'Y



# . ' 

### CaliforniaEnvironmental ProtectionAgency 

# I;wplO"s-kcKei StateofCalifornia JamesM Strock,Secreranfor En~~rronrnenral horecnon PeteWilson, Gavemar

I aEPARTMENTOFPESTICIDE REGULATION 2sW.Wells,Drrecror
1020 N Street,Room 100 Sacramento, California 95814-5624

March 31, 1995 

### RECEIVED 

## 'APR 06

## 1995 Air&Toxrcshlsrxi U.S.EPARegion

### 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)1994-1995VOC 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 1994-1995data 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 "Reductionsfrom 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 accountMr. 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 straightforwardmethod 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-evaluationof pesticide products and California'sunique 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-chainhydrocarbons, 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