'Y 

. ' California Environmental Protection Agency 

I;wplO"s-kcKei 

State of California 

James M Strock, Secreran for En~~rronrnenral horecnon Pete Wilson, Gavemar 

I aEPARTMENT OF PESTICIDE REGULATION 

2s W. Wells, Drrecror 

1020 N Street, Room 100 

Sacramento, California 95814-5624 

March 31, 1995 

RECEIVED 

'APR 0 6 1995 

Air & Toxrcs hlsrxi 

U.S. EPA Region 9 

Mr. David P. Howekamp 

U.S. Environmental Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, California 94105 

Dear Mr. 

This is in response to your recent letter requesting technical 

clarification on issues in the pesticide component of the 4." 

California State Implementation Plan (SIP) submitted to the 

U.S. Environmental Protection Agency (U.S. EPA) on 

November 15, 1994. 

You asked whether California intends to establish, in 1996, a 

1990 baseline inventory of volatile organic compound (VOC) 

emissions from agricultural and commercial structural pesticides 

by multiplying California's 1990 (backcasted from 1991) pesticide 

use data by the VOC contents determined during the Department of 

Pesticide Regulation's (DPR) 1994-1995 VOC content data call-in. 

The 1990 baseline will be established by multiplying the 

backcasted 1990 pesticide use data by the emission factors. 

Emission factors will include the VOC contents data from the 

1994-1995 data call-in, but could also include factors based on 

data submitted documenting, for example, specific application 

techniques of specific pesticides that lower VOC emissions. 

You also asked whether the table entitled "Reductions from 1990 

Baseline1' in your letter correctly reflects DPR's commitment to 

limiting VOC emissions from pesticides by specific percentages of 

the 1990 base year emissions and by specific years in specific 

nonattainment areas regardless of future growth in emissions that 

might otherwise occur. As described in the program, DPR1s 

commitment to reduce pesticidal VOC emissions takes into account 
Mr. David P. Howekamp 

March 31, 1995 

Page 2 

any growth in emissions. Therefore, the proposed 20 percent 

reduction goal could be considered to be greater than 20 percent 

if one includes growth in pesticidal VOC emissions. We believe 

our program would be hampered by inclusion of inaccurate growth 

estimates. The straightforward method of reducing pesticidal VOC 

emissions from the 1990 emission inventory provides a clearly 

established goal. 

Your third question was to confirm whether California has 

committed to implement any regulations needed to achieve these 

emission reductions by December 1998 and to adopt the necessary 

regulations by a specific month prior to the implementation date. 

DPR commits to adopt enforceable regulations by 1998 if 

evaluation of the pesticide VOC reduction program described in 

the SIP is not achieving the targeted 20 percent pesticidal VOC 

reduction. I must point out that the pesticide VOC reduction 

program already contains essential enforceable regulations. a 

Specifically, the authority to conduct the re-evaluation of 

pesticide products and California's unique full use reporting for 

C 

pesticides provide the underpinning for the program. DPR will 

base its decision to adopt additional regulations upon a review 

of the VOC inventories and an evaluation of the response to 

voluntary reduction efforts. During 1997, DPR will consult with 

U.S. EPA, the agricultural and structural pest control 

industries, county agricultural commissioners, UC Cooperative 

Extension, and other interested parties. 

Finally, you asked whether California assumes emissions from 

adjuvants are negligible, and if so, what is the basis for that 

assumption. As you know, U.S. EPA does not regulate adjuvants. 

Although California registers adjuvants, all adjuvant use is not 

tracked in the Pesticide Use Report and is not tracked or 

estimated by the Air Resources Board or the air districts, so 

they are not part of the inventory. Since adjuvants are used at 

relatively low rates and tend to be long-chain hydrocarbons, 

their contribution as a source of VOCs is probably very low. In 

addition, since adjuvants are not used without pesticides, 

reducing pesticide VOC emissions would also result in 

commensurate reductions in adjuvant use. 
Mr. David P. Howekamp 

March 31, 1995 

Page 3 

If you have any questions or if we can provide additional 

information, please call me. 

Sincerely, 

James W. Wells 

Director 

(916) 445-4000 

cc: Mr. James D. Boyd, Executive Officer, Air Resources Board