Final Staff Report and Recommendations on Agricultural Burning



## Chapter 6

Cost Impacts of Alternatives to BurningFinal Staff Report and Recommendations on Agricultural Burning This page intentionally blank



## .San Joaquin Valley Unified Air Pollution Control Di strict 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 growe rs. Growers typically pay the contractor to burn, chip, or shred the material s. The biomass facilities also pay chipping operators for the chipped material. Th e District is estimating incremental costs of non-burning alternatives by su btracting the cost of open burning from the total cost of the alternative. Th e incremental costs are then used in further analysis.

6.1 COSTS FOR OPEN BURNING

6.1.1 Costs for Orchard and Vineyard Removal by Ope n Burning

Since the entire orchard or vineyard removal proces s may be affected by the method utilized for disposal of the material, the D istrict 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. A fter 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 b urning with vineyard wire in place (the wire is removed and disposed after burni ng 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 con fidentiality with respect to their pricing. Per discussions with the contractor s, actual cost for a particular site will vary with specific orchard or vineyard configu ration and site conditions.

The agricultural industry also provided estimates f or removal/burning operations.

Average pricing provided to the District by the orc hard removal contractors as well as estimates provided by the agricultural indu stry are as follows:San Joaquin Valley Unified Air Pollution Control Di strict 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 Bu rning $ 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, assumi ng the roots would be extracted from the ground prior to the burning oper ation. Orchard removal contractors generally indicated citrus orchard remo val 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 di d not specifically address orchard removals other than Citrus. For purposes o f analysis, the District will assume that the agricultural industry estimate of $ 314 per acre applies to all orchards. Additionally, agricultural industry esti mates 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 Ope n Burning

Disposal of orchard prunings by open burning requir es that the prunings be pushed to the end of each row and then piled for bu rning. 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 bo th 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 contrac tor to perform theseSan Joaquin Valley Unified Air Pollution Control Di strict 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 fo r smaller chipping operations.

6.2 COSTS OF ALTERNATIVES TO BURNING

6.2.1 Costs for Orchard and Vineyard Removal for fu el at Biomass Power

Plants

The District has identified the grinding (or chippi ng) 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 en sure that grinding will produce a usable biomass fuel). After drying, the downed t rees 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 biom ass is normally loaded into heavy haul trucks and transported to the biomass facility

.

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

District contacted several established orchard remo val contractors and obtained budgetary quotations for typical orchard removal op erations with conversion of the material to biomass. In addition, the agricult ural industry provided cost estimates for this activity. Results of the cost s urvey are presented in the following table:San Joaquin Valley Unified Air Pollution Control District May 20, 2010Revised July 21, 20106-4Chapter 6: Cost Impacts ofAlternatives to BurningFinal Staff Report andRecommendations on Agricultural BurningTable 6-2Cost for Orchard and Vineyard Removals by Grindingto Biomass Fuel$ per acreCitrus Other Orchards VineyardsMinimum Charge perProjectOrchardContractorsAgIndustryEstimateOrchardContractorsAgIndustryEstimateOrchardContractorsAgIndustryEstimateOrchardContractorsAgIndustryEstimateAverageContractorQuote/Estimatefor OrchardRemoval$525 $580 $388 $400 $225 $380Transporting andCompostingRoots$244 $75 $244 $75 $75 $244Removal ofVineyard Wireand TrellisN/A N/A N/A N/A $650 $775$5,000 $5,000Total EvaluatedCost Based onAverageContractor Quoteor Ag IndustryEstimate$769 $655 $632 $475 $950 $1,399 $5,000 $5,000Cost DifferentialBetweenGrinding toBiomass andOpen Burning$369 $341 $365 $161 $737 $1,132 $3,850 $3,850San Joaquin Valley Unified Air Pollution Control Di strict 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 budg etary estimates, the actual cost for a particular site will vary with specific orchard or vineyard configuration, site conditions, haul distance to a biomass power p lant 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 re moval, grinding and transport to the biomass facility. The pricing did not inclu de any impact from any federal or other incentive programs aimed at promoting use of agricultural material as biomass fuel (since such programs are considered te mporary).

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, pr imarily due to issues with separation of dirt from the root ball in clay or ro cky 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 contr actors, a value of 30 tons biomass fuel per acre was assumed for citrus orchar ds.

In the costs presented in the table above, the Dist rict’s data assumed that the roots, after drying in the field, will be transport ed to a composting operation. The following cost estimates were provided by the ag in dustry for removing root materials: $75 for one ton of roots and $244 for fo ur tons of roots. For orchard removals, District staff estimated the roots to wei gh 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 no t 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 a nd thus can be ignored for the District’s comparative analysis.

Review of Table 6-2 indicates that the prices obtai ned by the District for open burning and grinding for biomass are very similar t o the estimates provided by the ag industry. In addition, since the pricing di fferential between grinding to biomass and open burning shown in Table 6-2 is gene rally greater when based on the quotations obtained by the District rather t han on the information provided by the ag industry, the District’s cost effectivene ss analysis will be performed based only on the quotations obtained by the Distri ct since this will provide the most conservative analysis with respect to industry ’s concerns.San Joaquin Valley Unified Air Pollution Control Di strict 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 Chi pping

Options for chipping and recycle of prunings consis t of:

1. Chipping prunings for conversion to biomass fuel 2. In-row chipping of prunings for on-site land inc orporation

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 operato r 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 Calif ornia 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 ob tain 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 analy sis provided by the farming industry indicated that the in-row chipping operati on 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 wi ll assume that the prices for in-row chipping for land incorporation may vary fro m $30 to $60 per acre.San Joaquin Valley Unified Air Pollution Control Di strict 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 BURN ING

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 f ollowed by conversion to either biomass fuel or land incorporation results i n 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 pe r ton of emission reduction is defined as the cost differential between chipping o r grinding and open burning in dollars per acre divided by the difference between burning and chipping in per acre total emissions (PM 2.5 + NO

x + VOC), or:



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

### )

CE

= 

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

# )

The cost effectiveness calculated by the above expr ession will primarily be a function of the type of tree or plant (which determ ines the difficulty of removal and the amount and fuel quality of the material, af fecting both the denominator and numerator of the above expression) and of the t otal acreage which affects the numerator of the above expression since operati ons on smaller acreages cost more per acre due to the project minimums impo sed by most orchard

contractors.

6.3.2 Emissions Due To Open Burning

Open Burning of Orchard Removals

Emissions of PM 2.5 , NO

x 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 equi pment to the site

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

3. Emissions from a wheel loader used to stack tree s 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 rootsSan Joaquin Valley Unified Air Pollution Control Di strict 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 t he District’s 2008 Area Sources Emission Inventory Methodology (revised 01J un09) for orchard

removals. Values are:

PM 2.5 7.3 lb/ton material burned

NO

x 5.2 lb/ton material burned

VOC 5.2 lb/ton material burned

• Highway vehicle emissions for delivery of equipmen t 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 Ti er 2 diesel engine requiring one hour of operation for 70 tons for mat erial.

• Wheel loader emissions are estimated based on a 25 0 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 PM 2.5 , NO

x 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 equi pment to the site

2. Emissions from a wheel loader used to stack tree s or vines into piles for burning 3. Emissions from open burning of prunings

• Emission factors for open burning are taken from t he District’s 2008 Area Sources Emission Inventory Methodology (revised 01J un09) for orchard

removals. Values are:

PM 2.5 7.3 lb/ton material burned

NO

x 5.2 lb/ton material burned

VOC 5.2 lb/ton material burned

• Highway vehicle emissions for delivery of equipmen t 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 Di strict 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 25 0 hp Tier 2 diesel engine operating at a rate of one hour per acre. 6.3.3 Emissions Due to Grinding and Conversion of M aterial to Biomass

Fuel

Grinding and Conversion of Material from Orchard Re movals to Biomass Fuel

Emissions of PM 2.5 , NO

x 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 equi pment 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 rem ove the trees or

vines

3. Emissions from two wheel loaders used to stack t rees, vines, and roots into piles for burning

4. PM 2.5 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 recei ve and handle the fuel 7. Power plant emissions due to fuel burning

• The PM 2.5 emission factor for grinding (0.05 lb per ton) was based on a review of existing District permits for grinding wo od material and vineyard materials. A review of four existing permits indic ated 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:

PM 2.5 0.86 lb/ton material burned

NO

x 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 fo r every 24 tons of ground material for delivery to the biomass power plant, a nd one (1) 100-mile round trip for every 24 tons of roots for delivery to composting operation.

• Excavator emissions for orchard removal are estima ted based on a 240 hp Tier 1 diesel engine requiring one hour of opera tion per acre.San Joaquin Valley Unified Air Pollution Control Di strict 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 grindin g operation are estimated based on a 250 hp Tier 2 diesel engine op erating at a rate of three hours per acre.

• Tub grinder emissions are estimated based on a 100 0 hp Tier 2 diesel engine operating at a rate of one hour per acre.

• Dozer emissions for receiving and handling materia l 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 receive d.

• Wheel loader emissions required for gathering and loading roots for transport to a composter are estimated based on a 2 50 hp Tier 2 diesel engine operating at a rate of one hour per acre.

Grinding and Conversion of Orchard Prunings to Biom ass Fuel

Emissions of PM 2.5 , NO

x 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 equi pment to the site and deliver ground material to the biomass plant 2. Emissions from one wheel loader used to handle p runings

3. PM 2.5 emissions from grinding of prunings 4. Engine emissions (PM2.5, NOx, and VOC) from the grinder 5. Dozer operation at the biomass facility to recei ve and handle the fuel 6. Power plant emissions due to fuel burning

• The PM 2.5 emission factor for grinding (0.05 lb per ton) was based on a review of existing District permits for grinding wo od material and vineyard materials. A review of four existing permits indic ated 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:

PM 2.5 0.86 lb/ton material burned

NO

x 1.92 lb/ton material burned

VOC 0.38 lb/ton material burnedSan Joaquin Valley Unified Air Pollution Control Di strict 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 w heel loader to the site and one (1) 100-mile round trip for every 24 tons o f ground material for delivery to the biomass power plant.

• Wheel loader emissions associated with the grindin g operation are estimated based on a 250 hp Tier 2 diesel engine op erating 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 materia l 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 receive d.

Chipping of Prunings for Land Incorporation

Emissions of PM 2.5 , NO

x and VOC from grinding and conversion have been estimated by the District based on the following:

• Emissions estimates for chipping of prunings for l and incorporation

include:

1. Highway vehicle emissions to deliver mobile equi pment to the site

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

3. PM 2.5 emissions from grinding of prunings 4. Engine emissions (PM2.5, NOx, and VOC) from the grinder

• The PM 2.5 emission factor for grinding (0.05 lb per ton) was based on a review of existing District permits for grinding wo od material and vineyard materials. A review of four existing permits indic ated 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 chip per 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 a cre.San Joaquin Valley Unified Air Pollution Control Di strict 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 grindin g operation are estimated based on a 250 hp Tier 2 diesel engine op erating 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 ev aluation 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 grindin g versus open burning for citrus orchards. The tables present results for plo t sizes between 1 and 20 acres, with the expected emissions and cost for burning pe r acre, expected emissions and cost for grinding per acre, differential emissi ons and differential cost per

acre. The cost structure shown in the tables refle cts a $5,000 minimum charge required for orchard removals by grinding to biomas s and a minimum charge of $1,150 for orchard removal by open burning. The “p er 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 sma ller acreages, trending to a lower fixed value for larger acreages as would be e xpected. Per acre emissions are also somewhat higher for smaller acreages prima rily due to the emissions associated with mobilization of equipment at the si te.

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

structure similar to Tables 6-4 and 6-5. As with o rchards, per-acre costs and cost effectiveness value is generally higher for sm aller acreages, trending to a lower fixed value for larger acreages.San Joaquin Valley Unified Air Pollution Control District May 20, 2010Revised July 21, 20106-13Chapter 6: Cost Impacts ofAlternatives to BurningFinal Staff Report andRecommendations on Agricultural BurningNOxPM2.5VOCNOxPM2.5VOCNOxPM2.5VOC10.09450.1240 0.1075 $1,150 0.0575 0.0145 0.0065$5,244 0.03700.1095 0.1010 $4,09420.09250.1243 0.1073 $575 0.0503 0.0143 0.0065$2,744 0.04220.1100 0.1008 $2,1693 0.09180.1242 0.1072 $383 0.0480 0.0142 0.0065$1,911 0.04380.1100 0.1007 $1,52740.09150.1241 0.1073 $288 0.0468 0.0141 0.0065$1,494 0.04470.1100 0.1008 $1,20750.09130.1242 0.1072 $267 0.0465 0.0141 0.0065$1,244 0.04480.1101 0.1007$97760.09120.1242 0.1072 $267 0.0460 0.0141 0.0065$1,077 0.04520.1101 0.1007$81070.09110.1241 0.1072 $267 0.0459 0.0141 0.0065$958 0.04520.1100 0.1007$69180.09100.1242 0.1072 $267 0.0456 0.0141 0.0065$869 0.04540.1101 0.1007$60290.09090.1242 0.1072 $267 0.0456 0.0141 0.0065$800 0.04530.1101 0.1007$533100.09090.1242 0.1072 $267 0.0453 0.0141 0.0065$744 0.04560.1101 0.1007$477120.09080.1242 0.1072 $267 0.0450 0.0140 0.0065$661 0.04580.1102 0.1007$394140.09080.1242 0.1072 $267 0.0450 0.0141 0.0065$632 0.04580.1101 0.1007$365150.09080.1242 0.1072 $267 0.0449 0.0141 0.0065$632 0.04590.1101 0.1007$365160.09080.1242 0.1072 $267 0.0448 0.0141 0.0065$632 0.04600.1101 0.1007$365180.09070.1242 0.1072 $267 0.0448 0.0141 0.0065$632 0.04590.1101 0.1007$365200.09070.1242 0.1072 $267 0.0447 0.0141 0.0065$632 0.04600.1101 0.1007$365Basis:30 BDT/acre for other orchard4 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding caseGrind & haul cost includes $244 for root compostingTable 6-4Per Acre Emissions andCosts Using District DataOpen Burning versus Grind and Haul for Orchards other than CitrusCost Basis: Chipper Contractor Quotations Jan 2010OrchardRemovalSizeOpen BurningGrind & HaulDifferenceEmissionsTons per AcreCost$/acreEmissionsTons per AcreCost$/acreEmissions ReductionTons per AcreCost$/acreSan Joaquin Valley Unified Air Pollution Control District May 20, 2010Revised July 21, 20106-14Chapter 6: Cost Impacts ofAlternatives to BurningFinal Staff Report andRecommendations on Agricultural BurningNOxPM2.5VOCNOxPM2.5VOCNOxPM2.5VOC10.0945 0.12400.1075 $1,150 0.0575 0.0145 0.0065 $5,244 0.0370 0.1095 0.1010 $4,09420.0925 0.12430.1073 $575 0.0503 0.0143 0.0065 $2,744 0.0422 0.1100 0.1008 $2,16930.0918 0.12420.1072 $400 0.0480 0.0142 0.0065 $1,911 0.0438 0.1100 0.1007 $1,51140.0915 0.12410.1073 $400 0.0468 0.0141 0.0065 $1,494 0.0447 0.1100 0.1008 $1,09450.0913 0.12420.1072 $400 0.0465 0.0141 0.0065 $1,244 0.0448 0.1101 0.1007$84460.0912 0.12420.1072 $400 0.0460 0.0141 0.0065 $1,077 0.0452 0.1101 0.1007$67770.0911 0.12410.1072 $400 0.0459 0.0141 0.0065 $958 0.0452 0.1100 0.1007$55880.0910 0.12420.1072 $400 0.0456 0.0141 0.0065 $869 0.0454 0.1101 0.1007$46990.0909 0.12420.1072 $400 0.0456 0.0141 0.0065 $800 0.0453 0.1101 0.1007$40010 0.0909 0.12420.1072 $400 0.0453 0.0141 0.0065 $769 0.0456 0.1101 0.1007$36912 0.0908 0.12420.1072 $400 0.0450 0.0140 0.0065 $769 0.0458 0.1102 0.1007$36914 0.0908 0.12420.1072 $400 0.0450 0.0141 0.0065 $769 0.0458 0.1101 0.1007$36915 0.0908 0.12420.1072 $400 0.0449 0.0141 0.0065 $769 0.0459 0.1101 0.1007$36916 0.0908 0.12420.1072 $400 0.0448 0.0141 0.0065 $769 0.0460 0.1101 0.1007$36918 0.0907 0.12420.1072 $400 0.0448 0.0141 0.0065 $769 0.0459 0.1101 0.1007$36920 0.0907 0.12420.1072 $400 0.0447 0.0141 0.0065 $769 0.0460 0.1101 0.1007$369Basis:30 BDT/acre for citrus4 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding caseGrind & haul cost includes $244 for root compostingDifferenceEmissionsTons per AcreOpen BurningCost$/acreTable 6-5Per Acre Emissions and Costs Using District DataOpen Burning versus Grind and Haul for CitrusCost Basis: Chipper Contractor Quotations Jan 2010EmissionsTons per AcreOrchardRemovalSizeCost$/acreGrind & HaulEmissions ReductionTons per AcreCost$/acreSan Joaquin Valley Unified Air Pollution Control District May 20, 2010Revised July 21, 20106-15Chapter 6: Cost Impacts ofAlternatives to BurningFinal Staff Report andRecommendations on Agricultural BurningNOxPM2.5VOCNOxPM2.5VOCNOxPM2.5VOC10.0210 0.0220 0.0190 $1,150 0.03050.0030 0.0020 $5,725 0.0000 0.0190 0.0170$4,57520.0193 0.0220 0.0190 $575 0.02330.0028 0.0018 $3,225 0.0000 0.0192 0.0172$2,65030.0185 0.0220 0.0190 $383 0.02100.0027 0.0017 $2,392 0.0000 0.0193 0.0173$2,00840.0183 0.0220 0.0190 $288 0.01990.0026 0.0016 $1,975 0.0000 0.0194 0.0174$1,68850.0180 0.0220 0.0190 $230 0.01950.0026 0.0016 $1,725 0.0000 0.0194 0.0174$1,49560.0179 0.0220 0.0190 $213 0.01900.0026 0.0016 $1,558 0.0000 0.0194 0.0174$1,34570.0176 0.0219 0.0190 $213 0.01860.0026 0.0016 $1,439 0.0000 0.0193 0.0174$1,22680.0178 0.0219 0.0189 $213 0.01830.0026 0.0016 $1,350 0.0000 0.0193 0.0173$1,13790.0177 0.0219 0.0189 $213 0.01810.0026 0.0016 $1,281 0.0000 0.0193 0.0173$1,06810 0.0177 0.0220 0.0190 $213 0.01820.0026 0.0016 $1,225 0.0000 0.0194 0.0174$1,01212 0.0176 0.0220 0.0190 $213 0.01780.0026 0.0016 $1,142 0.0000 0.0194 0.0174$92914 0.0175 0.0220 0.0190 $213 0.01760.0026 0.0016 $1,082 0.0000 0.0194 0.0174$86915 0.0175 0.0220 0.0190 $213 0.01760.0026 0.0016 $1,058 0.0000 0.0194 0.0174$84516 0.0175 0.0219 0.0190 $213 0.01760.0026 0.0016 $1,038 0.0000 0.0193 0.0174$82518 0.0175 0.0219 0.0189 $213 0.01750.0026 0.0016 $1,003 0.0000 0.0193 0.0173$79020 0.0175 0.0220 0.0190 $213 0.01750.0026 0.0016$9750.0000 0.0194 0.0174$762* Grind and haul cost includes $650 per acre for removal of wire and stakes$75 per acre for composting rootsBasis5 BDT/acre for Vineyard1 BDT/acre for rootsRoots are burned in burning caseRoots are transported to composting operation for grinding caseGrind & HaulEmissions ReductionTons per AcreCost$/acreDifferenceTable 6-6Per Acre Emissions and Costs Using District DataOpen Burning versus Grind and Haul for Vineyards/KiwisCost Basis: Chipper Contractor Quotations Jan 2010EmissionsTons per AcreOpen BurningCost$/acreEmissionsTons per AcreOrchardRemoval SizeCost*$/acreSan Joaquin Valley Unified Air Pollution Control Di strict 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 fo r conversion to biomass fuel, the

District evaluated the emissions as follows based o n 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

Chipping - lb/acre Tons

per

acre Acres

PM 2.5 NO

x VOC PM 2.5 NO

x VOC PM 2.5 NO

x 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 fo r 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 Incorporatio n

Burn - lbs/acre Chip/Land

Incorporate lb/acre Emission Reduction for Chipping - lb/acre Tons

per

acre Acres

PM 2.5 NO

x VOC PM 2.5 NO

x VOC PM 2.5 NO

x 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 materia ls provides the greatest reduction in emissions relative to open burning. Based on the g reater emission reductions and reliability of cost data, the District will base fu rther 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 est imate and determined the incremental cost of shredding to be $38 per acre.San Joaquin Valley Unified Air Pollution Control Di strict 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 N EW ARB

REGULATIONS ON TRUCKS AND EQUIPMENT

Agricultural representatives note that the costs fo r 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 o r less’ in the 2007 analysis. Agricultural representatives do not believe there h as been any decrease in costs and that the new costs will increase for chippers becau se of the equipment replacements. The additional components of the “Off-Road” rule an d the amount ($26/ton instead of $28/ton) the biomass power plants are now paying fo r 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 operat or and agricultural industry. District staff will reevaluate any significant impact to the industry as necessary.San Joaquin Valley Unified Air Pollution Control Di strict 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.