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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

2012 Update: Recommendations on Agricultural Burnin g

May 2012

I. EXECUTIVE SUMMARY



### Historically, the practice for disposing of agricul tural materials is through the open burning of the materials in the field. Burning agri cultural materials provided an economically feasible method for the timely disposa l of these materials, helped prevent the spread of plant diseases, and controlle d weeds and pests. The air quality impact that emissions from open burning cou ld have in the San Joaquin Valley Air Basin has long been a concern, and the D istrict, ARB and Valley farmers have implemented a number of measures to minimize t hat impact.

In 2003, California Senate Bill (SB) 705 (Californi a Health and Safety Code Section (H&SC) 41855.5 and 41855.6) established a schedule for specific types of agricultural material to no longer be openly burned in the field , but provided for a postponement of the phase-out where justified by technical and econ omic impediments. The San Joaquin Valley Air District (District) has implemen ted SB 705 through Rule 4103 (Open Burning) and the District’s smoke management progra m and have reduced the total acreage of agricultural materials burned in the Val ley by 80%. In 2010, the District prepared the 2010 Final Staff Report and Recommendations on Agri cultural Burning (2010 Report

) which evaluated each crop category identified in H&SC Section 41855.5 and provided recommendations for allowing or prohib iting the open burning of categories as outlined by the senate bill. Based u pon the 2010 Report, the California Air Resources Board (ARB) provided a two year concu rrence on the District’s recommended postponements, based on the lack of fea sible alternatives to open burning.

This 2012 Report shows that in the two years since the 2010 Report, there have been no significant changes in the economic feasibility of various alternatives to agricultural burning. The amount of agricultural materials acce pted at biomass facilities continues to fluctuate based on market conditions and, in fac t, at least one biomass facility has ceased operation since 2010. There are currently n o long-term federal or state funding commitments for the operation of biomass facilities or development of alternatives to burning. In addition:

• The additional processing and costs associated wit h vineyard removals and citrus continue to be a concern. However, it is ec onomically feasible for the largest citrus growers to send removal matter to bi omass plants, so open burning of citrus orchard removals for citrus growers of 3, 500 acres or more will no longer

be allowed.

• NRCS funding for chipping is being discontinued, a nd there has not been a significant change in the availability of chipping contractors, making chipping economically infeasible for some nut growers.2

• Chipping is not a viable option for pome fruits du e to susceptibility to bacteria.

• Raisin trays are no longer being accepted by recyc ling firms, and biomass facilities will not accept the trays due to polymer s in the trays.

• Burning alternatives for rice stubble are also aff ected by fluctuations in market demand for rice stubble (making material removal in feasible) and by limited water allocations (making soil incorporation infeasible).

For these reasons, which are discussed in this 2012 Report, the District requests continued ARB concurrence regarding necessary postp onements. The District carefully manages any remaining agricultural burning with its Smoke Management System and continues to consider the economic feasibility of b urning alternatives on a case-by-case

basis.

II. REGULATORY BACKGROUND

A. State Law Requirements

SB 705 requires the District to limit open burning for diseased crops, establish best management practices for other weeds and maintenanc e, and prohibit open burning for numerous crop categories. SB 705 authorizes the Di strict to postpone the burn prohibition dates for specific types of agricultura l material if the District makes three specific determinations and the ARB concurs:

(1) There are no economically feasible alternatives to open burning that type of material; (2) Open burning of that type of material will not cause or substantially contribute to a violation of National Ambient Air Quality Standar ds (NAAQS); and (3) There is no long-term federal or state funding commitment for the continued operation of biomass facilities in the Valley or th e development of alternatives to burning.

In the 2010 Report, the District fulfilled state la w requirements and evaluated each crop category identified in H&SC Section 41855.5, provid ing recommendations for allowing or prohibiting the open burning of categories. Whi le the H&SC is designed to reduce emissions from agricultural burning, it recognizes that technological and economic factors may limit the availability of options for d isposing of agricultural materials without burning. The H&SC thus allows the District to dete rmine the details and timing of the prohibitions. The 2010 Report documented the Distr ict’s recommended determinations for specified crops and materials, particularly tho se that did not have any technologically or economically feasible alternatives to open burni ng.

B. The District’s Rule 4103 (Open Burning) and 2010 Report

The District amended Rule 4103 in April 2010 to inc orporate H&SC requirements and require the District to review its determinations f or any postponed crops and materials at least once every five years. This process would pr otect public health without adverse3

impacts to the economic viability of growing these crops in the San Joaquin Valley (Valley).

In the 2010 Report, the District determined that th e continued conditional issuance of burn permits for the crop categories specified in T able 1 under the District’s smoke management system would not cause or substantially contribute to a violation of an applicable federal ambient air quality standard. Th e District’s 2010 Report demonstrated that there were no economically feasible alternativ es for these crop categories. In addition, for the purpose of providing alternatives to open burning, the District found that there are no long-term funding commitments for the continued operation of biomass facilities in the Valley.

Table 1 – CH&SC Crop Categories & Burn Prohibition Requirements

Crop Category Burn Permits are no longer be issued for the following: Burn Permits continue to be issued for the following:
Field Crops alfalfa, asparagus, barley stubble, bea ns,

corn, cotton, flower straw, hay, lemon grass, oat stubble, pea vines, peanuts, safflower, sugar cane, vegetable crops, and wheat

stubble rice stubble up to 70% per year of the total acreage of rice farmed by the operator

residual rice stubble, spot burning of rice stubble, and burning of weeds and vegetative materials on rice field levees

and banks Prunings apricot crops, avocado crops, bushberry

crops, cherry crops, Christmas trees, citrus crops, date crops, eucalyptus crops, kiwi crops, nectarine crops, nursery prunings, olive crops, pasture or corral trees, peach crops, persimmon crops, pistachio crops, plum crops, pluot crops, pomegranate crops, prune crops, rose crops, and fig crops apple crops, pear crops, and quince crops

Weed

Abatement berms, fence rows, pasture, grass, and

bermuda grass weed abatement activities affecting ponding and levee banks

Orchard

Removals orchard removal matter of more than 15

acres at a single location, per calendar year, citrus crops > 3,500 acres citrus crops < 3,500 acres, apple crops, pear crops, quince crops, and orchard

removal matter from a total of 15 acres or less of orchard removal at a single location, per calendar year Vineyard

Removals none at this time vineyard removal materials from g rape and kiwi crops

Surface

Harvested Prunings grape canes (defined as "vineyard

materials"), grape vines, and from prunings of almond, walnut, and pecan crops for each agricultural operation whose total nut acreage at all agricultural operation sites is
3,500 acres or more raisin trays (defined as "vineyard materials"), and for up to 20 acres of prunings per year for almond, walnut, and pecan crops for agricultural operations whose total nut acreage at all agricultural operation sites is less than 3,500 acres with a case-by-case allowance of additional burn requests based on economic feasibility

Other

Materials brooder paper and deceased goats diseased beehives4

C. ARB’s concurrence of the District’s determinatio ns

On May 27, 2010, ARB provided a two year concurrenc e with the District’s extension of the burning prohibition date for specific crop cate gories. ARB’s evaluation concurred that there continues to be a number of impediments to fully implementing alternatives to burning for selected crop categories.

ARB recommended working with state legislature, Cal ifornia Energy Commission, and California Department of Food and Agriculture to ob tain incentive funding to increase utilization of agricultural materials at biomass fa cilities. Additionally, ARB recommended working with the District and Valley biomass waste- to-energy facilities to develop permit conditions that will provide more certainty regardi ng the use of agricultural materials. Finally, ARB staff’s evaluation shows that due to t he daily limitations on agricultural burning resulting from implementation of the Distri ct’s Smoke Management System, as well as the significant decline in the overall amou nt of agricultural burning, the remaining burning will not cause or substantially contribute to violations of federal air quality

standards.

ARB will reconsider the concurrence in 2012 based o n progress made to obtain incentive funding and any other new information. AR B will provide and extension of the concurrence if the statutory criteria continue to b e met.

D. EPA approval of Rule 4103

The U.S. Environmental Protection Agency (EPA) fina lized an approval for Rule 4103 on June 4, 2012 (Revisions to the California State Implementation Plan, San Joaquin Valley Unified Air Pollution Control District [Rule 4103], 2012, 214-217). EPA concurred

with the District’s conclusions on the current econ omic and technological feasibility of alternatives to open burning. EPA recommended reev aluating the feasibility of sending

citrus orchard removals to biomass facilities and t he availability of contractors to shred nut prunings. The economic and technological feasi bility of these alternatives will be reevaluated in this report.

III. THE DISTRICT’S SMOKE MANAGEMENT SYSTEM

The use of agricultural burning has sharply decreas ed in the San Joaquin Valley. The District uses a Smoke Management System (SMS) to ma nage the Valley’s remaining open burning of agricultural crops and materials. The SMS uses real-time meteorological information and computer modeling to determine the amount and location of agricultural burning that can be allowe d without resulting in ambient air pollutant concentrations that exceed federal health -based standards. The SMS analyzes 103 zones in the Valley and allocates dail y burning allowances in each zone based on local meteorology, the air quality conditi ons, the atmospheric holding capacity, the amount of burning already approved in a given area, and the potential impacts on downwind populations. This approach allo ws the District to better distribute5

air pollutant emissions from open burning temporall y and spatially, providing flexibility of burn days for growers while minimizing the impac t on the public.

Properly managed burning allocations under the exis ting District SMS ensures that air quality and health impacts of open burning of agric ultural materials, prescribed burning, and hazard reduction burning are minimized to the f ullest extent feasible. Under the SMS, combustion emissions are limited to levels bel ow the violation threshold of any applicable federal ambient air quality standard and burns are not allowed in zones on days when exceedances of the federal standards have occurred in that zone. The

District determined that the continued issuance of burn permits for the crop categories

outlined in Table 1 above would not cause or substa ntially contribute to a violation of an applicable federal ambient air quality standard.

The implementation of the District’s SMS and the us e of sustainable agricultural practices have significantly reduced the amount of materials being burned. Since June 2010, PM2.5 emissions from open burning have been f urther reduced by 46%. Overall, since 2002, the San Joaquin Valley has seen emissio ns from open burning reduced by 81%, or 9.8 tons of PM2.5 per day. Figure 1 shows the gradual reduction in open burning emissions in the Valley since 2002.

Figure 1 – Annual Agricultural Open Burning Emissio ns for PM2.5

While the SMS has been effective at reducing PM2.5 emissions, California state law still requires the District to evaluate alternatives to o pen burning to further reduce emissions in the Valley.6

IV. CURRENT ECONOMIC FEASIBILITY OF ALTERNATIVES TO OPEN

BURNING

A. Biomass

Agricultural materials remaining from the pruning o r the removal of orchards and vineyards can be ground or chipped, and then conver ted into to biomass fuel or land incorporation. Biomass burning allows for more com plete combustion of the fuel and since the equipment is regulated with air pollution controls, biomass burning results in fewer emissions than open burning. The biomass ind ustry thus reduces pollutants created by open burning and landfilling of potentia l biofuels such as agricultural, urban,

and forest wood materials.

1. Fuel Use and Storage Capacities

There are currently fourteen biomass power plants i n the Valley, with one additional plant under construction, two Authority to Construc t applications under review, and one recently cancelled application. The fourteen opera ting facilities each burn between 25 – 1,951 biomass tons per day. Otherwise, the amount of agricultural material to be burned as fuel by these plants fluctuates based on market conditions and is determined by the facility. One facility Authority to Constru ct application under review is proposing to commit to utilizing agricultural biomass that co uld still be open burned for at least

6.4% of its fuel.

Biomass facilities generally accept agricultural ma terials, forestry materials, and urban

wood residues to be used as fuel for their boilers. However, it is often more affordable for the biomass power plants to obtain urban mater ials from building demolition projects than agricultural materials, because these urban so urces can afford to pay significantly more for material disposal.

The average annual percentage of agricultural mater ial burned at the biomass plants from the plants that reported the total bone dry to ns (BDT) and agricultural material BDT in their quarterly reports is shown in Table 2 belo w. The percentage of agricultural material fuel versus non-agricultural material fuel that a biomass power plant accepts is constantly changing. While there is a year to year fluctuation in the amount of agricultural materials to be burned as fuel, there has been a general increase in the amount of agricultural material used as fuel due to the economic recession and overall lack of development-related construction.

Table 2: Average Percentage of Agricultural Materia l Burned

Year Ave % Ag Material

2008 25%

2009 43%

2010 53%

2011 44%7

The combined storage capacity for the biomass facil ities in the Valley at the time this report is approximately 310 acres. The available s torage capacity at any given facility at any given time can vary due to multiple factors. D ue to the variability of tons/acre storage capacity, it would be difficult to calculat e that amount of material that the biomass plants could actually store of the remainin g crop types. Some of the larger orchard removal contractors also have storage capab ilities, but as this is dependent on which contractors are used each time; this potentia l storage has not been factored into

the totals below in Table 3.

Table 3: Fuel Storage Capacity for Biomass Plants T hat Use Ag Materials

Facility Name Region Served Daily Fuel Use (GT) Fuel Storage Capacity (Acres)

Rio Bravo Fresno Central 850 8

Covanta Mendota Central 800 35

Madera Power Central 830 80

Ampersand Chowchilla Central 360 2

Subtotal/Average 2,840 125

Covanta Delano South 1,625 77

Dinuba Energy South 415 20

Sierra Power South 295 4

Rio Bravo Jasmin South 837 0.1

Rio Bravo Poso South 837 0.1

Mount Poso Cogen. South 1400 6

Subtotal/Average 5,409 107

Merced Power* North 360 10

Thermal Energy North 631 28

SPI Sonora North 250 5

Chinese Station North 710 15

SPI Lincoln North 600 20

Air Products North 450 0

Musco Olive Products North 25 0

Subtotal/Average 3,026 78

TOTAL ALL 11,275 310
* Merced Power has recently ceased operation, but i ts permit to operate remains valid.

Historically, there have been occasions when biomas s plants have turned away agricultural materials. During the fall of 2007, s everal biomass power plants in the District had to temporarily shut down plant operati ons due to equipment failures or maintenance purposes. In addition, some biomass po wer plants had to refuse chipping material because storage space was not available. Issues such as lack of storage space and equipment failure can create situations w hen the biomass power plant8

operators must turn away agricultural materials. T his inability to guarantee that a facility can accept agricultural biomass at all times create s uncertainty in the ability of the biomass plants to accept increased amounts of agric ultural fuel that would be generated by a complete prohibition of open burning.

Another important factor is the recent economic dow nturn in the construction industry. As the construction industry recovers in the future , biomass plants are more likely to accept construction wood materials over agricultura l materials to burn. Biomass facilities are thus unable to acceptance agricultur al biomass at all times. This creates uncertainty in the ability of the biomass plants to accept increased amounts of agricultural fuel that would be generated if that D istrict were to completely prohibit open burning. In general, due to the fluctuating circum stances described, biomass plants have been unwilling to commit to accepting higher l evels of agricultural biomass through conditions on their operating permits.

2. Availability of long-term federal or state fundi ng commitments

Monetary incentives have been provided to increase use of biomass. Funding or tax credits are or have been available through some sho rt-term programs such as the Existing Renewable Facilities Program through the C alifornia Energy Commission (CEC) and federal corporate tax credits from a shor t-term federal program called the Renewable Electricity Program Tax Credit. In addit ion, as part of ARB’s and CEC’s landmark programs to decrease greenhouse gas emissi ons, incentives and funding are currently available to identify and promote alterna tive biomass-based feedstocks, including agricultural materials, for the productio n of alternative fuels. Some federal programs provide funding opportunities to promote t he development of advanced, next generation energy technologies and fuels from bioma ss resources.

However, these monetary incentive programs are shor t-term in nature, either because the program sunsets within a few years, funding for the program has to be reappropriated, or funding per project is for a limit ed period. Therefore, there are currently no long-term federal or state funding commitments f or the operation of biomass facilities or development of alternatives to burning.

B. Specific Crop Categories

1. Vineyard Removal Materials from Grape and Kiwi C rops

Biomass power plant operators have indicated that t hey may accept vineyard materials. However, grape and kiwi vine cultivation requires u se of extensive trellis systems to support the vines. The support system consists of wires and may include wood or metal posts and stakes. In many instances, grape canes r emaining after pruning get wrapped around the wires to provide the needed support. As vines mature and age, trellis wires become deeply embedded into the canes or cordons. To avoid mechanical damage to chippers and biomass power plants, the embedded wir es need to be removed. Wire removal requires intensive manual labor, adding sig nificant potential cost to vineyard growers. Many chipping operators refuse to process these materials because of the9

wires. In addition, due to the limited number of c hipping contractors operating in the Valley, service may not be available according to t he vineyard grower’s schedule, which can cause delays in planting for the following seas on.

There has been no significant change to the economi c feasibility of chipping and hauling vineyard removals since the 2010 Report. Additiona lly, there has been no change in the availability of chipping operators. There is c urrently no economically feasible

alternative to remove the wire that is embedded in the cordon and canes to prevent damage to the chipping equipment or prevent wires f rom going to the biomass plants. Wire removal adds a significant cost to the growers . Increasing the amount of materials going into landfills is not considered a viable alt ernative as landfills are required to divert wood and green materials. Most chipping operators are not willing to chip and haul away the vineyard removal materials. Those who wou ld be willing to take the material would charge a higher fee. For these reasons, Dist rict staff concludes that there is no change to the determinations made in the 2010 repor t to continue to allow this category to be open burned through the District’s smoke mana gement system. This category will

be reevaluated in the next evaluation under Rule 41 03, when more economic and other

data is available.

2. Citrus Crops Orchard Removal Matter

Similar to vineyard removals, the chipping of citru s orchard removals with subsequent transport and processing at biomass power plants is considered the most technologically and viable alternative to open burn ing. The adobe soil in which citrus crops are usually grown is extremely difficult to r emove from the extensive root system of citrus trees. Separating the roots from the tru nk prior to chipping, as well as screening the chipped root material to remove exces sive clumps all increase the costs associated with chipping citrus material. In addit ion, ground citrus wood produces stringy material. It takes about six to eight week s of drying time for a typical non-citrus orchard, whereas citrus typically takes longer. As a result, biomass facilities which do accept citrus chips will blend 25% to 30% of citrus material with other crops to promote better flow of the material through the equipment. There is significant concern whether sufficient biomass capacity exists to handle all of the orchard removal material generated in the Valley if open burning was complet ely prohibited for that category.

a. Biomass Capacity

While there have been some new facilities and a few facilities that started burning biomass, in addition to other fuels, there has not been a significant increase in biomass fuel consumption or storage capacity from the addit ion of these facilities. One newly added facility has indicated it will primarily burn olive pits from its own olive processing operation. Another application for a facility addi ng the option to burn biomass has indicated biomass fuel is expected to be nut shells and fruit pits, which are not normally open burned.

Concerns raised by stakeholders in the 2010 Report remain valid. One concern is the whether or not biomass plants will accept citrus al ong with the additional processing and10

costs that are required to make the citrus chips ac ceptable as fuel. Another concern is whether biomass operators will take citrus once the economy improves and construction

material is more abundant as described above.

b. Large Citrus Farms

Under the District’s agricultural burn permit progr am, open burning of citrus orchard removals is dependent on a case-by-case analysis wh ich determines if there is sufficient biomass plant capacity and availability of economically feasible chipping services. However, District staff has determined t hat it is economically feasible for the largest citrus growers (>3,500 acres) to send remov al matter to biomass plants, as described in the June 27, 2011 letter to EPA (attac hed). This determination was based primarily on the ability of large growers to provid e a steady demand for chippers, the availability of chipping equipment for these large growers, and the currently reduced supply of urban wood materials as fuel for biomass plants at this time. Therefore, open burning of citrus orchard removals for large citrus growers (>3,500 acres) will no longer

be allowed.

With regard to other sizes of citrus growers, there has been no significant change to the economic feasibility of chipping and hauling remova ls since the 2010 Report. There is also still uncertainty in whether all of the citrus materials, if burning was prohibited, could be accepted at biomass power plants at this t ime, due to the lack of future commitments to biomass plant operation. For these r easons, District staff concludes that there is no change to the determinations made in the 2010 report to continue to allow this category to be open burned through the D istrict’s smoke management system. This category will be reevaluated in the n ext evaluation under Rule 4103, when

more economic and other data is available.

3. Surface Harvested Prunings from Almond, Walnut, and Pecan Crops

Nut trees are usually pruned after harvesting, eith er late or early in the year. In the past, growers generally open burned nut prunings to dispose of the material. However, many growers have found alternative ways to convert prunings into something useful, such as soil amendment. Many nuts growers are curr ently shredding the prunings and leaving the materials on the orchard floor. The ab ility to shred the materials varies among growers of different size farms and regions, with commercial shredders potentially being infeasible due to either excessiv e cost or unavailability. Additionally, there are also concerns for this practice, includin g preventing the pruning material from interfering with the harvesting of the crop and pot ential build-up of chipped material on the ground. This situation can then cause the chip ped material to be picked up during harvest. Although tilling could be done to bury th e chipped material to promote faster decomposition, growers try to minimize the number o f tractor passes in their orchards. Leaving chipped material on the ground has cause is sues during harvesting; therefore, many growers have mostly relied on removing the pru ning material from the field and open burning the pruning material. Due to harvesti ng and pruning practices, there is a11

short window of opportunity to have these types of prunings chipped. Some growers usually find it more conducive to their operations to gather the prunings and burn them.

a. Economic Feasibility of Alternatives

The economic feasibility of using an alternative to open burning surface harvested prunings is evaluated for every burn permit applica tion received. Since the 2010 determinations, there have been 53 applications to obtain approval to burn. There were 21 approved applications, meaning the price to impl ement an alternative was economically infeasible. Seven applications were d enied due to the cost of the alternative provided determined to be economically feasible. The remaining 25 applications were withdrawn due to a variety of rea sons.

Table 4: Number of Burn Applications for Surface Ha rvested Prunings

Applications
Approved 21

Denied 7

Withdrawn 25

Total 53

For growers that shred the pruning material as an a lternative method to open burning, the practice varies depending on the availability o f the custom shredder or the equipment and chipping contractors. Over the past ten years, the Natural Resources Conservation Service (NRCS) has encouraged growers to chip or shred the prunings from almond and walnut orchards by providing a cost -share basis through the Environmental Quality Incentives Program. In 2011, NRCS contracted for about 114 acres of surface harvested prunings to be chipped. According to recent conversations with NRCS staff, the program will not be continued into 2012.

Based on the case-by-case evaluations of specific g rower’s permit requests, there has not been a significant change in the number of chip ping contractors available, and the option of shredding is still potentially economical ly infeasible for some growers. District staff concludes that there is no change to the dete rmination made in the 2010 report to continue to allow this category to be open burned t hrough the District’s smoke management system. This category will be reevaluat ed in the next evaluation under Rule 4103, when more economic and other data is ava ilable.

4. Other categories

a. Pome Fruit

Pome fruits include apple, pear, and quince crops. The primary concern for pome fruits is their susceptibility to fire blight, a bacterial disease that kills blossoms, shoots, limbs, and potentially the entire tree. Chipping/grinding and composting create a potential12

opportunity for transfer and infection of nearby or chards. Fire blight is prevalent in the Valley and is a difficult disease to control. Burn ing of infected material is a preventive measure used by growers to help ensure the disease does not spread. In light of the disease issue, the District concludes that there is no feasible alternative to burning pome fruit prunings or orchard removal matter at th is time.

b. Raisin Trays

Raisin trays are paper trays used to dry the grapes on the ground. These trays contain polymer so that the moisture on the ground cannot b e absorbed in the raisin tray. The grapes remain on the raisin trays until they meet t he appropriate moisture content. In the past, growers used recycling firms to dispose o f the trays. These recycling firms shipped the trays to China for reuse. However, due to the declining value of the U.S. dollar, China has cut off the import of raisin tray s and this alternative is no longer broadly viable. Since the polymer does not degrade quickly, soil incorporation is not a feasible alternative to burning raisin trays. In ad dition, due to the polymer, biomass facilities will not accept raisin trays.

Through its Technology Advancement Program, the Dis trict is currently funding a project which will test a prototype device to reduc e emissions from the burning of raisin trays. While this project, as well as many others, are in the process of developing alternatives to reduce emissions, it is still under evaluation and not commercially available. Therefore, at this time there are curre ntly no feasible alternatives to burning raisin trays, and the District continues to recomme nd postponement of this burn prohibition until further information on potential alternatives are available.

c. Rice Stubble

Rice is planted in the spring and harvested in the fall. Once the rice is harvested, the rice straw remains in the field for disposition. R educing the amount of post-harvest straw residue in the rice fields is important to th e successful production of the next crop. Burning has been the historical cultural practice f or removing straw and residues for the rice industry.

Another potential alternative is soil incorporation , but this requires water to be delivered to the operations post-harvest season. Most rice g rowers in the Valley are in the northern region and, due to the annual distribution schedules designated by irrigation districts, water is not available to be delivered p ost-harvest as needed. Most rice growers in the Valley also do not have access to wa ter wells for their rice fields. Therefore, rice growers in the Valley do not typica lly rely on soil incorporation as a feasible option to dispose of their rice straw.

In 2007, District staff believed that rice growers could sell the rice straw to baling operators who would then sell it to their customers such as dairies. Therefore, the District prohibited open burning for 30% of rice st ubble per year. This option works well

when the there was a market for the baled rice stra w, but has not consistently provided13

an economically feasible option for rice growers. Due to the fluctuation in market demand for rice stubble, which impacts growers abil ity to effectively remove the material, and issues with water allocation, Distric t staff recommended that open burning

of rice stubble be allowed to continue for burns at 70% per year of the total acreage of rice farmed by the operator after June 1, 2010 and until June 1, 2015. There has been no significant change to the economic feasibility o f baling as an alternative to burning. District staff concludes that there is no change to the determination made in the 2010 report to continue to allow this category to be ope n burned through the District’s smoke management system. This category will be reevaluat ed in the next evaluation under Rule 4103, when more economic and other data is ava ilable.14

V. REFERENCES

San Joaquin Valley Air Pollution Control District [ SJVAPCD]. (2010). Final Staff Report and Recommendations on Agricultural Burning. Fresno, CA.

Revisions to the California State Implementation Pl an, San Joaquin Valley Unified Air Pollution Control District, 77 Fed. Reg. 2, pp. 214 -217. (2012, January 4).

US Environmental Protection Agency [EPA]. (2011). Technical Support Document for EPA’s Notice of Proposed Rulemaking for the Califor nia State Implementation Plan, San Joaquin Valley Unified Air Pollution Control Di strict, Rule 4103, Open Burning

.

California Air Resources Board [ARB]. (2010). Resolution 10-24, Agenda Item: 10-5-2.

P. Velasco, ARB. (2012). Update on Incentive Programs for Agricultural Waste Use at

Biomass Facilities.

T. Strauss, Natural Resources Conservation Service [NRCS]. (2012). Chipping Orchard

Removal Debris - New Contracts.