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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

2012 Update: Recommendations on Agricultural Burning 

May 2012 

I. EXECUTIVE SUMMARY 

Historically, the practice for disposing of agricultural materials is through the open 

burning of the materials in the field. Burning agricultural materials provided an 

economically feasible method for the timely disposal of these materials, helped 

prevent the spread of plant diseases, and controlled weeds and pests. The air 

quality impact that emissions from open burning could have in the San Joaquin 

Valley Air Basin has long been a concern, and the District, ARB and Valley farmers 

have implemented a number of measures to minimize that impact.

In 2003, California Senate Bill (SB) 705 (California 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 economic impediments. The San 

Joaquin Valley Air District (District) has implemented SB 705 through Rule 4103 (Open 

Burning) and the District’s smoke management program and have reduced the total 

acreage of agricultural materials burned in the Valley by 80%. In 2010, the District 

prepared the 2010 Final Staff Report and Recommendations on Agricultural Burning 

(2010 Report) which evaluated each crop category identified in H&SC Section 41855.5 

and provided recommendations for allowing or prohibiting the open burning of 

categories as outlined by the senate bill. Based upon the 2010 Report, the California 

Air Resources Board (ARB) provided a two year concurrence on the District’s 

recommended postponements, based on the lack of feasible 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 accepted at biomass facilities continues 

to fluctuate based on market conditions and, in fact, at least one biomass facility has 

ceased operation since 2010. There are currently no 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 with vineyard removals and 

citrus continue to be a concern. However, it is economically feasible for the 

largest citrus growers to send removal matter to biomass 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, and there has not been a 

significant change in the availability of chipping contractors, making chipping 

economically infeasible for some nut growers. 
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• Chipping is not a viable option for pome fruits due to susceptibility to bacteria. 

• Raisin trays are no longer being accepted by recycling firms, and biomass 

facilities will not accept the trays due to polymers in the trays. 

• Burning alternatives for rice stubble are also affected by fluctuations in market 

demand for rice stubble (making material removal infeasible) 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 postponements. The District carefully 

manages any remaining agricultural burning with its Smoke Management System and 

continues to consider the economic feasibility of burning 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 maintenance, and prohibit open burning for 

numerous crop categories. SB 705 authorizes the District to postpone the burn 

prohibition dates for specific types of agricultural 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 Standards (NAAQS); and 

(3) There is no long-term federal or state funding commitment for the continued 

operation of biomass facilities in the Valley or the development of alternatives to 

burning. 

In the 2010 Report, the District fulfilled state law requirements and evaluated each crop 

category identified in H&SC Section 41855.5, providing recommendations for allowing 

or prohibiting the open burning of categories. While 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 disposing of agricultural materials without 

burning. The H&SC thus allows the District to determine the details and timing of the 

prohibitions. The 2010 Report documented the District’s recommended determinations 

for specified crops and materials, particularly those that did not have any technologically 

or economically feasible alternatives to open burning. 

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

The District amended Rule 4103 in April 2010 to incorporate H&SC requirements and 

require the District to review its determinations for any postponed crops and materials at 

least once every five years. This process would protect public health without adverse 
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impacts to the economic viability of growing these crops in the San Joaquin Valley 

(Valley). 

In the 2010 Report, the District determined that the continued conditional issuance of 

burn permits for the crop categories specified in Table 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. The District’s 2010 Report demonstrated 

that there were no economically feasible alternatives 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, beans, 

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 grape 

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 beehives 
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C. ARB’s concurrence of the District’s determinations 

On May 27, 2010, ARB provided a two year concurrence with the District’s extension of 

the burning prohibition date for specific crop categories. 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, California Energy Commission, and 

California Department of Food and Agriculture to obtain incentive funding to increase 

utilization of agricultural materials at biomass facilities. Additionally, ARB recommended 

working with the District and Valley biomass waste-to-energy facilities to develop permit 

conditions that will provide more certainty regarding the use of agricultural materials. 

Finally, ARB staff’s evaluation shows that due to the daily limitations on agricultural 

burning resulting from implementation of the District’s Smoke Management System, as 

well as the significant decline in the overall amount 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 on progress made to obtain 

incentive funding and any other new information. ARB will provide and extension of the 

concurrence if the statutory criteria continue to be met. 

D. EPA approval of Rule 4103 

The U.S. Environmental Protection Agency (EPA) finalized 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 economic and technological feasibility of 

alternatives to open burning. EPA recommended reevaluating the feasibility of sending 

citrus orchard removals to biomass facilities and the availability of contractors to shred 

nut prunings. The economic and technological feasibility of these alternatives will be 

reevaluated in this report. 

III. THE DISTRICT’S SMOKE MANAGEMENT SYSTEM 

The use of agricultural burning has sharply decreased in the San Joaquin Valley. The 

District uses a Smoke Management System (SMS) to manage 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 allowed without resulting in ambient air 

pollutant concentrations that exceed federal health-based standards. The SMS 

analyzes 103 zones in the Valley and allocates daily burning allowances in each zone 

based on local meteorology, the air quality conditions, the atmospheric holding 

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

impacts on downwind populations. This approach allows the District to better distribute 
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air pollutant emissions from open burning temporally and spatially, providing flexibility 

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

Properly managed burning allocations under the existing District SMS ensures that air 

quality and health impacts of open burning of agricultural materials, prescribed burning, 

and hazard reduction burning are minimized to the fullest extent feasible. Under the 

SMS, combustion emissions are limited to levels below 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 substantially contribute to a violation of 

an applicable federal ambient air quality standard. 

The implementation of the District’s SMS and the use of sustainable agricultural 

practices have significantly reduced the amount of materials being burned. Since June 

2010, PM2.5 emissions from open burning have been further reduced by 46%. Overall, 

since 2002, the San Joaquin Valley has seen emissions 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 Emissions 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 open burning to further reduce emissions 

in the Valley. 
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IV. CURRENT ECONOMIC FEASIBILITY OF ALTERNATIVES TO OPEN 

BURNING 

A. Biomass 

Agricultural materials remaining from the pruning or the removal of orchards and 

vineyards can be ground or chipped, and then converted into to biomass fuel or land 

incorporation. Biomass burning allows for more complete 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 industry thus reduces pollutants 

created by open burning and landfilling of potential biofuels such as agricultural, urban, 

and forest wood materials.

1. Fuel Use and Storage Capacities 

There are currently fourteen biomass power plants in the Valley, with one additional 

plant under construction, two Authority to Construct applications under review, and one 

recently cancelled application. The fourteen operating 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 Construct application under review is proposing 

to commit to utilizing agricultural biomass that could still be open burned for at least 

6.4% of its fuel. 

Biomass facilities generally accept agricultural materials, 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 materials from building demolition projects 

than agricultural materials, because these urban sources can afford to pay significantly 

more for material disposal. 

The average annual percentage of agricultural material burned at the biomass plants 

from the plants that reported the total bone dry tons (BDT) and agricultural material BDT 

in their quarterly reports is shown in Table 2 below. 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 Material Burned 

Year Ave % Ag Material

2008 25% 

2009 43% 

2010 53% 

2011 44% 
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The combined storage capacity for the biomass facilities in the Valley at the time this 

report is approximately 310 acres. The available storage capacity at any given facility at 

any given time can vary due to multiple factors. Due to the variability of tons/acre 

storage capacity, it would be difficult to calculate that amount of material that the 

biomass plants could actually store of the remaining crop types. Some of the larger 

orchard removal contractors also have storage capabilities, but as this is dependent on 

which contractors are used each time; this potential storage has not been factored into 

the totals below in Table 3. 

Table 3: Fuel Storage Capacity for Biomass Plants That 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 its permit to operate remains valid. 

Historically, there have been occasions when biomass plants have turned away 

agricultural materials. During the fall of 2007, several biomass power plants in the 

District had to temporarily shut down plant operations due to equipment failures or 

maintenance purposes. In addition, some biomass power 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 when the biomass power plant 
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operators must turn away agricultural materials. This inability to guarantee that a facility 

can accept agricultural biomass at all times creates uncertainty in the ability of the 

biomass plants to accept increased amounts of agricultural fuel that would be generated 

by a complete prohibition of open burning. 

Another important factor is the recent economic downturn in the construction industry. 

As the construction industry recovers in the future, biomass plants are more likely to 

accept construction wood materials over agricultural materials to burn. Biomass 

facilities are thus unable to acceptance agricultural 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 District were to completely prohibit open 

burning. In general, due to the fluctuating circumstances described, biomass plants 

have been unwilling to commit to accepting higher levels of agricultural biomass through 

conditions on their operating permits. 

2. Availability of long-term federal or state funding commitments 

Monetary incentives have been provided to increase use of biomass. Funding or tax 

credits are or have been available through some short-term programs such as the 

Existing Renewable Facilities Program through the California Energy Commission 

(CEC) and federal corporate tax credits from a short-term federal program called the 

Renewable Electricity Program Tax Credit. In addition, as part of ARB’s and CEC’s 

landmark programs to decrease greenhouse gas emissions, incentives and funding are 

currently available to identify and promote alternative biomass-based feedstocks, 

including agricultural materials, for the production of alternative fuels. Some federal 

programs provide funding opportunities to promote the development of advanced, next 

generation energy technologies and fuels from biomass resources. 

However, these monetary incentive programs are short-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 limited period. Therefore, there are currently 

no long-term federal or state funding commitments for the operation of biomass facilities 

or development of alternatives to burning. 

B. Specific Crop Categories 

1. Vineyard Removal Materials from Grape and Kiwi Crops 

Biomass power plant operators have indicated that they may accept vineyard materials. 

However, grape and kiwi vine cultivation requires use 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 remaining 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 wires need to be removed. Wire 

removal requires intensive manual labor, adding significant potential cost to vineyard 

growers. Many chipping operators refuse to process these materials because of the 
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wires. In addition, due to the limited number of chipping contractors operating in the 

Valley, service may not be available according to the vineyard grower’s schedule, which 

can cause delays in planting for the following season. 

There has been no significant change to the economic feasibility of chipping and hauling 

vineyard removals since the 2010 Report. Additionally, there has been no change in 

the availability of chipping operators. There is currently 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 from 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 alternative 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 would be willing to take the material 

would charge a higher fee. For these reasons, 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 District’s smoke management system. This category will 

be reevaluated in the next evaluation under Rule 4103, when more economic and other 

data is available. 

2. Citrus Crops Orchard Removal Matter 

Similar to vineyard removals, the chipping of citrus orchard removals with subsequent 

transport and processing at biomass power plants is considered the most 

technologically and viable alternative to open burning. The adobe soil in which citrus 

crops are usually grown is extremely difficult to remove from the extensive root system 

of citrus trees. Separating the roots from the trunk prior to chipping, as well as 

screening the chipped root material to remove excessive clumps all increase the costs 

associated with chipping citrus material. In addition, ground citrus wood produces 

stringy material. It takes about six to eight weeks 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 completely 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 addition 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 adding 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 along with the additional processing and 
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costs that are required to make the citrus chips acceptable 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 program, open burning of citrus orchard 

removals is dependent on a case-by-case analysis which determines if there is 

sufficient biomass plant capacity and availability of economically feasible chipping 

services. However, District staff has determined that it is economically feasible for the 

largest citrus growers (>3,500 acres) to send removal matter to biomass plants, as 

described in the June 27, 2011 letter to EPA (attached). This determination was based 

primarily on the ability of large growers to provide 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 removals 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 time, due to the lack of future 

commitments to biomass plant operation. For these reasons, 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 District’s smoke management 

system. This category will be reevaluated in the next 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, either 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 currently shredding the prunings and 

leaving the materials on the orchard floor. The ability to shred the materials varies 

among growers of different size farms and regions, with commercial shredders 

potentially being infeasible due to either excessive cost or unavailability. Additionally, 

there are also concerns for this practice, including preventing the pruning material from 

interfering with the harvesting of the crop and potential build-up of chipped material on 

the ground. This situation can then cause the chipped material to be picked up during 

harvest. Although tilling could be done to bury the chipped material to promote faster 

decomposition, growers try to minimize the number of tractor passes in their orchards. 

Leaving chipped material on the ground has cause issues during harvesting; therefore, 

many growers have mostly relied on removing the pruning material from the field and 

open burning the pruning material. Due to harvesting and pruning practices, there is a 
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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 application received. Since the 2010 

determinations, there have been 53 applications to obtain approval to burn. There were 

21 approved applications, meaning the price to implement an alternative was 

economically infeasible. Seven applications were denied due to the cost of the 

alternative provided determined to be economically feasible. The remaining 25 

applications were withdrawn due to a variety of reasons. 

Table 4: Number of Burn Applications for Surface Harvested Prunings 

Applications

Approved 21 

Denied 7 

Withdrawn 25 

Total 53

For growers that shred the pruning material as an alternative method to open burning, 

the practice varies depending on the availability of 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 grower’s permit requests, there has 

not been a significant change in the number of chipping contractors available, and the 

option of shredding is still potentially economically infeasible for some growers. District 

staff concludes that there is no change to the determination made in the 2010 report to 

continue to allow this category to be open burned through the District’s smoke 

management system. This category will be reevaluated in the next evaluation under 

Rule 4103, when more economic and other data is available. 

 

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 potential 
12 

opportunity for transfer and infection of nearby orchards. Fire blight is prevalent in the 

Valley and is a difficult disease to control. Burning 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 this 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 be absorbed in the raisin tray. The 

grapes remain on the raisin trays until they meet the appropriate moisture content. In 

the past, growers used recycling firms to dispose of 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 trays 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 addition, due to the polymer, biomass 

facilities will not accept raisin trays. 

Through its Technology Advancement Program, the District is currently funding a 

project which will test a prototype device to reduce 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 currently no feasible alternatives to burning 

raisin trays, and the District continues to recommend 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. Reducing the amount of post-harvest 

straw residue in the rice fields is important to the successful production of the next crop. 

Burning has been the historical cultural practice for 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 growers 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 post-harvest as needed. Most rice 

growers in the Valley also do not have access to water wells for their rice fields. 

Therefore, rice growers in the Valley do not typically 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 stubble per year. This option works well 

when the there was a market for the baled rice straw, but has not consistently provided 
13 

an economically feasible option for rice growers. Due to the fluctuation in market 

demand for rice stubble, which impacts growers ability to effectively remove the 

material, and issues with water allocation, District 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 of 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 open burned through the District’s smoke 

management system. This category will be reevaluated in the next evaluation under 

Rule 4103, when more economic and other data is available. 

 
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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 Plan, 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 California State Implementation Plan, 

San Joaquin Valley Unified Air Pollution Control District, 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.