District has established a procedure whereby 

burners on the waiting list receive notification when their allocation is going to be 

available. Properly managed burning allocations under the existing District 

SMS ensures that air quality and health impacts of open burning of agricultural 

materials, prescribed burning, and hazard reduction burning are minimized to the 

fullest extent. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

8-2 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

Figure 8-2 shows the burn allocation zones in each of the eight counties in the 

SJVAB 

Figure 8-2 Smoke Management System Burn Allocation Zones 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

8-3 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

8.2 2007 OZONE PLAN 

Air monitoring data in the San Joaquin Valley Air Basin (SJVAB) indicates ozone 

levels that exceed the eight-hour ozone National Ambient Air Quality Standards 

(NAAQS) set by the federal government to protect public health and welfare. As 

a result, the United States Environmental Protection Agency (EPA) has classified 

the Valley as serious nonattainment. In accordance with the requirements of the 

federal Clean Air Act, nonattainment areas must develop plans to achieve 

attainment of the NAAQS. Consequently, the San Joaquin Valley Unified Air 

Pollution Control District (District), adopted the 2007 Ozone Plan. The Ozone 

Plan contains a comprehensive and exhaustive list of regulatory and incentivebased measures to reduce emissions of ozone and particulate matter precursors 

throughout the Valley. Additionally, the Plan calls for major advancements in 

pollution control technologies for mobile and stationary sources of air pollution, 

and a significant increase in state and federal funding for incentive-based 

measures to create adequate reductions in emissions to bring the entire Valley 

into attainment with the federal ozone standard. 

In preparing the Ozone Plan, consistent with the District’s guiding principle, the 

control strategy in the Plan is developed with the utmost consideration to future 

needs for the PM2.5 Attainment Plan discussed below. Both Plans’ focus is 

based on NOx reduction strategy. Consequently, the control strategy to attain 

the federal 8-hour ozone standard produces NOx emissions reductions that are 

close to what is needed for attainment of the 1997 PM2.5 standards by the 

maximum statutory attainment date of April 15, 2015. This suggests that the 

ozone strategy will provide most – if not all – of the reductions needed to attain 

the PM2.5 annual standard, based on simple modeling exercises. There is a 

possibility that that some additional NOx emissions reductions from incentivebased measures may be needed to demonstrate attainment of the 19977 annual 

PM2.5 standard.

Appendix I of the Ozone Plan listed the Control Measures that are needed to 

achieve attainment of the standards. One of these Control Measures is S-AGR-1 

Open Burning, which addressed the phased-down prohibitions of burning 

agricultural materials mandated by the state Health and Safety Code Sections 

41855.5 and 41855.6. District Rule 4103 (Open Burning) in conjunction with the 

District’s “Staff Report and Recommendations on Agricultural Burning” is the 

mechanism by which the District is implementing the agricultural materials open 

burn prohibition. 

8.3 2008 PM2.5 PLAN 

In 1997, EPA sets two PM2.5 standards: a 24-hour standard (65 μg/m3

) to 

protect short term health impacts, and a 12-month (annual) standard (15 μg/m3) 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

8-4 Chapter 8: Air Quality Impacts of Continued 

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Final Staff Report and 

Recommendations on Agricultural Burning

to protect against long-term impacts. The San Joaquin complied with the 24-

hour standard, based on data from 2004 through 2006. In 2006, EPA revised the 

24-hour standard to lower the standard (35 μg/m3). It is estimated that that 

attainment plans for this new standard may be required by 2012 or 2013. 

EPA has designated the San Joaquin Valley Air Basin as nonattainment of the 

federal PM2.5 standards. In April 2008, the District Governing Board adopted 

the PM2.5 Plan that demonstrates the strategies the District will pursue in order 

to achieve attainment of the federal PM2.5 standards. The 2008 PM2.5 Plan 

builds upon the comprehensive strategy adopted in the District’s 2007 Ozone 

Plan to bring the San Joaquin Valley Air Basin into attainment of the federal 

PM2.5 standards. In preparing the 2007 Ozone Plan, the control strategy was 

developed with utmost consideration to future needs for the PM2.5 attainment 

plan. An evaluation of the District’s ozone control strategy to attain the federal 8-

hour ozone standard has determined that the ozone plan included NOx 

emissions reductions that are close to what is needed for attainment of the 1997 

PM2.5 standards by the maximum statutory date attainment date of April 5, 2015. 

Based on simplified modeling exercises performed at the time of the ozone plan 

was completed, the ozone control strategy was determined to have a design 

value that would provide most – if not all – of the reductions needed to attain the 

PM2.5 annual standard. 

Appendix I of the PM2.5 Plan listed the Control Measures that are needed to 

achieve attainment of the standards. One of these Control Measures is S-AGR-1 

Open Burning, which addressed the phased-down prohibitions of burning 

agricultural materials mandated by the California Health and Safety Code 

(CH&SC) Sections 41855.5 and 41855.6. District Rule 4103 (Open Burning) in 

conjunction with the District’s “Staff Report and Recommendations on 

Agricultural Burning” is the mechanism by which the District is implementing the 

agricultural materials open burn prohibition. 

8.3.1 Annual PM2.5 Standard 

As discussed in the District 2008 PM2.5 Plan, attainment of the annual standard 

is projected by 2014 by the regional photochemical model and all receptor 

evaluations. The predicted value is within one microgram of the standard; 

therefore, a weight of evidence evaluation is appropriate. The predictions of 

these models are compared, along with air monitoring data, trends and other 

technical information, to establish a weight of evidence assurance that attainment 

will be achieved. The weight of evidence evaluation supports acceptance of the 

regional and receptor modeling predictions. Evaluation of the receptor modeling 

identifies that attainment will not occur by 2009 with the expected achievable 

reductions and will require the extensive NOx reductions proposed by ARB for 

2014. Reductions achieved by the District and current ARB efforts for all directly 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

8-5 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

emitted and secondary particulate sources are important to achieving attainment. 

The proposed NOx reductions for 2014 would not be sufficient to achieve 

attainment without these other reductions. The strategy for attainment includes 

reduction of directly emitted PM2.5 (geologic, mobile, organic carbon and 

vegetative burning) as well as reductions from SOx and NOx as precursors to 

ammonium sulfate and ammonium nitrate. Secondary organic aerosol 

particulate formation is also included in the modeling evaluation of motor vehicle 

and organic carbon contributions. 

8.3.2 24-Hour PM2.5 Standard 

As discussed in the District 2008 PM2.5 Plan, attainment of the prior 24-hour 65 

microgram standard is projected to occur prior to 2014 and with much less 

reductions required than are needed to attain the annual standard. This means 

that the annual standard identifies the amount of reductions needed to achieve 

attainment. ARB used the regional model to evaluate the top 25% of days 

modeled to provide the annual analysis. Based on design values for 2005, ARB 

projected a 2014 value of 45 micrograms or less at all sites. Due to concerns that 

the last two years have experienced slightly higher 24-hour values, the District 

also performed a screening assessment with estimated design values for 2007 

(based on incomplete and uncertified data). Evaluation by the District projected 

a 2014 value of 53 micrograms. Both of these projections are well below the 65 

microgram standard and do not require a weight of evidence evaluation. 

Unmonitored area evaluation for the year 2014 was conducted by ARB and 

provides confirming evidence for the attainment demonstration. The 

unmonitored area evaluation requires examination of regional modeling results 

for the entire Valley. ARB has provided a screening assessment produced from 

the regional model results for the year 2014 to determine if any portion of the 

modeling domain predicts concentrations greater than the monitored locations. 

This initial analysis did not identify any grid squares that have higher values. 

ARB has committed to conduct further evaluation in accordance with EPA 

guidance should this be determined to be necessary; however, the screening 

assessment indicates that it is unlikely that any areas will be identified that 

require subsequent evaluation or temporary monitoring. The District and ARB 

will confer with EPA to ensure that the unmonitored area evaluation provides 

sufficient confirmation for the attainment demonstration.

8.4 OPEN BURNING EMISSIONS INVENTORY

The prohibition of open burning of certain materials has been implemented by 

adopting Rule 4103 in June 1992. The rule was subsequently amended in 

December 1992, December 1993, June 2001, September 2004, May 2005, and 

May 2007. The emissions inventory from the 2007 Ozone Plan and the 2008 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

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8-6 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

PM2.5 Plan for Control Measure S-AGR-1 (Open Burning) are shown in Table 1 

below. The projected emission reductions and actual estimated emissions 

reductions for the 2010 burn prohibition schedule are presented in Table 2 and 

Table 3 below. Both of the plans did not include the projected emissions 

reduction from 2007 and 2010 burn prohibition deadlines. 

Since District’s implementation of the open burning prohibitions of agricultural 

materials pursuant to the state law requirements, emission of NOx, PM, and VOC 

from this source category has significantly been reduced. The emissions 

reductions achieved so far are more than the estimated amount indicated in the 

PM2.5 Plan and Ozone Plan. In addition to fulfilling the CH&SC 2010 burn 

prohibition deadline and the requirements from Rule 4103, the District has also 

met the State Implementation Plan commitments for this source category.

Table 8 – 1 Emissions Inventory from the PM2.5 and Ozone Plans for 

Open Burning 

Emissions Inventory for Open Burning NOx PM2.5 VOC SO2

(S-AGR-1) (tpd) (tpd) (tpd) (tpd) 

PM2.5 Plan: Emissions Inventory by 2010 5.27 6.94 n/a 0.13 

Ozone Plan: Emissions Inventory by 20081

4.8 n/a 5.7 n/a 

1. The Ozone Plan does not show projected reductions for 2010. 

Table 8 – 2 PM2.5 Plan Projected Emissions Reduction for Open Burning 

NOx PM2.5 VOC SO2

PM2.5 Plan: Emissions Reduction (tpd) (tpd) (tpd) (tpd)

PM2.5 Plan: Projected Annual Average Reductions 

for the Open Burning Control Measure by 20101 1.95 2.57 n/a 0.05

PM2.5 Plan: Estimated Reductions from 2007 Burn 

Prohibition Deadline (Annual) 3.54 4.57 n/a 0.09

PM2.5 Plan: Estimated Reductions from 2010 Burn 

Prohibition Deadline (Annual) 0.54 1.79 n/a 0.03

District’s Total Estimated Reductions for Open 

Burning 4.08 6.36 n/a 0.12

1. The projected reductions include emissions from the rulemaking projects from the 2007 and 

2010 CH&SC deadlines. 

*tpd: tons per day; N/A: not applicable to the Plan
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

8-7 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

Table 8 – 3 Ozone Plan Projected Emissions Reduction for Open Burning 

NOx PM2.5 VOC SO2

Ozone Plan: Emissions Reduction (tpd) (tpd) (tpd) (tpd) 

Ozone Plan: Projected Annual Average Reductions 

for the Open Burning Control Measure by 20081 1.1 n/a 1.3 n/a 

 

Ozone Plan: Estimated Reductions from 2007 Burn 

Prohibition Deadline (Annual) 3.2 n/a 3.7 n/a 

Ozone Plan: Estimated Reductions from 2010 Burn 

Prohibition Deadline (Annual) 0.5 n/a 1.5 n/a 

District’s Total Estimated Reductions for Open 

Burning 3.7 n/a 5.2 n/a 

1. The projected reductions include emissions from the rulemaking projects from the 2007 and 

2010 CH&SC deadlines. 

*tpd: tons per day; N/A: not applicable to the Plan
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

Revised July 21, 2010 

8-8 Chapter 8: Air Quality Impacts of Continued 

Open Burning and Alternatives 

Final Staff Report and 

Recommendations on Agricultural Burning

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