Mr. Andrew Steckel, ChiefRulemaking Office (Air-4)

U.S. Environmental Protection AgencyRegion 9

75 Hawthorne StreetSan Francisco, California 94105

Dear Mr. Steckel:

Enclosed is a revised document entitled List of Conservation Management Practices for

Agricultural Operations (CMP) to the Great Basin Unified Air Pollution Control District’s

(District) Rule 502, Conservation Management Practices. Rule 502 was adopted by theDistrict on July 7, 2005, and submitted by the Air Resources Board (ARB) for inclusion

in the State of California Implementation Plan for Achieving and Maintaining the

National Ambient Air Quality Standard (SIP) on October 20, 2005.

The District revised the CMP in response to U.S. Environmental Protection Agency’s

(U.S. EPA) concern regarding clarification issues on the conservation management

practice categories in the CMP. A copy of the U.S. EPA letter dated June 8, 2011, to

the District is enclosed along with the District’s Board Order adopting the CMP

revisions. We understand that the U.S. EPA has examined the revised CMP and

concurred with the CMP’s revised changes.

ARB is requesting that U.S. EPA replace the CMP in the Rule 502 SIP submitted on

October 20, 2005, with the revised CMP enclosed with this letter.

If you have any questions about this request, please contact Mr. Michael J. Guzzetta,

Manager, Rule Evaluation Section, at (916) 322-6025 or by email atmquzzettcarb.ca.qov.Sincerely,

Steven S. Cliff, Ph.

Assistant Chief

Stationary Source Division -

Enclosures

The energy challenge facing California is real. Eveiy Californian needs to take immediate action to reduce energy consumption.

For a list ofsimple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.ov.

California Environmental Protection Agency

Printed on Recycled Paper
157 Short Street, Suite 6

Bishop, California 93514-3537

Mr. Michael J. Guzzetta, Manager (wlo Enclosures)Rule Evaluation Section

Stationary Source Division
Great Basin Unified Air Pollution Control District

LIST OF CONSERVATION MANAGEMENT PRACTICES

FOR AGRICULTURAL OPERATIONS

Including Best Available Control Measures (BACM) and

Best Available Retrofit Control Technology (BARCT)

for Agricultural Practices

htti :1 ‘www.gbuapcd.org/farm/index.htm

December 2011
A. Land Preparation / Cultivation

B. Harvesting

C. Other

D. Unpaved Roads greater than or equal to 75 vehicle trips / day (complete this category if

your farm roads has 75 or greater vehicle trips per day)

F. Unpaved Roads less than 75 vehicle trips / day (complete this category if your farm roads

has less than 75 vehicle trips per day)

F. Unpaved Vehicle / Equipment Areas (vehicle I equipment parking lots, staging areas,

etc.) greater than or equal to 50 vehicle trips / year (complete this category if your farms

unpaved vehicle / equipment area has 50 or greater vehicle trips per year)

G. Unpaved Vehicle / Equipment Areas less Than 50 vehicle trips /year (complete this

category iiyour farm’s unpaved vehicle / equipment area has less than 50 vehicle trips

per year)

If a dairy, confined animal feeding operation (CAFO) or other crop or agricultural practice - - comes into the three counties that comprisethe Great-Basin UnifiedAirPollutionControl

District, a CMP list will be developed for that type of operation. Please contact the District

at (760) 872-8211 if you have any questions.

Page 2 of 17
Chemigation/Fertigation: Application of chemicals through an irrigation

system reduces the need to travel in-field forapplication purposes.

Combined Operations: Combine equipment to perform several operations

during one pass, thereby reducing the number of

. passes necessary to cultivate the land.

Conservation Irrigation: Conserving water through drip, sprinkler,

• underground lines, conserves water and reduces

weed population and need for tillage.

Equipment Changes/Technological Use larger equipment, modify land planing and landImprovements: leveling, matching the equipment to row spacing to

reduce the number of passes.

Multiple CMPs in another category:Night Farming: Operate at night when moisture levels are higher

and winds tend to be lighter, thereby reducing dust

emissions.

Non-Tillage / Chemical Tillage: Use flail mower, low volume sprayers, or heat

delivery systems (as harvest pre-conditioner).Reduces or eliminates number of soil tillage passes.

Soil Moisture Management: Ensure adequate soil moisture levels at the time of

tillage or soil maintenance to reduce dust emissions.

Other (special approval required): Contact District at (760) 872-8211 for approval.

Page 3 ofI7
Equipment Changes/Technological Use larger equipment, modify land planing and land

Improvements: leveling, matching the equipment to cow spacing to

reduce the number of passes.

Green Chop: Harvest a forage crop without allowing it to dry in

the field; reduces multiple equipment passes.

Large Bales: Use balers to harvest crop, reducing PM1O

emissions from crops traditionally harvested by

chopping, truck passes, and residue burning.

Multiple CMPs in another category:

Night Harvesting: Implement cultural practices at night or when the

humidity is high.

Shuftle System: Haul multiple or larger trailers/bins per trip thereby

reducing the number oftrips.

Other (special approval required): Contact District (760) 872-821 1 for approval

Page 4 of 17
organic matter. Converting to no or low till

operations, implement reduced till activities, adding

soil! water amendments to improve resource and

reduce tillage needs.

Cover Crop: Use seeding or natural vegetationlregrowth of

plants to cover soil surface and reduce wind erosionof soil.

Fallowing Land: Temporary or permanent removal from production

eliminates entire operationlpasses or reduces soildisturbing activities.

Multiple CMPs in another category:Organic Practices: Use biological control methods or non-chemical

control methods. Reduces chemical use and numberof application passes.

Surface Roughening: In wind-prone areas, conduct surface roughening by

bedding, rough disking, or tillage that leaves thesurface covered with stable clods.

Time of Disturbance/Planting: Time planting to coincide with the time of year

when PM concentrations are less.

Other (special approval required): Contact District (760) 872-8211 for approval

Page 5 ofl7
emissions reductions as long as paved surface is

kept clean.)

Road Oil: Apply road oil to the unpaved road surface area.Washed Gravel: Apply washed gravel to the unpaved road surface

area.

Water: Apply water at a sufficient quantity and frequency

to maintain moist surface under windy conditions.

Other (speciaL approval required): Contact District (760) 872-8211 for approval

Page 6 of 17
Chips / Mulches: Apply wood chips or mulch to the unpaved road

surface area.

Dust Suppressant: Apply an approved dust suppressant at a sufficient

quantity and frequency to prevent windblown dust.

Less than 10 vehicle trips on any day:

Organic Materials: Apply organic materials to the unpaved road

surface area.

Paving: Pave unpaved roads. (Gives maximum PM-10

emissions reductions as long as paved surface is - kept clean.)

Polymers: Apply polymers to the unpaved road surface area.Road Oil: Apply road oil to the unpaved road surface area.

Speed Limits: Control speed limits to 15 mph on unpaved roads

. through worker behavior modification, signage, or

any other necessary means.

Track-Out Control: Minimize dirt material tracked out onto public

roadways by paving or chemically stabilizing, or

: applying gravel to the unpaved road surface for a

distance of at least 100 feet from the publicroadway. Check or clean the underside of all haul

trucks before leaving the parking or staging area.

Water: Apply water to the unpaved road surface area.Washed Gravel: Apply washed gravel to the unpaved road surface

area.

Wind Barrier: Plant trees or establish other barriers on the

typically upwind side of the traffic area to minimize

windblown dust from the unpaved surface.

Other (special approval required): Contact District (760) 872-821 1 for approval

Page7ofl7
EQUAL TO 25)

Dust Suppressant: Apply an approved dust suppressant at a sufficient

quantity and frequency to prevent windblown dust.

Paving: Pave unpaved vehicle / equipment areas. (Gives

maximum PM-10 emissions reductions as long as

paved surface is kept clean.)

Road Oil: Apply road oil to the unpaved vehicle/equipment

area surface.

Vegetative material: Apply vegetative material to the unpaved

. vehicle/equipment area surface.

Washed Gravel: Apply washed gravel to the unpaved

vehicle/equipment area surface.

Water: Apply water to the unpaved vehicle/equipment area

surface.

Other (special approval required): Contact District (760) 872-8211 for approval

Page 8 of 17
Chips / Mulches: Apply wood chips or mulches to the unpaved

vehicle/equipment area surface.

Less than 10 vehicle trips on any day:

Organic materials: Apply organic material to the unpaved

. vehicle/equipment area surface.

Polymers: Apply polymers to the unpaved road surface area.

Restricted Access: Restrict public access to unpaved

vehicle/equipment area surface using signage or

physical access restrictions (e.g., access barrier)and/or limit total trips to less than 10 per day.

Road Oil: Apply road oil to the unpaved vehicle/equipment

area surface.

Speed Limits: Control speed limits to 15 mph on unpaved vehicle

/ equipment area through worker behavior

modification, signage, or any other necessary

means.

Paving: Pave unpaved vehicle / equipment areas. (Gives

maximum PM-b emissions reductions as long as

paved surface is kept clean.)

Water: Apply water to the unpaved vehicle/equipment area

surface.

Washed Gravel: Apply washed gravel to the unpaved

vehicle/equipment area surface.

Wind Barrier: Plant trees or establish other barriers on the

typically upwind side of the traffic area to minimize

. windblown dust from the unpaved surface.

Other (special approval required): Contact District (760) 872-821 1 for approval

Page 9 of 17
Cessation of Activities: No disking, tilling or other land preparation

activities shall take place when active wind erosion

is observed on a field and visible particulate matter

.

leaves the property from which it originates.

Chemigation/Fertigation: Application of chemicals through an irrigation

system reduces the need to travel in-field for

application purposes.

Combined Operations: Combine equipment to perform several operations

during one pass, thereby reducing the number of

passes necessary to cultivate the land.

Conservation Irrigation: Conserving water through drip, sprinkler,

, underground lines, conserves water and reduces

weed population and need for tillage.

Conservation tillage (e.g.: no tillage, Types oftillage that reduce loss of soil and water in

minimum tillage) comparison to conventional tillage. Reduces the

number of passes, soil disturbance. It improves soil

because it retains plant residue and increases

organic matter. Converting to no or low till

operations, implement reduced till activities, adding

soil! water amendments to improve resource and

reduce tillage needs.

Cross Wind Stripcropping: Establish crops in strips across the prevailing wind

direction and arranged so that strips susceptible to

wind erosion are alternated with strips resistant to

wind erosion.

Equipment Changes/Technological Use larger equipment, modify land planing and land

Improvements: leveling, matching the equipment to row spacing to reduce the number of passes.

Multiple CMPs in another category:

Mulching: Applying or leaving plant residue or other material

on the soil surface. Reduces wind entrainment of

dust, and reduces weed competition.

Night Farming: Operate at night when moisture levels are higher and winds tend to be lighter, thereby reducing dust

emissions.

List of CMPs options continued on next page

Page 10 of 17
p

g

g p

y 

g

number of passes and soil disturbances compared to

seeding operations.

Other (special approval required): Contact District (760) 872-82 1 1 for approval

Page 11 of 17
Equipment Changes/Technological Use larger equipment, modify land planing and land

Improvements: leveling, matching the equipment to row spacing to

reduce the number of passes.

Hand Harvesting: Harvest crop by hand thereby reducing soil

disturbances by equipment.

Multiple CMPs in another category:

Night Harvesting: Implement cultural practices at night or when the

humidity is high.

Pre-Harvest Soil Preparation: Apply a light amount of water or other stabilizing

material to soil prior to harvest.

Shed Packing: Pack commodities in a covered or closed area.

Shuttle System: Haul multiple or larger trailers/bins per trip thereby

reducing the number oftrips.

Other (special approval required): Contact District (760) 872-82 1 1 for approval

Page 12of17
p

p

eliminates entire operation/passes or reduces soil

. disturbing activities.

Multiple CMPs in another category:Non-tillage/Chemical Tillage: Use flail mower, low volume sprayers, or heat

delivery systems (as harvest pre-conditioner).Reduces or eliminates number of soil tillage passes.

Organic Practices: Use biological control methods or non-chemical

control methods. Reduces chemical use and number

of application passes.

Soil Moisture Management: Ensure adequate soil moisture levels at the time of

tillage or soil maintenance to reduce dust emissions.

Surface Roughening: In wind-prone areas, conduct surface roughening by

bedding, rough disking, or tillage that leaves thesurface covered with stable clods.

Time of Disturbance/Planting: Time planting to coincide with the time of year

when PM concentrations are less.

Wind Barriers: Plant or maintain perennial or annual plants

interspersed throughout a crop field as close to

perpendicular as practical to the direction of

prevailing winds.

Other (special approval required): Contact District (760) 872-82 1 1 for approval

Page 13 of 17
Paving: Pave unpaved roads. (Gives maximum PM-b emissions reductions as long as paved surface is

• kept clean.)

Road Oil: Apply road oil to the unpaved road surface area.

Washed Gravel: Apply washed gravel to the unpaved road surface

area.

Water: Apply water at a sufficient quantity and frequency

to maintain moist surface under windy conditions.

Other (special approval required): Contact District (760) 872-821 1 for approval

Page 14 of 17
Chips / Mulches: Apply wood chips or mulch to the unpaved road

surface area.

Dust Suppressant: Apply an approved dust suppressant at a sufficient

quantity and frequency to prevent windblown dust.

Less than 10 vehicle trips on any day:

Organic Materials: Apply organic materials to the unpaved road

surface area.

Paving: Pave unpaved roads. (Gives maximum PM-10

emissions reductions as long as paved surface is

kept clean.)

Polymers: Apply polymers to the unpaved road surface area.Road Oil: Apply road oil to the unpaved road surface area.

Speed Limits: Control speed limits to 15 mph on unpaved roads

through worker behavior modification, signage, or

any other necessary means.

Track-Out Control: Minimize dirt material tracked out onto public

roadways by paving or chemically stabilizing, or

applying gravel to the unpaved road surface for adistance of at least 100 feet from the publicroadway. Check or clean the underside of all haul

. trucks before leaving the parking or staging area.

Water: Apply water to the unpaved road surface area.Washed Gravel: Apply washed gravel to the unpaved road surface

, area.

Wind Barrier: Plant trees or establish other barriers on the

typically upwind side ofthe traffic area to minimizewindblown dust from the unpaved surface.

Other (special approval required): Contact District (760) 872-82 1 1 for approval

Page 15 of 17
EQUAL TO 25)

Dust Suppressant: Apply an approved dust suppressant at a sufficient

quantity and frequency to prevent windblown dust.

Paving: Pave unpaved vehicle / equipment areas. (Gives

maximum PM-lO emissions reductions as long as

paved surface is kept clean.)

Road Oil: Apply road oil to the unpaved vehicle/equipment

area surface.

Vegetative material: Apply vegetative material to the unpaved

vehicle/equipment area surface.

Washed Gravel: Apply washed gravel to the unpaved

vehicle/equipment area surface.

Water: Apply water to the unpaved vehicle/equipment area

surface.

Other (special approval required): Contact District (760) 872-82 1 1 for approval

Page 16 of 17
Chips / Mulches: Apply wood chips or mulches to the unpaved

vehicle/equipment area surface.

Less than 10 vehicle trips on any day:

Organic materials: Apply organic material to the unpaved

vehicle/equipment area surface.

Polymers: Apply polymers to the unpaved road surface area.Restricted Access: Restrict public access to unpaved

vehicle/equipment area surface using signage orphysical access restrictions (e.g., access barrier)

and/or limit total trips to less than 10 per day.

Road Oil: Apply road oil to the unpaved vehicle/equipment

area surface.

Speed Limits: Control speed limits to 15 mph on unpaved vehicle

/ equipment area through worker behavior

. modification, signage, or any other necessary

means.

Paving: Pave unpaved vehicle / equipment areas. (Gives

maximum PM-b emissions reductions as long aspaved surface is kept clean.)

Water: Apply water to the unpaved vehicle/equipment area

surface.

Washed Gravel: Apply washed gravel to the unpaved

vehicle/equipment area surface.

Wind Barrier: Plant trees or establish other barriers on the

typically upwind side ofthe traffic area to minimize

windblown dust from the unpaved surface.

Other (special approval required): Contact District (760) 872-821 1 for approval

Page 17 of 17

BlO #111205-07

December 5, 2011

I HEREBY CERTIFY that ata regular meeting of the Great Basin Unified Air Pollution Control

District Governing Board held in Mono County Board of Supervisors Chambers, Bridgeport,California on December 5, 2011 an order was duly made and entered as follows:

AGENDA ITEM #7: CONSENT AGENDA ITEMS A THROUGH B AND E

A motion was made by Eastman and seconded by Cervantes approving consent agenda

items a through b and e as follows:

a) Approval of revised agricultural activities Conservation Management Practices

Guidance as requested by the United States Environmental Protection agency.

b) Adoption of the 2012 District Rule adoption/revision schedule as required by California

Health & Safety Code §40923. (US EPA 105 Grant Program)

e) Approve purchase orders with NRG Systems in the amount of $5,471.12 for

anemometers; California P&C, Inc. in the amount of $3,971.73 for HD remotecameras; and Trango Broadband Wireless in the amount of $2,675.23 for network

communication antennas.

Ayes: Board Members — Arcularius, Hansen, Johnston, Eastman, Veatch, Sweeney, Cervantes

Noes: 0

Abstain: 0

Absent: 0

Motion carried 7/0 and so ordered.

ATTEST:

Tori DeHaven, Clerk of the Board

June 8,2011

Mr. Theodore D. Schade

Air Pollution Control Officer

Great Basin Unified Air Pollution Control District

157 Short Street

Bishop, California 935 14-3537

Dear Ted,As we recently discussed, EPA has completed a preliminary review of Rule 502 as adopted by the Great Basin Unified Air Pollution Control District (GBUAPCD) on July 7, 2005 and

submitted to EPA by the California Air Resources Board (CARB) on October 20, 2005. We

understand that GBUAPCD adopted this rule primarily to comply with California Senate Bill

700, and that the rule may not be needed to comply with Federal Clean Air Act (CAA) State

Implementation Plan (SIP) requirements at this time. Nonetheless, EPA is required under CAA Section 110 to approve or disapprove all such SIP submittals within one year of determining that the submittals are complete.

EPA generally reviews SIP rule submittals such as this one against three criteria: enforceability, anti-backsliding, and stringency. While this rule would improve the SIP and fulfills the antibacksliding and stringency criteria, we do not believe it is fully enforceable. As a result, ifwe

propose action on this rule pursuant to CAA Section 110, we would propose a simultaneous

limited approval and limited disapproval. If we finalize such action, it would have the effect of

incorporating the rule requirements into the federally-enforceable SIP, while notifying the public of our enforceability concerns. There would be no CAA sanction or FIP implications ofthis

action because we do not believe it is a required submittal at this time.

Our concern partly regards Rule 502 Section 6.2, which directs owner/operators to select one

CMP from the CM? list for each of the applicable CMP categories. However, the rule does not

contain a clear, consistent listing or description of what constitutes an “applicable” category. In addition, the supporting documents are not consistent in terms of applicable CMP categories and CMPs. See, for example, the Board Report dated July 7, 2005 Attachment C; Program Description and Plan Application Forms dated December 19, 2008; and the optional CMP

application forms (2005, 2008). This is problematic because the type and number of applicable CMP categories determines the number ofCMPs required by the rule. To address this issue, the

applicable CMP categories should be clarified and made consistent among the rule, the CMP list,

the plan description, the application forms, and any other supporting information for the rule.
47tcç

An ew Steckel, Manager

Air Division, Rules Office

cc. Mike Guzzetta, CARB