Final Staff Report and 

Recommendations on Agricultural Burning 

Chapter 6 

Cost Impacts of Alternatives to Burning 
Final Staff Report and 

Recommendations on Agricultural Burning 

This page intentionally blank. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-1 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Chapter 6: COST IMPACTS OF ALTERNATIVES TO BURNING 

(for each affected crop/material)

The costs shown in this analysis are borne by growers. Growers typically pay 

the contractor to burn, chip, or shred the materials. The biomass facilities also 

pay chipping operators for the chipped material. The District is estimating 

incremental costs of non-burning alternatives by subtracting the cost of open 

burning from the total cost of the alternative. The incremental costs are then 

used in further analysis. 

6.1 COSTS FOR OPEN BURNING 

6.1.1 Costs for Orchard and Vineyard Removal by Open Burning 

Since the entire orchard or vineyard removal process may be affected by the 

method utilized for disposal of the material, the District examined current costs 

for the complete removal/burning process including tree or vine extraction, 

transport/piling and burning. For orchard removals, the trees are typically either 

pushed over with a dozer or removed from the ground with an excavator. Large 

trees may require some breaking up for handling. After drying in the field, the 

downed trees are then moved to burn piles either by dozer or wheel-loader. 

Vineyards are typically bull dozed into piles for burning with vineyard wire in 

place (the wire is removed and disposed after burning is complete). 

To obtain costs, orchard removal contractors in the SJV were contacted who 

provided expected average costs for the removal and burning for various orchard 

types and vineyards. All contractors requested confidentiality with respect to 

their pricing. Per discussions with the contractors, actual cost for a particular site 

will vary with specific orchard or vineyard configuration and site conditions. 

The agricultural industry also provided estimates for removal/burning operations. 

Average pricing provided to the District by the orchard removal contractors as 

well as estimates provided by the agricultural industry are as follows: 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-2 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Table 6-1 

Prices for Orchard and Vineyard Removals by Open Burning 

$ per acre 

 Citrus 

Average for 

other Orchards 

including nuts, 

stone fruit and 

general 

deciduous 

Vineyards 

Minimum 

Charge per 

Burning 

Project 

Average 

Contractor 

Pricing 

$400 $267 $213 $1,150 

Ag Industry 

Estimates $314 - $267 - 

The above pricing includes burning of roots, assuming the roots would be 

extracted from the ground prior to the burning operation. Orchard removal 

contractors generally indicated citrus orchard removal and burning to be 

somewhat more difficult than the average for other types of orchards and 

indicated a higher price for this specific type. 

Agricultural industry estimates for open burning did not specifically address 

orchard removals other than Citrus. For purposes of analysis, the District will 

assume that the agricultural industry estimate of $314 per acre applies to all 

orchards. Additionally, agricultural industry estimates did not address a minimum 

project charge for burning projects. For purposes of analysis, the District will 

assume that the minimum project charge estimated by orchard contractors will be 

generally applicable. 

6.1.2 Costs for Disposal of Orchard Prunings by Open Burning 

Disposal of orchard prunings by open burning requires that the prunings be 

pushed to the end of each row and then piled for burning. Pruning weights are 

typically 1 to 1.5 tons per acre on a wet basis (30-35% moisture) for orchards 

regardless of tree type per information provided both by orchard contractors and 

the farming industry. To burn the prunings, costs must be incurred to 1) push the 

prunings to the end of each row and then pile them for burning, 2) obtain a 

burning permit and 3) then supervise the burn. The farming industry estimates 

the cost of this activity at approximately $22 per acre. It is assumed that a $500 

minimum project cost would be required by a contractor to perform these 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-3 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

services consistent with quoted project minimums for smaller chipping 

operations. 

6.2 COSTS OF ALTERNATIVES TO BURNING 

6.2.1 Costs for Orchard and Vineyard Removal for fuel at Biomass Power 

Plants 

The District has identified the grinding (or chipping) of orchard removal material 

followed by utilization of the material as fuel for power generation as a feasible 

alternative to open burning. In this approach for orchard removal the trees are 

typically extracted or pushed over and then allowed to dry in the field for 

approximately four weeks prior to grinding (except for citrus for which a drying 

time of approximately eight weeks is required to ensure that grinding will produce 

a usable biomass fuel). After drying, the downed trees are typically loaded on a 

wheel-loader which transports them to the grinder. The grinder may be either a 

tub grinder or a horizontal hammer mill, depending upon the contractor and/or 

the specifics of the job. After grinding, the biomass is normally loaded into heavy 

haul trucks and transported to the biomass facility. 

To obtain costs for conversion of orchard removal matter into biomass fuel, the 

District contacted several established orchard removal contractors and obtained 

budgetary quotations for typical orchard removal operations with conversion of 

the material to biomass. In addition, the agricultural industry provided cost 

estimates for this activity. Results of the cost survey are presented in the 

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

 Revised July 21, 2010 

6-4 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Table 6-2 

Cost for Orchard and Vineyard Removals by Grinding to Biomass Fuel 

$ per acre 

Citrus Other Orchards Vineyards Minimum Charge per Project 

Orchard 

Contractors

Ag 

Industry 

Estimate 

Orchard 

Contractors

Ag 

Industry 

Estimate 

Orchard 

Contractors

Ag 

Industry 

Estimate 

Orchard 

Contractors

Ag 

Industry 

Estimate

Average 

Contractor 

Quote/Estimate 

for Orchard 

Removal 

$525 $580 $388 $400 $225 $380 

Transporting and 

Composting 

Roots 

$244 $75 $244 $75 $75 $244 

Removal of 

Vineyard Wire 

and Trellis 

N/A N/A N/A N/A $650 $775 

$5,000 $5,000 

Total Evaluated 

Cost Based on 

Average 

Contractor Quote 

or Ag Industry 

Estimate 

$769 $655 $632 $475 $950 $1,399 $5,000 $5,000 

Cost Differential 

Between 

Grinding to 

Biomass and 

Open Burning 

$369 $341 $365 $161 $737 $1,132 $3,850 $3,850 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-5 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Per discussions with the contractors providing budgetary estimates, the actual 

cost for a particular site will vary with specific orchard or vineyard configuration, 

site conditions, haul distance to a biomass power plant and the current price paid 

for biomass fuel. To ensure that the quoted costs would be comparable to those 

quoted for open burning, the scope included tree removal, grinding and transport 

to the biomass facility. The pricing did not include any impact from any federal or 

other incentive programs aimed at promoting use of agricultural material as 

biomass fuel (since such programs are considered temporary). 

Similar to the pricing obtained for orchard burning, the District’s discussions with 

orchard removal contractors also indicated that the pricing for citrus orchards is 

higher than the average for other orchard types, primarily due to issues with 

separation of dirt from the root ball in clay or rocky soil and the lower desirability 

of citrus as biomass fuel. This is consistent with the estimates provided by the 

agricultural industry which also indicate a higher pricing for citrus versus other 

types of orchards. Based on discussions with contractors, a value of 30 tons 

biomass fuel per acre was assumed for citrus orchards. 

In the costs presented in the table above, the District’s data assumed that the 

roots, after drying in the field, will be transported to a composting operation. The 

following cost estimates were provided by the ag industry for removing root 

materials: $75 for one ton of roots and $244 for four tons of roots. For orchard 

removals, District staff estimated the roots to weigh four tons per acre. For 

vineyard removals, District staff assumed that the roots weigh one ton per acre. 

Ag industry estimates were based on 1 ton of roots per acre for orchards and 4 

tons per acre for vineyards. 

As with open burning, the prices listed above do not include extraction of roots 

from the field and the loading of roots into piles for further handling because as 

mentioned previously, it is assumed that this cost will be incurred regardless of 

the approach used for orchard or vineyard removal and thus can be ignored for 

the District’s comparative analysis. 

Review of Table 6-2 indicates that the prices obtained by the District for open 

burning and grinding for biomass are very similar to the estimates provided by 

the ag industry. In addition, since the pricing differential between grinding to 

biomass and open burning shown in Table 6-2 is generally greater when based 

on the quotations obtained by the District rather than on the information provided 

by the ag industry, the District’s cost effectiveness analysis will be performed 

based only on the quotations obtained by the District since this will provide the 

most conservative analysis with respect to industry’s concerns. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-6 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

6.2.2 Costs for Disposal of Orchard Prunings by Chipping 

Options for chipping and recycle of prunings consist of: 

1. Chipping prunings for conversion to biomass fuel

2. In-row chipping of prunings for on-site land incorporation 

The practice of chipping prunings for conversion to biomass fuel is less 

commonly practiced in comparison to in-row chipping for land incorporation and 

the pricing was found to be variable depending upon the business approach by 

the contractor. Information provided by an operator with smaller chipping 

equipment indicated that prunings could be chipped for biomass at a cost of $100 

per dry ton with a minimum job charge of $500. An operator with large grinding 

equipment indicated that under good conditions the cost could be $40 - $60 per 

ton with a minimum of $6,000 per day when grinding prunings for biomass. 

Costs for chipping prunings for land incorporation have been included in a 

number of recent studies by the University of California Cooperative Extension as 

presented in Table 6-3: 

Table 6-3 

Published Costs for In-Row Chipping of Prunings for Land Incorporation 

UC Report Title Date 

Cost per Acre to 

Shred Prunings 

NC-VS-09 

Sample Costs to Establish and 

Produce Nectarines 2009 $41 

OL-SV-09 Sample Costs to Produce Olives 2009 $10 

PH-VS-09 

Sample Costs to Establish and 

Produce Peaches 2009 $41 

WN-VN-07 

Sample Costs to Establish and 

Produce Walnuts 2007 $27 

AM-VS-08-1

Sample Costs to Establish and 

Produce Almonds 2007 $24 

In addition, a chipper operator was contacted to obtain a budgetary quotation. 

This contractor indicated an in-row chipping price of $26 per acre with a $500 

project minimum, regardless of tree type. An analysis provided by the farming 

industry indicated that the in-row chipping operation for almonds would cost $30-

$65 per acre depending upon the age of the trees. For purposes of this analysis 

and based on the information above, the District will assume that the prices for 

in-row chipping for land incorporation may vary from $30 to $60 per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-7 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

6.3 COST EFFECTIVENESS OF ALTERNATIVES TO OPEN BURNING 

6.3.1 Approach 

In general, the reduction of agricultural material from the pruning or the removal 

of orchards and vineyards by grinding or chipping followed by conversion to 

either biomass fuel or land incorporation results in fewer emissions when 

compared to open burning; however, these operations may incur extra costs over 

those associated with open burning. To examine the cost feasibility of these 

alternatives, cost effectiveness (CE) in dollars per ton of emission reduction is 

defined as the cost differential between chipping or grinding and open burning in 

dollars per acre divided by the difference between burning and chipping in per 

acre total emissions (PM2.5 + NOx + VOC), or: 

(($/acre)chip - ($/acre)burn)

CE =

(

(tonsemissions/acre)burn -(tonsemissions/acre)chip

)

The cost effectiveness calculated by the above expression will primarily be a 

function of the type of tree or plant (which determines the difficulty of removal 

and the amount and fuel quality of the material, affecting both the denominator 

and numerator of the above expression) and of the total acreage which affects 

the numerator of the above expression since operations on smaller acreages 

cost more per acre due to the project minimums imposed by most orchard 

contractors. 

6.3.2 Emissions Due To Open Burning 

Open Burning of Orchard Removals

Emissions of PM2.5, NOx and VOC from open burning operations have been 

estimated by the District based on the following: 

• Emissions estimates for orchard removals include: 

1. Highway vehicle emissions to deliver mobile equipment to the site 

2. Emissions from a dozer used to remove the trees or vines 

3. Emissions from a wheel loader used to stack trees or vines into piles 

for burning 

4. Tractor emissions for collection and stacking of roots for burning 

5. Emissions from open burning of trees, vines and roots 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-8 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Emission factors for open burning are taken from the District’s 2008 Area 

Sources Emission Inventory Methodology (revised 01Jun09) for orchard 

removals. Values are: 

PM2.5 7.3 lb/ton material burned 

NOx 5.2 lb/ton material burned 

VOC 5.2 lb/ton material burned 

• Highway vehicle emissions for delivery of equipment assumes two 100 

mile round-trips for a heavy haul truck to deliver a dozer and a wheel 

loader. 

• Dozer emissions are estimated based on a 300 hp Tier 2 diesel engine 

requiring one hour of operation for 70 tons for material. 

• Wheel loader emissions are estimated based on a 250 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

• Tractor emissions required for piling and burning of roots are estimated 

based on an 80 hp tier 2 diesel engine operating at a rate of one hour per 

acre. 

Open Burning of Orchard Prunings

Emissions of PM2.5, NOx and VOC from open burning operations have been 

estimated by the District based on the following: 

• Emissions estimates for orchard removals include: 

1. Highway vehicle emissions to deliver mobile equipment to the site 

2. Emissions from a wheel loader used to stack trees or vines into piles 

for burning 

3. Emissions from open burning of prunings 

• Emission factors for open burning are taken from the District’s 2008 Area 

Sources Emission Inventory Methodology (revised 01Jun09) for orchard 

removals. Values are: 

PM2.5 7.3 lb/ton material burned 

NOx 5.2 lb/ton material burned 

VOC 5.2 lb/ton material burned 

• Highway vehicle emissions for delivery of equipment assumes one 100 

mile round-trip for a heavy haul truck to deliver a wheel loader to the site. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-9 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Wheel loader emissions are estimated based on a 250 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

6.3.3 Emissions Due to Grinding and Conversion of Material to Biomass 

Fuel 

Grinding and Conversion of Material from Orchard Removals to Biomass Fuel

Emissions of PM2.5, NOx and VOC from grinding and conversion have been 

estimated by the District based on the following: 

• Emissions estimates for grinding and conversion of material to biomass 

fuel include: 

1. Highway vehicle emissions to deliver mobile equipment to the site, 

deliver ground material to the biomass plant and to deliver roots to a 

composting operation 

2. Emissions from an excavator or dozer used to remove the trees or 

vines 

3. Emissions from two wheel loaders used to stack trees, vines, and roots 

into piles for burning 

4. PM2.5 emissions from grinding of trees, vines and roots 

5. Engine emissions (PM2.5, NOx, and VOC) from the grinder 

6. Dozer operation at the biomass facility to receive and handle the fuel 

7. Power plant emissions due to fuel burning 

• The PM2.5 emission factor for grinding (0.05 lb per ton) was based on a 

review of existing District permits for grinding wood material and vineyard 

materials. A review of four existing permits indicated a range of 0.0088 

lb/ton to 0.08 lb/ton with an average of 0.03. 

• Emission factors for biomass power plant operation are based on reported 

operation for the Delano plant. Values are: 

PM2.5 0.86 lb/ton material burned 

NOx 1.92 lb/ton material burned 

VOC 0.38 lb/ton material burned 

• Highway vehicle emissions calculations assume four 100 mile round-trips 

for a heavy haul truck to deliver a tubgrinder, an excavator and two wheel 

loaders to the site, one (1) 100-mile round trip for every 24 tons of ground 

material for delivery to the biomass power plant, and one (1) 100-mile 

round trip for every 24 tons of roots for delivery to composting operation. 

• Excavator emissions for orchard removal are estimated based on a 240 

hp Tier 1 diesel engine requiring one hour of operation per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-10 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Wheel loader emissions associated with the grinding operation are 

estimated based on a 250 hp Tier 2 diesel engine operating at a rate of 

three hours per acre. 

• Tub grinder emissions are estimated based on a 1000 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

• Dozer emissions for receiving and handling material at the biomass power 

plant are estimated based on a 300 hp Tier 2 diesel engine requiring two 

hours of operation for 70 tons for material received. 

• Wheel loader emissions required for gathering and loading roots for 

transport to a composter are estimated based on a 250 hp Tier 2 diesel 

engine operating at a rate of one hour per acre. 

Grinding and Conversion of Orchard Prunings to Biomass Fuel

Emissions of PM2.5, NOx and VOC from grinding and conversion have been 

estimated by the District based on the following: 

• Emissions estimates for grinding and conversion of material to biomass 

fuel include: 

1. Highway vehicle emissions to deliver mobile equipment to the site and 

deliver ground material to the biomass plant 

2. Emissions from one wheel loader used to handle prunings 

3. PM2.5 emissions from grinding of prunings 

4. Engine emissions (PM2.5, NOx, and VOC) from the grinder 

5. Dozer operation at the biomass facility to receive and handle the fuel 

6. Power plant emissions due to fuel burning 

• The PM2.5 emission factor for grinding (0.05 lb per ton) was based on a 

review of existing District permits for grinding wood material and vineyard 

materials. A review of four existing permits indicated a range of 0.0088 

lb/ton to 0.08 lb/ton with an average of 0.03. 

• Emission factors for biomass power plant operation are based on reported 

operation for the Delano plant. Values are: 

PM2.5 0.86 lb/ton material burned 

NOx 1.92 lb/ton material burned 

VOC 0.38 lb/ton material burned 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-11 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Highway vehicle emissions calculations assume two 100 mile round-trips 

for a heavy haul truck to deliver a grinder and a wheel loader to the site 

and one (1) 100-mile round trip for every 24 tons of ground material for 

delivery to the biomass power plant. 

• Wheel loader emissions associated with the grinding operation are 

estimated based on a 250 hp Tier 2 diesel engine operating at a rate of 

three hours per acre. 

• Grinder emissions are estimated based on a 100 hp Tier 2 diesel engine 

operating at a rate of one hour per acre. 

• Dozer emissions for receiving and handling material at the biomass power 

plant are estimated based on a 300 hp Tier 2 diesel engine requiring two 

hours of operation for 70 tons for material received. 

Chipping of Prunings for Land Incorporation

Emissions of PM2.5, NOx and VOC from grinding and conversion have been 

estimated by the District based on the following: 

• Emissions estimates for chipping of prunings for land incorporation 

include: 

1. Highway vehicle emissions to deliver mobile equipment to the site 

2. Emissions from a wheel loader used to handle the prunings 

3. PM2.5 emissions from grinding of prunings 

4. Engine emissions (PM2.5, NOx, and VOC) from the grinder 

• The PM2.5 emission factor for grinding (0.05 lb per ton) was based on a 

review of existing District permits for grinding wood material and vineyard 

materials. A review of four existing permits indicated a range of 0.0088 

lb/ton to 0.08 lb/ton with an average of 0.03. 

• Highway vehicle emissions calculations assume two 100 mile round-trips 

for a heavy haul truck to deliver a grinder or chipper and one wheel loader 

to the site. 

• Chipping or grinding emissions are estimated based on a 415 hp Tier 1 

diesel engine requiring one hour of operation per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-12 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

• Wheel loader emissions associated with the grinding operation are 

estimated based on a 250 hp Tier 2 diesel engine operating at a rate of 

one hour per acre. 

6.3.4 Per Acre Costs and Per Acre Emissions 

Table 6-4 presents the results of the District’s evaluation of emissions and per 

acre costs for converting orchard removal material to biomass fuel by grinding 

versus open burning for orchards other than citrus. Likewise, Table 6-5 presents 

the results of the District’s evaluation emissions and per acre costs for converting 

orchard removal material to biomass fuel by grinding versus open burning for 

citrus orchards. The tables present results for plot sizes between 1 and 20 acres, 

with the expected emissions and cost for burning per acre, expected emissions 

and cost for grinding per acre, differential emissions and differential cost per 

acre. The cost structure shown in the tables reflects a $5,000 minimum charge 

required for orchard removals by grinding to biomass and a minimum charge of 

$1,150 for orchard removal by open burning. The “per acre” charge indicated in 

Table 6-2 only becomes effective after the minimum project cost is exceeded. As 

a result, per-acre cost is generally higher for smaller acreages, trending to a 

lower fixed value for larger acreages as would be expected. Per acre emissions 

are also somewhat higher for smaller acreages primarily due to the emissions 

associated with mobilization of equipment at the site. 

Table 6-6 presents a similar analysis for vineyard removals with a pricing 

structure similar to Tables 6-4 and 6-5. As with orchards, per-acre costs and 

cost effectiveness value is generally higher for smaller acreages, trending to a 

lower fixed value for larger acreages. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010

 Revised July 21, 2010 

6-13 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

NO x PM 2.5 VOC NO x PM 2.5 VOC NO x PM 2.5 VOC

1 0.0945 0.1240 0.1075 $1,150 0.0575 0.0145 0.0065 $5,244 0.0370 0.1095 0.1010 $4,094

2 0.0925 0.1243 0.1073 $575 0.0503 0.0143 0.0065 $2,744 0.0422 0.1100 0.1008 $2,1693 0.0918 0.1242 0.1072 $383 0.0480 0.0142 0.0065 $1,911 0.0438 0.1100 0.1007 $1,5274 0.0915 0.1241 0.1073 $288 0.0468 0.0141 0.0065 $1,494 0.0447 0.1100 0.1008 $1,2075 0.0913 0.1242 0.1072 $267 0.0465 0.0141 0.0065 $1,244 0.0448 0.1101 0.1007 $977

6 0.0912 0.1242 0.1072 $267 0.0460 0.0141 0.0065 $1,077 0.0452 0.1101 0.1007 $8107 0.0911 0.1241 0.1072 $267 0.0459 0.0141 0.0065 $958 0.0452 0.1100 0.1007 $6918 0.0910 0.1242 0.1072 $267 0.0456 0.0141 0.0065 $869 0.0454 0.1101 0.1007 $6029 0.0909 0.1242 0.1072 $267 0.0456 0.0141 0.0065 $800 0.0453 0.1101 0.1007 $533

10 0.0909 0.1242 0.1072 $267 0.0453 0.0141 0.0065 $744 0.0456 0.1101 0.1007 $47712 0.0908 0.1242 0.1072 $267 0.0450 0.0140 0.0065 $661 0.0458 0.1102 0.1007 $39414 0.0908 0.1242 0.1072 $267 0.0450 0.0141 0.0065 $632 0.0458 0.1101 0.1007 $36515 0.0908 0.1242 0.1072 $267 0.0449 0.0141 0.0065 $632 0.0459 0.1101 0.1007 $36516 0.0908 0.1242 0.1072 $267 0.0448 0.0141 0.0065 $632 0.0460 0.1101 0.1007 $36518 0.0907 0.1242 0.1072 $267 0.0448 0.0141 0.0065 $632 0.0459 0.1101 0.1007 $36520 0.0907 0.1242 0.1072 $267 0.0447 0.0141 0.0065 $632 0.0460 0.1101 0.1007 $365

Basis:

30 BDT/acre for other orchard

4 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding caseGrind & haul cost includes $244 for root composting

Table 6-4 

Per Acre Emissions and Costs Using District Data 

Open Burning versus Grind and Haul for Orchards other than Citrus

Cost Basis: Chipper Contractor Quotations Jan 2010

Orchard 

Removal 

Size

Open Burning Grind & Haul Difference

Emissions 

Tons per Acre Cost $/acre

Emissions 

Tons per Acre Cost $/acre

Emissions Reduction 

Tons per Acre Cost $/acre
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-14 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

NO x PM 2.5 VOC NO x PM 2.5 VOC NO x PM 2.5 VOC

1 0.0945 0.1240 0.1075 $1,150 0.0575 0.0145 0.0065 $5,244 0.0370 0.1095 0.1010 $4,094

2 0.0925 0.1243 0.1073 $575 0.0503 0.0143 0.0065 $2,744 0.0422 0.1100 0.1008 $2,169

3 0.0918 0.1242 0.1072 $400 0.0480 0.0142 0.0065 $1,911 0.0438 0.1100 0.1007 $1,5114 0.0915 0.1241 0.1073 $400 0.0468 0.0141 0.0065 $1,494 0.0447 0.1100 0.1008 $1,0945 0.0913 0.1242 0.1072 $400 0.0465 0.0141 0.0065 $1,244 0.0448 0.1101 0.1007 $844

6 0.0912 0.1242 0.1072 $400 0.0460 0.0141 0.0065 $1,077 0.0452 0.1101 0.1007 $6777 0.0911 0.1241 0.1072 $400 0.0459 0.0141 0.0065 $958 0.0452 0.1100 0.1007 $5588 0.0910 0.1242 0.1072 $400 0.0456 0.0141 0.0065 $869 0.0454 0.1101 0.1007 $4699 0.0909 0.1242 0.1072 $400 0.0456 0.0141 0.0065 $800 0.0453 0.1101 0.1007 $400

10 0.0909 0.1242 0.1072 $400 0.0453 0.0141 0.0065 $769 0.0456 0.1101 0.1007 $36912 0.0908 0.1242 0.1072 $400 0.0450 0.0140 0.0065 $769 0.0458 0.1102 0.1007 $36914 0.0908 0.1242 0.1072 $400 0.0450 0.0141 0.0065 $769 0.0458 0.1101 0.1007 $36915 0.0908 0.1242 0.1072 $400 0.0449 0.0141 0.0065 $769 0.0459 0.1101 0.1007 $36916 0.0908 0.1242 0.1072 $400 0.0448 0.0141 0.0065 $769 0.0460 0.1101 0.1007 $36918 0.0907 0.1242 0.1072 $400 0.0448 0.0141 0.0065 $769 0.0459 0.1101 0.1007 $36920 0.0907 0.1242 0.1072 $400 0.0447 0.0141 0.0065 $769 0.0460 0.1101 0.1007 $369

Basis:

30 BDT/acre for citrus4 BDT/acre for rootsRoots are burned in burning case

Roots are transported to composting operation for grinding caseGrind & haul cost includes $244 for root composting

Difference

Emissions 

Tons per Acre

Open Burning

Cost 

$/acre

Table 6-5 

Per Acre Emissions and Costs Using District Data 

Open Burning versus Grind and Haul for Citrus

Cost Basis: Chipper Contractor Quotations Jan 2010

Emissions 

Tons per Acre

Orchard 

Removal 

Size

Cost 

$/acre

Grind & Haul

Emissions Reduction 

Tons per Acre Cost $/acre
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

6-15 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

NOx PM 2.5 VOC NO x PM2.5 VOC NOx PM2.5 VOC

1 0.0210 0.0220 0.0190 $1,150 0.0305 0.0030 0.0020 $5,725 0.0000 0.0190 0.0170 $4,575

2 0.0193 0.0220 0.0190 $575 0.0233 0.0028 0.0018 $3,225 0.0000 0.0192 0.0172 $2,6503 0.0185 0.0220 0.0190 $383 0.0210 0.0027 0.0017 $2,392 0.0000 0.0193 0.0173 $2,0084 0.0183 0.0220 0.0190 $288 0.0199 0.0026 0.0016 $1,975 0.0000 0.0194 0.0174 $1,6885 0.0180 0.0220 0.0190 $230 0.0195 0.0026 0.0016 $1,725 0.0000 0.0194 0.0174 $1,4956 0.0179 0.0220 0.0190 $213 0.0190 0.0026 0.0016 $1,558 0.0000 0.0194 0.0174 $1,3457 0.0176 0.0219 0.0190 $213 0.0186 0.0026 0.0016 $1,439 0.0000 0.0193 0.0174 $1,2268 0.0178 0.0219 0.0189 $213 0.0183 0.0026 0.0016 $1,350 0.0000 0.0193 0.0173 $1,1379 0.0177 0.0219 0.0189 $213 0.0181 0.0026 0.0016 $1,281 0.0000 0.0193 0.0173 $1,068

10 0.0177 0.0220 0.0190 $213 0.0182 0.0026 0.0016 $1,225 0.0000 0.0194 0.0174 $1,01212 0.0176 0.0220 0.0190 $213 0.0178 0.0026 0.0016 $1,142 0.0000 0.0194 0.0174 $929

14 0.0175 0.0220 0.0190 $213 0.0176 0.0026 0.0016 $1,082 0.0000 0.0194 0.0174 $86915 0.0175 0.0220 0.0190 $213 0.0176 0.0026 0.0016 $1,058 0.0000 0.0194 0.0174 $84516 0.0175 0.0219 0.0190 $213 0.0176 0.0026 0.0016 $1,038 0.0000 0.0193 0.0174 $82518 0.0175 0.0219 0.0189 $213 0.0175 0.0026 0.0016 $1,003 0.0000 0.0193 0.0173 $79020 0.0175 0.0220 0.0190 $213 0.0175 0.0026 0.0016 $975 0.0000 0.0194 0.0174 $762

* Grind and haul cost includes $650 per acre for removal of wire and stakes

$75 per acre for composting roots

Basis

5 BDT/acre for Vineyard1 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding case

Grind & Haul

Emissions Reduction 

Tons per Acre Cost $/acre

Difference

Table 6-6 

Per Acre Emissions and Costs Using District Data 

Open Burning versus Grind and Haul for Vineyards/Kiwis

Cost Basis: Chipper Contractor Quotations Jan 2010

Emissions 

Tons per Acre

Open Burning

Cost 

$/acre

Emissions 

Tons per Acre

Orchard 

Remova

l Size

Cost* 

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

 Revised July 21, 2010 

 

6-16 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

Prunings

For the alternative of grinding orchard prunings for conversion to biomass fuel, the 

District evaluated the emissions as follows based on one (1) bone-dry ton per acre 

of prunings and a 20 acre orchard plot size: 

Table 6-7 

Emissions Comparison 

Open Burning versus Grinding for Biomass Fuel 

Burn - lbs/acre Grind/Biomass - 

lb/acre 

Emission Reduction for 

Tons Chipping - lb/acre 

per 

acre 

Acres

PM2.5 NOx VOC PM2.5 NOx VOC PM2.5 NOx VOC 

1 20 7.9 7.7 6.4 1.1 7.6 0.6 6.8 0.1 5.8 

For the alternative of chipping orchard prunings for land incorporation, emissions 

estimates are as follows based on one (1) bone dry ton of prunings per acre: 

Table 6-8 

Emissions Comparison 

Open Burning versus Shredding for Land Incorporation 

Burn - lbs/acre Chip/Land 

Incorporate lb/acre 

Emission Reduction for 

Tons Chipping - lb/acre 

per 

acre 

Acres

PM2.5 NOx VOC PM2.5 NOx VOC PM2.5 NOx VOC 

1 20 7.9 7.7 6.4 0.2 6.2 0.4 7.7 1.5 6.0 

Per the above tables, shredding the pruning materials provides the greatest reduction in 

emissions relative to open burning. Based on the greater emission reductions and 

reliability of cost data, the District will base further analysis only on the alternative method 

of shredding the materials in place. As previously mentioned, shredding operations may 

vary between $30 and $60 per acre depending on the availability of custom shredder and 

the amount of pruning material, while burning costs $22 per acre. District staff has used 

the higher costs of shredding as a conservative estimate and determined the incremental 

cost of shredding to be $38 per acre. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

 

6-17 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

6.4 ADDITIONAL IMPACTS (COST AND AVAILABILITY) OF NEW ARB 

REGULATIONS ON TRUCKS AND EQUIPMENT 

Agricultural representatives note that the costs for the upcoming off-road equipment 

(Tier 3), which needs to be replaced by 2012, need to be considered. The factors in the 

previous rulemaking analysis did not include trucks, Heavy Duty Rules, and AB32 (new 

colors on tractors, turning off AC units). It has been suggested that District staff analyze 

what has changed for the line items for ‘20 acres or less’ in the 2007 analysis. 

Agricultural representatives do not believe there has been any decrease in costs and 

that the new costs will increase for chippers because of the equipment replacements. 

The additional components of the “Off-Road” rule and the amount ($26/ton instead of 

$28/ton) the biomass power plants are now paying for the material could also impact the 

cost analysis. The District’s costs analysis above are based on the most current and 

best available information from the chipping operator and agricultural industry. District 

staff will reevaluate any significant impact to the industry as necessary. 
San Joaquin Valley Unified Air Pollution Control District May 20, 2010 

 Revised July 21, 2010 

 

6-18 Chapter 6: Cost Impacts of 

Alternatives to Burning 

Final Staff Report and 

Recommendations on Agricultural Burning

This page intentionally blank.