Revised Proposed Staff Report and Recommendations on Agricultural Burning



## Chapter 3

Technical and Economic Analysis of Affected Crop Categories and RecommendationsRevised Proposed Staff Report and Recommendations on Agricultural Burning This page intentionally blank



## .San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-1 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 

### Chapter 3: Technical and Economic Analysis of Affec ted Crop

Categories and Recommendations

In 2005 and 2007, District staff evaluated several alternatives to open burning for the crop categories identified in the CH&SC. While most of those crops and materials are already subject to the requirements o f Rule 4103 and are prohibited from being burned, there were no technologically or economically feasible alternatives available for some crops and materials at the time. District staff has reviewed the technologically feasible alternatives for each of the affected agricultural crop in the SJVAB. From those alterna tives, District staff has evaluated what appears to be the most viable and li kely method to open burning for many of the affected crops in the SJVAB. Fur ther discussion on emissions and costs for open burning and the alternatives for these crops are presented in the following chapters of this report. This chapte r analyzes the crop categories that are allowed to be burned until June 1, 2010 an d presents the revised proposed recommendations on whether to prohibit or postpone open burning of

those materials after this date.

During the research process, District staff has wor ked closely with the ag industry representatives and other agencies to address the b urn prohibition requirements for various crops. The ag industry representatives have conducted extensive research and effort to provide District staff with key information to help move this project forward. The information used for further analysis include economic data, costs for chipping and burning, descriptions of ope rations, and other related documents. The ag industry has made significant pro gress over the years in reducing emissions from open burning through resear ch, development, and implementation of viable alternative methods. Howe ver, there are concerns for some crops where growers have not been able to iden tify technologically or economically feasible alternatives.

The basis of the economic feasibility analysis is a comparison of compliance costs of the likely non-burning alternative to prof it rates (Return on Sales, or ROS) of the industry sector. To evaluate the econo mic feasibility of burn prohibitions on orchard pruning/removal operations for subject crops, the District engaged their regulatory economic consultant, Appli ed Development Economics, Inc. (ADE). ADE has familiarity with and constant access to comprehensive and applicable profitability and revenue data. Complia nce costs for non-burning disposal alternatives were estimated by District en gineers and ag industry representatives using a variety of data sources and methodologies. The development of compliance cost estimates is present ed in Chapter 6.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-2 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning Profits for subject industry sectors were estimated by ADE by applying published profitability rates for crops to estimated revenues . Profit rates, production, acreage, and prices were taken from the USDA Ag Cen sus 2007, University of California Cooperative Extension, and California Ag ricultural Commissioners’ Annual Report, as well as data compiled commerciall y by Dun and Bradstreet. While the profitability rates used in the analysis below are long-term averages from Dun and Bradstreet, it should be noted that in dustry stakeholders engaged in extensive effort and provided significant input regarding the recent profitability of certain crops. These data are presented in Appe ndix C and confirm the District’s conclusions on the significance of econo mic impacts (i.e., greater or less than 10% of profit) on each crop operation.

The analysis was conducted for each crop/operation (nut orchard prunings, citrus orchard removals, vineyard removals, and removal of other orchards such as stone fruit). The calculations are shown on the ta bles in Appendix E, and the results of the analysis are shown below.

Summary of Results, Economic Feasibility

Crop Operation Farm Scale, Acres Cost/Profit, % Vineyard – Wine Grapes <100 55.2% – 82.0% Vineyard – Wine Grapes ≥ 100 46.9% – 69.6% Vineyard – Raisin & Table Grapes <100 87.0% – 129.2 % Vineyard – Raisin & Table Grapes ≥ 100 73.9% – 109.7% Vineyard – Kiwi <100 11.1% – 16.6% Vineyard – Kiwi Vineyard

Removal

≥ 100 9.5% – 14.1%

Citrus <100 10.9% – 11.9%

Citrus Orchard

Removal ≥ 100 9.4% - 10.3%

Other orchards <100 7.0%

Other orchards Orchard

Removal ≥ 100 5.9%
Almond, Pecan, Walnut <100 10.0%
Almond, Pecan, Walnut Pruning ≥ 100 8.5%San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-3 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.1 VINEYARD REMOVAL MATERIALS

Summary and Recommendation

Table 3-1 Summary of Analysis

Vineyard

Removal

Materials Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Grapes (wine grapes only)

Farms Less

than100 acres Possibly

Biomass No. Wire

Issues. $762 -

$1,132 55.2%-82.0% No

Farms 100

acres or more Possibly

Biomass No. Wire

Issues. $762 -

$1,132 46.9%-69.6% No

Grapes (raisin and table grapes)

Farms Less

than100 acres Possibly

Biomass No. Wire

Issues. $762 -

$1,132 87.0%-129.2% No

Farms 100

acres or more Possibly

Biomass No. Wire

Issues. $762 -

$1,132 73.9%-109.7% No

Kiwi

Farms Less

than100 acres Possibly

Biomass No. Wire

Issues. $762 -

$1,132 11.1%-16.6% No

Farms 100

acres or more Possibly

Biomass No. Wire

Issues. $762 -

$1,132 9.5%-14.1% No

*Biomass power plants can accept vineyard removals given that wires are removed from the

vines.

Recommendation: District staff evaluated biomass power plants as an alternative to open burning of vineyard removal materials and other factors. The economic feasibility analysis is presented in Section E-1 of Appendix E. At this time, District staff recommends that vineyard removal materials continue to be allowed to be open burned based on the following reasons:

• There is currently no economically feasible altern ative to remove

the wire that is embedded in the cordon and canes t o prevent damage to the chipping equipment or prevent the wir es from going to the biomass power plants. Wire removal adds a s ignificant 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 an d haul away the vineyard removal materials or would charge a higher fee.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-4 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning Description and Findings

Vineyards include both grape vines and kiwi vines b ecause both crops require support, such as the trellis systems to help keep t he fruits off the ground. Grape vines are used to produce table grapes, wine grapes or raisin grapes. The cultural practices and the type of trellis system u sed at a vineyard are based on the intended use of the grapes (table, wine, or rai sins) and other factors. In addition to the vine and trellis wire, a vineyard m ay contain cross arms, as well as metal or wooden stakes and posts. Treated stake s (sometimes with metal braces) cannot be chipped and must be taken to a la ndfill. The posts currently being used are predominantly made out of steel. Me tal stakes are removed before chipping and taken to a steel plant. The en d posts can also be made out

of redwood which can be burned.

According to ag representatives, disposal methods f or vineyard removal materials are the same for table, wine and raisins grapes. A grower will generally grow a crop to produce specifically table grapes, w ine grapes or raisin grapes. However, some vineyards provide the grower some fle xibility so that based on several factors, including market prices, a grower can determine well into the production year whether the grape crop will end up as table grapes, wine grapes or raisin grapes.

Depending on the disposal method with the vineyard removal materials, the materials that help support the vine can pose sever al issues for the grower during the removal process. In many cases, most of the foreign material can be removed from the vine. However, there are some sit uations where complete removal of the material, such as wire, can be diffi cult and expensive for the

grower. When too much wire is embedded into the vines, chip pers can refuse to chip the agricultural materials. If the wires were to be chipped along with the wood, the number of power plant operators that will accept such agricultural

materials can be limited.

According to biomass power plant operators, vineyar d removal materials are accepted. The only restriction with vineyard remov al materials is that wire is removed and treated posts are taken out. Substanti al amount of wire in the chipped material can cause problems for the biomass power plant. Other contamination (as long as not excessive) in the mat erial, such as dirt, need to be controlled but is not a major concern to the operat ors since some amount of dirt is expected of all agricultural fuel. It is genera lly not an issue if the chipped

materials are clean.

While growers can hire laborers to remove most of t he wires that connect the vines, it is not practical to remove the wire that is embedded into the cordon or the canes. Ag representatives indicated that the r aisin vineyards are pruned inSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-5 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning such a way that the remaining canes are wrapped aro und the vineyard wire to support the crop. In order to chip the materials f or fuel use at biomass power plants, ag representatives indicated that the wire must be cut more times (compare to open burn) and be removed completely fr om the vineyard or must be present only in very short lengths before it can be chipped. This presents an issue for vineyards where a cordon is created by wr apping the vine around the wire in the second year. As the vine grows, the wi re becomes more and more embedded in the vine, making it impossible to remov e. In some trellis systems, there may be as many as four wires embedded in the cordon. Ag representatives also indicated that chipping operat ors have reported the wire causing problems and getting wrapped around the mov ing parts of their machinery, and that biomass facilities prefer not t o receive material with wire because the wire causes havoc with their equipment.

Ag representatives have also indicated that getting the materials chipped according to the grower’s schedule has been an issu e because it could take weeks or months to have a field chipped, which may be too late to plant for the

next season.

3.2 ORCHARD REMOVAL MATTER FROM CITRUS, APPLE, PEAR

, QUINCE, AND FIG CROPS AND ORCHARD REMOVAL MATTER FR OM

A TOTAL OF 20 ACRES OR LESS

In 2007, ARB concurred with the District’s limited postponement to allow for the burning of orchard removal matter from 20 acres or less and other type of

orchard removals. Rule 4103 defines "Orchard Remov al Matter" as agricultural material generated by the removal of orchards. Thi s includes leaves, branches, trunks, roots, stumps and untreated branch support sticks. The rule prohibits burning of orchard removal material generated as a result of land use conversion from agricultural to nonagricultural purposes.

Since 2002, the Natural Resources Conservation Serv ice (NRCS) has encouraged growers to chip debris left from orchard or vineyard removals by providing a cost-share basis through the Environmen tal Quality Incentives Program (EQIP), which help reduce NOx, VOC, PM10, a nd PM2.5 emissions generated from open burning. The program also incl udes chipping of almond and walnut pruning, which will be discussed in Sect ion 3.7.3 of this chapter. According to NRCS staff, the payment rate has incre ased from $100 per acre to $150 per acre. In order for the growers to replant the field, the chipped orchard removal materials are typically removed from the fa rm to a biomass power plant or a composting facility. The chips could also be deposited on unpaved roads for dust control purposes. Based on NRCS data, the amo unt of chipped materials from the orchard and vineyard removal category aver aged about 270 acres in the SJVAB per year, from 2007 to 2009.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-6 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.2.1 Orchard Removal Matter from a Total of 20 Acr es or Less

Summary and Recommendation

Table 3-2 Summary of Analysis

Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Orchard Removal Matter from 20 Acres or Less Catego ry*

Farms Less

than100 acres Biomass Yes $161 7.0% Yes

Farms 100

acres or more Biomass Yes $161 5.9% Yes

*Reduce Burn allowance to 15 acres per location per year. No case by case determinations for additional acreage.

Recommendation: District staff has completed the review process for the technologically feasible alternatives to open burning of orchard removal mat ter from a total of 20 acres or less. The economic feasibility analysis is present ed in Section E-2 in Appendix E. Biomass power plants appear to be the most tech nologically feasible alternative to open burning of orchard removal matt er; however, due to the limiting factor of increased cost per acre for smal ler acreage and availability of chipping operators, District staff believes that op en burning be allowed to

continue for small orchard removals. District staf f recommends that the current open burning limit be reduced to 15 acres or less o f orchard removal at a single location, per calendar year. District staff also r ecommends that there be no case by case determinations for additional acreage since the cost analysis shows that it becomes more expensive as the acreage becomes sm aller regardless of the

total size of the farm.

In addition chipping operator typically refuses sma ll jobs, making it difficult for many growers to remove small acreages of orchard re movals. The District has increasingly refused most requests for burns that a re over 15 acres. The District’s Compliance Department has indicated that several requests above 15 acres have been denied because the costs to chip an d remove the orchards were determined to be economically feasible.

District staff has found that limiting the acreage amount to 15 acres would be feasible based on the District’s cost analysis to c hip and haul the orchard removal materials to the biomass power plants, wher e the cost per acre appears

to level out at about 15 acres or more. Further in formation on cost analysis can be found in the Costs section of this report. According to the burn applications,San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-7 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning burn permits that were approved for less than 15 ac res make up for most of the burns, over 84%. According to some growers and chi pping operators, the cost per acre could level out to as low as 10 acres for some growers; however, District

staff believes that 15 acres is a reasonable limit based on the cost analysis and considering fluctuations in cost caused by location , fuel costs, and materials, and

other factors.

Description and Findings

Since June 2007, the District has provided limited burning allocation for orchard removal matter from 20 acres or less and has requir ed a case-by-case economic justification of the open burning alternatives from growers before evaluating and determining whether a burn permit may be issued for farms burning less than 20 acres but are greater than 100 cumulative acres. A RB concluded that the postponements will not substantially contribute to the violation of an applicable federal air quality standard, and discussed the imp ortant role of the District’s comprehensive smoke management program in preventin g impacts to nearby communities. However, ARB noted that orchard remov al of 20 acres or less from all other crop types must be implemented narrowly. This category includes all orchard type, except for citrus and pome fruits (ap ples, pears, and quince crops). As recommended above, figs would be considered as p art of this category.

Growers typically need to remove some orchards ever y few years to keep the farm productive. Growers, ag representatives and c hipping operators have expressed several concerns with the chipping of orc hard removal matter from small acreage. Generally, small acreage growers ar e not a priority for chipping operators because of amount of materials generated compared to the time it takes to travel and move the equipment to the field . Biomass power plant operators have indicated that the large chippers ar e doing jobs less than twenty acres with an understanding that the cost of chippi ng has gone up.

Chipping operators also charge a minimum fee (or mo ve-in fee) to the grower. As a result of the minimum charge, the per acre cos t for such small removals increases as the acreage becomes smaller. Based on the District’s cost analysis and information received from ag representatives, t he cost per acre appears to level out at a certain acreage. The fee could vary among chipping operators and is dependent on the availability of chipping contra ctors, storage at biomass power plants, the crop type and density, topography , soil type, and location. Given these considerations and the fact that most g rowers are already chipping the orchard removals above 20 acres, District staff has used a conservative estimate for chipping costs for the analysis.

Ag representatives have indicated that when chippin g operators work on small acreage jobs, growers are often forced to wait unti l the chipping operator plans toSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-8 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning be in the area. This can cause significant delays in fumigation, land preparation, irrigation, and planting. Trees must be ordered a year in advance. When the land is not prepared in time for the trees to be pl anted, these young trees die, at a large cost to the grower.

For farms greater than 100 cumulative acres in the SJVAB, the District has required a case-by-case economic justification of t he open burning alternatives from growers before evaluating and determining whet her a burn permit may be

issued for less than 20 acres. District staff eval uated the economic feasibility of the alternatives based on the applications and copi es of receipts, written bids, or supporting information for the economic justificati on. District staff has found that the case-by-case economic justification varies sign ificantly, from net losses to the cost exceeding the ten-percent (10%) net profit thr eshold. Information provided by growers also supports the higher costs per acre for chipping of orchard removal for smaller acreages, which in the past has shown to be less economically feasible.

From June 2007 to February 2010, the District recei ved a total of 1088 applications for orchard removals of 20 acres or le ss per year. Of those applications, the District issued burn permits for 964 applicants of various farm sizes, including those that are greater than 100 cu mulative acres. However, based on the evaluation of the economic justificati ons, District staff issued burn permits for only 305 applications for farm over 100 cumulative acres. For the approved burn permits, the amount of acres burned r elative to the amount of acres farmed is equivalent to four percent (4%), or about 8,200 acres burned from a total of 196,400 acres. Based on this analy sis, the District has implemented narrowly the provisions for burning orc hard removals of 20 acres or

less.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-9 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.2.2 Fig Crops Orchard Removal Matter

Summary and Recommendation

Table 3-3 Summary of Analysis

*Analysis of fig crop will be considered as part of “Other Fruit Orchards”. Reduce Burn allowance to 15 acres per location per year. No case by case determinations for additional acreage.

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing of fig orchards and recommends that open burning of fig orchard removals be reduced to less than 15 acres at a sing le location, per calendar year after June 1, 2010. The economic feasibility analy sis is presented in Section E-2 of Appendix E. Fig orchard removals would be consi dered as part of the small other orchard removals category. District staff al so recommends that there be no case by case determinations for additional acreage.

Description and Findings

When fig orchards are removed, the trees are typica lly no longer productive and would be replaced with new fig orchards or are no l onger an economical crop and would be replaced with other crops. There are no fire blight issues or other concerns for fig crops. In addition, the orchard m aterials would be acceptable at biomass power plants as an additional fuel source. Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: District

Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS) Fig Crop*

Farms Less

than100 acres Biomass Yes $161 7.0% Yes

Farms 100

acres or more Biomass Yes $161 5.9% YesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-10 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.2.3 Citrus Crops Orchard Removal Matter

Summary and Recommendation

Table 3-4 Summary of Analysis

Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Citrus Crop*

Farms Less

than100 acres Biomass Some
operators $369 10.9%-11.9% No

Farms 100

acres or more Biomass Some
operators $369 9.4%-10.3% No

*Biomass power plants are willing to take citrus cr ops; however, the materials are typically

blended with other materials and are less desirable

.

Recommendation: District staff evaluated the factors currently impa cting citrus crops and the proposed alternative for disposal. The economic fe asibility analysis is presented in Section E-3 in Appendix E. For citrus crops, Di strict staff has considered biomass power plants as the most technologically an d viable alternative to open burning. Based on District staff’s analysis, it is not economically feasible to prohibit open burning for citrus crop. In addition , there appears to be uncertainty

in whether all of the citrus materials could be acc epted at biomass power plants at this time, due to the lack of future commitments to biomass plan operation.

District staff recommends that citrus orchard remov als continue to be allowed to be open burned. As recommended and supported by th e industry, District staff also recommends that growers allow a drying time of between eight to ten weeks for citrus materials as a best management practice before burning.

Description and Findings

The following citrus crops are all grown in the San Joaquin Valley: grapefruits, lemons, oranges (primarily Navels and Valencias), t angerines, and mandarins. According to the County Agricultural Commissioner’s Data for Calendar Year 2008, oranges make up about 82% of the harvested ac reage of citrus crops in the SJVAB. Growers typically remove old citrus orc hards in the year prior to planting. Based on the District’s data, orchard re movals from citrus crops are spread out through the year; however planting usual ly occurs between February and April.

Citrus is often grown in clay-like soil that adhere s to its roots. The extensive lifespan of citrus crops leads to the development o f an extensive root structureSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-11 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning that is difficult to free of soil debris when the r oot is removed. Clay soil, common to citrus orchards, is difficult to remove from the roots. Separating the roots from the trunk and then processing the trunk and the stu mp or root separately for the purpose of multiple uses increase the costs of oper ations, such as chipping and grinding. Furthermore, screening of chipped materi als to remove excessive clay from stumps increases the overall citrus orchard re moval costs to growers. It takes about six to eight weeks of drying time for a typical non-citrus orchard; citrus takes longer to dry. Growers would need to dry the material long enough so that a biomass facility will take the material a nd ration it.

In addition to the concerns noted above, growers, a g representatives and chipping operators have expressed several other con cerns with the chipping of citrus crop orchard removal matter. Key concerns i nclude 1) the reluctance or refusal of some power plants to accept citrus chips , 2) the additional processing and costs that are required to make the citrus chip s acceptable by the power plants, and 3) whether biomass operators will take citrus once the economy improves and they start getting more construction m aterial.

Biomass power plant operators recognize that citrus has been a problem in the past, but feel that this no longer seems to be the case as there have been considerable changes in processing the citrus mater ials. Biomass power plant operators have indicated that mixing citrus chips w ith chips from other crops helps promote better flow of the chips through thei r equipment. In the past, one of the issues was that clay soil could become trapp ed in the rootballs and damage the power plant boiler refractories. The st ringy nature of citrus tree chips could also clog conveyors and material handli ng equipment unless the chips were finely ground. Biomass power plant oper ators have indicated that from 2003 to 2005, the roots seemed to be a problem initially with citrus materials getting into the conveyor systems, but later it was determined that citrus needed a drying process of around six to eight weeks, mayb e shorter in hotter
temperatures.

According to CBEA, all of the facilities have worke d diligently with the orchard

removal contractors to resolve the issues with citr us wood and as a result, higher percentage of citrus material could now be accepted . Biomass power plants continue to fall short of their goals for more citr us orchard materials and a number of plants continue to be extremely short of wood fuel. Many are currently curtailed or operating at reduced loads and are in need of more fuel at this time. The District looks forward to working with the biomass industry to achieve long-term commitments toward the extensive use of agricultura l biomass.

For more information on biomass facilities, please refer to Chapter Eight of this
report.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-12 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.2.4 Apple, Pear, and Quince Orchard Removal Matte r

Summary and Recommendation

Table 3-5 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing of orchard removals for apple crops, pear crops, and quince crops and has determined that there are currently no feasible alternatives that would substitute open burning of these crops. There are two factors for this consideration: 1) biomass operators will not accept treated materials and 2) requiring that these crops transport materials in c losed containers is beyond what is required for other orchard removals and therefor e, costs are expected to be greater. For the second factor, District staff is not aware of any chipping operators that have closed containers for this purp ose. District staff recommends that open burning continue for these crops.

Description and Findings

As mentioned above for prunings from pome fruits, c rops such as apples, pears, and quince are susceptible to fire blight, a bacter iological disease that can spread through insects, wind, and mechanical device s and kills blossoms, shoots, limbs, and sometimes the entire tree. In m ost cases, the on-set of fire blight is unidentifiable and can be spread by conta ct or exposure to other healthy orchard material. For orchard removals, the equipm ents used to cut or remove the tree are also routinely sterilized with antibac terial agents to mitigate exposure to the disease or potential disease.

Similar to pruning, orchard removals from apple, pe ar, and quince crops need to be burned to combat further spread of fire blight w ithin orchards and to prevent potential infection of nearby orchards. As indicated by some operators and county ag commissioners, they are not aware of an e ffective treatment for fire blight. Growers have considered chipping the orcha rd removals and transporting the materials to biomass facilities. However, the primary concern with this alternative is potentially spreading the disease to other orchards during transportation. In addition, biomass operators pre fer clean product and will not Orchard

Removal

Matter Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: District

Percent of

Return on

Sales Industry

Stakeholder

Percent Return

on Sales

Apple, Pear, & Quince Crops None.

Disease

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-13 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning accept treated materials. As a result, burning is the preferred and most viable method used in the SJVAB to dispose of these crops in order to avoid potential exposure of the fire blight to healthy trees.

3.3 WEED ABATEMENT ACTIVITIES AFFECTING SURFACE WAT ERWAYS,

INCLUDING PONDING AND LEVEE BANKS

Summary and Recommendation

Table 3-6 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the weed abatement activities affecting surface waterways, including p onding and levee banks and recommends that open burning be allowed to continue as part of weed abatement activities affecting surface waterways, i ncluding ponding and levee banks. While chemicals and mowing are available fo r weed control in many locations, these alternatives are not viable becaus e of the slopes and remote

locations.

Description and Findings

It is noted in the May 19, 2005 Rule 4103 Final Sta ff Report, that although some weeds and locations lend themselves to Best Managem ent Practices (see Attachment 1 in Rule 4103), there remains a need fo r limited burning of some weeds. As mentioned earlier, this analysis does no t include the category for “other weeds and maintenance”. The CH&SC required the District to establish best management practices in 2005 for the control o f other weeds and maintenance, which includes ditch bank work, canal bank work, dodder weed, star thistle, tumbleweeds, noxious weeds, pesticide sacks, and fertilizer sacks. Since the implementation, landowners and irrigation districts have continued to do their part to reduce burning by seeking alternat ive ways to manage weeds. The best management practices in the rule were deve loped in collaboration with

affected sources and are alternatives that must be considered prior to any open burning. Landowners and operators have also opted for more mechanical and Weed

Abatement

Activities Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Surface Waterways – Ponding and

Levee Banks None.

Mowing

and

Herbicide

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-14 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning chemical control of weeds and only burned at times when conditions, such as remote locations or other requirements, prevent oth er alternative practices.

Since 2005, open burning is no longer allowed for w eed abatement activities from berms, fence rows, pasture, grass and Bermuda grass. However, open burning is currently allowed for weed abatement act ivities affecting surface waterways, including ponding and levee banks. The following materials are not considered to be part of the burn allowance for wee d abatement activities affecting surface waterways, ponding, and levee ban ks: 1) weeds that originate from outside and away from the surface waterways, p onding or levee banks and 2) any other debris or materials that are gathered from surface waterways, ponding, or levee banks, such as tree limbs or fore ign materials.

According to comments and information received from ag representatives and several agencies, there are currently no feasible a lternatives to burning all of the weeds along surface waterways, ponding and levee ba nks. Landowners and operators have considered using hand crews for remo ving weeds but found the alternative to be impractical. Landowners and oper ators typically mow and spray most of the weeds or use flame desiccation, for dir ect heating of residual weed foliage and over growth of weeds to assure the dest ruction of weed seeds. One operator discs specific sites as needed. In many r emote locations along surface waterways, ponding, and levee banks, fire is the on ly option for effective control of weed seeds and for safety of workers.

In addition, ag representatives and agencies have i ndicated that burning weeds is the most effective option to slope the banks to stabilize them and allow the water to flow easily, with less erosion. Rodents, such as gophers, have also been a concern around levees, including some ground squirrels that have bored through entire levees. Standing weeds make it near ly impossible to check the banks for rodents, which can cause ditch breaks or erosions and lead to flooding of surrounding areas. Complete prohibition to open burning in these areas could

also increase additional use of other chemicals for pest control.

The Federal EPA and the State and Regional Water Bo ards continue to push to eliminate the use of chemicals near any waterway. Recognizing these issues, many landowners and operators are controlling the u se of chemicals along surface waterways, ponding, and levee banks due to concerns over runoff of chemicals from land to waterways. Ag representativ es have provided a copy of the California’s Porter-Cologne Water Quality Act o f 1969 and related information from the federal EPA (attached as part of Appendix B), which further explains the water regulations. The California Porter-Cologne W ater Quality Act regulates the discharge of waste into ambient waters, and authori zes Regional Boards to impose requirements on waste dischargers after cons ideration of several factors. Along with other responsibilities, the Regional Boa rds also regulate all pollutantSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-15 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning or nuisance discharges that may affect either surfa ce water or groundwater. One of the purposes of the federal Water Pollution Cont rol Act (or Clean Water Act) is to restore and maintain the chemical, physical, and biological integrity of the nation's waters by preventing point and nonpoint po llution sources.

One operator indicated that the ability to burn occ asionally would reduce the amount of chemical needed. According to the operat or, the area of the banks by the water line make up about 0.2% of the agency’s t otal acreage and only a portion of that is burned annually.

3.4 OTHER MATERIALS

Other materials include brooder paper, deceased goa ts and diseased bee hives.

3.4.1 Brooder Paper

Summary and Recommendation

Table 3-7 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has found that the current and prima ry disposal method for brooder paper is landfilling. District staff considers lan dfills to be a viable alternative to open burning and will recommend that these material s be prohibited from being

burned. The District’s SMS data also shows an insi gnificant amount of emissions from open burning of brooder paper in the SJVAB in the last few years.

Description and Findings

A broad variety of fowl are raised in confined anim al facilities in the SJVAB. Poultry operators use brooder paper to protect thei r young birds during transportation and the first few weeks of life. In general, the paper needs to easily absorb poultry droppings and disintegrate fo r easier disposal. District staff contacted four operators that raise poultry. Three of the operators indicated that they do not burn their brooder paper but put it in a dumpster for delivery to a landfill. A large operator that raises turkeys and chickens indicated that he

doesn't "... believe that burning brooder paper is a common prac tice in Other

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Brooder Paper Landfill Yes N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-16 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning California." District staff also contacted an oper ator that burns the brooder paper used for raising ducks. The operator indicated tha t he has alternatives to burning the brooder paper including composting the brooder paper or taking it to a

landfill.

3.4.2 Deceased Goats

Summary and Recommendation

Table 3-8 Summary of Analysis

*N/A: not applicable

Recommendation:

District staff considers burial to be a viable alte rnative to open burning. District staff does not consider rendering to be a viable al ternative to open burning due to the many issues noted for that technology. District staff recommends that these materials be prohibited from open burning. The Dis trict’s SMS data also shows an insignificant amount of emissions from deceased goats being burned in the SJVAB in the last few years.

Description and Findings

Several published articles have noted that meat goa t production has been gaining in popularity in the United States in recen t years. Some goat operators

confirmed that there is increased demand for their products.

The discussion below on deceased goats differentiat es goats that expire from diseases (diseased) and goats that expire from othe r causes (not diseased).

Deceased goats that were not diseased - Whether goa ts are raised for their milk, their meat or their fur, goats are subject to fatal injury due to accidents, predatory animals, exposure to the elements, and other causes . Operators have experienced several particular issues in the past f ew years with the disposal of goats that have died from causes other than disease s. Issues have included the die off of goats due to high summer temperatures an d the reluctance or refusal of rendering plants to accept goats due to concerns ov er the cost to collect the animals and possible diseases. Two goat operators noted that they did not know of any operators that used open burning to dispose of their goats. Instead, Other

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Deceased

Goats Burial Yes N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-17 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning operators usually bury the goats on their property in as safe a manner as possible.

Deceased goats that were diseased - In the interest of protecting public health, several regulatory agencies have regulations affect ing the handling of diseased animals. Two diseases of particular concern are ma d cow disease and scrapie. Bovine spongiform encephalopathy (BSE), also known as mad cow disease is a fatal disease that causes progressive neurological degeneration in cattle. Scrapie is a fatal, degenerative disease affecting the central nervous system of sheep and goats.

The California Department of Food and Agriculture ( CDFA) regulates on-site carcass disposal in the case of animals suspected o f succumbing to contagious disease. The California Code of Regulations, Calif ornia Food and Agriculture, Division 5, Part 1, Chapter 1, Section 9141 require s that "Any person that has the care or control of any animal that dies from any co ntagious disease shall immediately cremate or bury the animal." Section 9 142 requires that "An animal which has died from any contagious disease shall no t be transported, except to the nearest crematory." And Section 9143 requires that "An animal which has died from any contagious disease shall not be used for the food of any human being, domestic animal, or fowl."

In addition, the Department of Resources Recycling and Recovery (CalRecycle) has prohibitions that impact the disposal of deceas ed goats. Section 17855.2 of California Code of Regulations Title 14, Natural Re sources, Division 7, CIWMB, Chapter 3.1, Compostable Materials Handling Operati ons and Facilities Regulatory Requirements, prohibits the composting o f unprocessed mammalian tissue except for certain specific instances.

In 1997, FDA published a final regulation designed to prevent the spread of BSE through animal feed. The 1997 FDA rule prohibits t he use of most mammalian protein in the manufacture of animal feeds given to ruminant animals, such as cows, sheep, and goats. The regulation also requir es process and control systems to ensure that feed for ruminants do not co ntain the prohibited mammalian tissue. In 2008, FDA published a regulat ion that strengthened the 1997 rule by prohibiting the tissues that have the highest risk for carrying the agent thought to cause BSE in animal feed.

When goats die from unknown causes, some operators will try to discover the cause of death by taking the carcass to a veterinar ian for an examination in an

effort to determine the cause of death.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-18 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.4.3 Diseased Bee Hives

Summary and Recommendation

Table 3-9 Summary of Analysis

*N/A: not applicable

Recommendation: Several key considerations for diseased bee hives a re that the diseases could be dormant in the frames and used equipment, as well a s develop resistance to chemicals used in the sterilization process. The C H&SC specifically identify this crop type as “diseased” bee hives. District staff believes that there are currently no technologically feasible alternatives to open bu rning of diseased bee hives at

this time. District staff recommends that diseased bee hives be allowed to

continue to be burned.

Description and Findings

Bees are a key component in the growing of crops. The importance of bees was noted in an article in the U.S. Department of Agric ulture's science magazine, "Agricultural Research." The author Kevin J. Hacke tt (ARS National Program Leader, Biological Control, Beltsville, Maryland) n oted in the March 2004 issue of Agricultural Research magazine that "The value of h oney bee pollination to U.S. agriculture is more than $14 billion annually, acco rding to a Cornell University study. Crops from nuts to vegetables and as divers e as alfalfa, apple, cantaloupe, cranberry, pumpkin, and sunflower all r equire pollinating by honey bees. For fruit and nut crops, pollination can be a grower's only real chance to increase yield. The extent of pollination dictates the maximum number of fruits." In light of this, it is vitally important to grower s that the supply and availability of bees are protected to the highest degree possible.

Artificial bee hives serve two purposes: production of honey and pollination of crops. The hives are commonly transported so the b ees can pollinate crops in selected areas. Modern bee hives are usually const ructed of wood and consist of several parts which include the following:

• Bottom board - this has an entrance for the bees t o get into the hive. Other

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Diseased

Bee Hives None. Disease

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-19 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning • Brood box - is the most bottom box of the hive and is where the queen bee lays her eggs.

• Honey Super - same as brood box, but is the upper- most box where honey is

stored.

• Frames and Foundation - wooden frame and plastic s heet with honey comb impression where bees build wax honey combs.

• Inner and Outer Cover - As the name implies.

Beekeepers have experienced several problems in the past few years. A recent development is the problem of colony collapse disor der (CCD), a phenomenon where bees mysteriously abandon their hives. The U C Davis Department of Entomology website contains an article dated Oct. 1 6, 2007, about a lecture presented by UC Davis honey bee specialist Eric Mus sen . The article notes the following comment: "One-third of America's honey b ees vanished this past year due to the mysterious CCD, characterized by almost total hive abandonment. Nearly all adult worker bees unexpectedly fly away from the hive, abandoning the stored honey, pollen, larvae and pupae. Usually th ey leave in less than a week, and only the queen and a few young workers remain".

Section 29208 of California Code of Regulations Tit le 3, Food and Agricultural Code, Division 13, Bee Management and Honey Product ion, requires that "If American foulbrood is found in an apiary, the abate ment shall be by killing the bees in the infested colonies and disposing of the hives and their contents, together with any other infested comb, hives, and a ssociated appliances which are found in the apiary, in one of the following wa ys: If abatement is by burning, the person abating shall act in accordance with app licable air pollution control district or air quality maintenance district regula tions and state and local fire control laws. If the regulations or laws prohibit burning immediately, the diseased colonies shall be sealed and placed in an enclosed structure and thereafter burned on the first date allowed by the regulation or law. All the activities shall be reported to the inspector prior to burning, who may require that burning occur only under his or her supervision."San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-20 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.5 RICE STUBBLE (STRAW)

Until June 1, 2010, permits may be issued for the b urning of rice stubble up to 70% per year of the total acreage of rice farmed by the operator. Permits may also be issued for the burning of residual rice stu bble, spot burning of rice stubble, and burning of weeds and vegetative materi als on rice field levees and

banks.

Summary and Recommendation

Table 3-10 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing rice stubble. 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 recommends that op en burning of rice stubble be allowed to continue for burns at 70% per year of th e total acreage of rice farmed by the operator after June 1, 2010 and until June 1 , 2015. District staff will review the feasibility of a complete burn prohibiti on for rice stubble in 2015.

Description and Findings

Most of the rice grown in the SJVAB is grown in the northern part of the air basin. 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 postharvest straw residue in the rice fields is importa nt to the successful production of the next crop. Burning has been the historical cul tural practice for removing straw and residues for the California rice industry . Burning rice straw helps prepare the field for the next rice crop as burning destroys any diseases in the rice straw of the current crop.

The farming operations for rice growers in the SJVA B are different from Sacramento Valley growers, where significant acres of rice are also farmed. Rice growers in the Sacramento Valley typically dis pose of their rice straw by incorporating the rice straw into the soil. Unlike Sacramento Valley where water Rice Stubble (Straw) Potentially

feasible

alternative Currently in

practice by operators? Increment

al Cost, $/acre at

20 acres

or more: District

Percent

of Return

on Sales Industry

Stakeholder

Percent

Return on

Sales

Rice Stubble (Straw) No. Market

and Water

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-21 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning allocations allow post-season irrigating, water can not be delivered to agricultural operations in the Northern SJVAB in the post-harves t season due to the annual distribution schedules designated by irrigation dis tricts. Due to the lack of available water in the post-harvest season, rice gr owers in the SJVAB do not use soil incorporation to dispose of their rice straw b ecause the residue may not breakdown by planting season. Most rice growers in the SJVAB do not have

access to water wells for their rice fields.

In 2007, District staff believed that rice growers could sell the rice straw to rice straw baling operators who would then sell it to th eir customers such as dairies. Therefore, the District prohibited open burning for 30% of rice stubble per year.

In 2009, District staff attended a meeting held by several rice growers that farm in the Escalon area. According to the growers, the ba ling alternative worked well

for the 2007 harvest as there was a market for the baled rice straw. However, rice growers stated that they were having difficult y in their efforts to comply with the 70% burn allowance for 2009. Specifically, the y were having difficulty in getting their rice straw baled and removed from the ir farms. The rice growers and a rice straw baling operator indicated that the y have conducted several searches on alternatives to burning the rice materi al and there is currently no market for baled rice straw. In November 2009, a v ariance was approved for a group of rice growers that farm in the Escalon area to allow them to burn the remaining 30% of their acreage. Growers noted in t heir variance application that there were no viable alternatives currently availab le for disposal of the rice

stubble.

According to the District’s burn data for rice stub ble, the annual burn acreage have fluctuated since 2006. This change is primari ly due to the market demand for rice stubble. However, open burning from rice stubble have been reduced by 42% since 2005, base on a three-year average from 2 007 to 2009. The market should continue to be assessed annually to ensure t hat rice stubble can continue to be used for other alternatives, such as dairies.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-22 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.6 Prunings from Apple, Pear, Quince, and Fig Crop s

3.6.1 Prunings from Apple, Pear and Quince Crops

Summary and Recommendation

Table 3-11 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for disposing prunings from apples, pears, and quince c rops and do not believe that there are technologically feasible alternatives to open burning of these materials. Depending on the amount and size of materials, it m ay not be feasible to require that growers place the materials into plastic bags for burial. The chemicals are preventative measures to help control fire blight; however, chemicals are not the solution to ensure complete control since the bacte rial disease may develop

resistant strains. District staff recommends that prunings from apples, pears, and quince be allowed to be burned to help control the spread of fire blight.

Description and Findings

Pome fruit including apple, pear, and quince crops are susceptible to a disease called fire blight. Fire blight is a destructive b acterial disease that kills blossoms, shoots, limbs, and sometimes the entire tree. Inse cts, wind, and mechanical devices can spread fire blight. According to the a g representatives and an agricultural commissioner, fire blight can destroy an entire orchard in a single

season if left uncontrolled. The bacterium can be easily transmitted to susceptible tissue by contact. The equipments used to prune the tree are routinely sterilized with antibacterial agents when moving from one tree to the next to mitigate exposure to the disease or potenti al disease. The unrestricted

movement of infected tissue will cause the disease to spread rapidly and under certain environmental conditions (hot and wet). Co ntainment of the infected

tissue is an essential element for control.

Apple, pear, and quince prunings are burned to comb at further spread of fire blight within orchards and to prevent potential inf ection of nearby orchards. Some operators and county ag commissioners have ind icated that they are not Prunings Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS) Apple, Pear, & Quince Crops None.

Disease

Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-23 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning aware of an effective treatment for fire blight. C hemicals that are used to control the bacterial disease could prove ineffective if th e disease becomes resistant over time. According to an agricultural commission er, the options for controlling fire blight that is becoming resistant to chemical means of control with Streptomycin are burning on site or disposal by pla cing infected plant material in double plastic bags for burial.

3.6.2 Prunings from Fig Crops

Summary and Recommendation

Table 3-12 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered shredding as an alter native to open burning of prunings from fig crops and other factors currently impacting fig crops. Shredding the pruning materials on site appears to be a common practice and the most feasible alternative to open burning of pr unings from fig crops. Shredding the fig prunings and allowing it to decom pose should not be a significant fruit degradation concern for fig orcha rd removal as the chipped material should have decomposed or be reduced in si ze by the time of harvest. The current mowing and sorting practices would help reduce any excessive materials from the figs during harvest. As a resul t, District staff recommends that open burning be prohibited for prunings from fig cr ops.

Description and Findings

Most figs are harvested as a dried crop. Figs are dried on the tree and allowed to fall to the ground. Dried figs are mechanically swept into windrows and collected and harvests are repeated at two to three week intervals. This method of surface harvesting requires the orchard grounds to remain free of excess

debris that will hinder the harvest. The harvested figs are then transported to a dry location to be sorted before being sold.

According to ag representatives, there are no fire blight issues for figs and shredding the pruning material has become a common practice. Fig crops are typically pruned by hand during the winter. The pr uning materials are placed in the aisle of the tree rows and shredded in place. Operators typically mow the Prunings Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Fig Crop Shredding Yes N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-24 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning center of the tree rows a few times a year to manag e and maintain the orchard

floor.

3.7 SURFACE HARVESTED PRUNINGS

3.7.1 Prunings from Grape Vines and Grape Canes

Summary and Recommendation

Table 3-13 Summary of Analysis

Surface

Harvested Prunings – Vineyard

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent

of Return

on Sales Economically

Feasible? (less than 10% ROS)

Grape Vines Soil Incorporation Yes N/A N/A N/A Grape Canes Soil Incorporation Yes N/A N/A N/A *N/A: not applicable

Recommendation: As shredding and soil incorporation of prunings fro m grape vines and grape canes are already widely practiced, District staff considers soil incorporation to be a viable alternative to open burning and recomme nds that prunings from grape vines and grape canes be prohibited from open burning.

Description and Findings

This category does not include grape attrition. Ac cording to the District’s policy, attrition is vegetative materials not associated wi th pruning (as defined in Rule 4103) or orchard removals. Attrition materials incl ude the incidental cuttings of dead or broken branches, tree mortality, water spro uts or suckers, or other damage to tree crops. Attrition materials may be bu rned provided that the materials are listed on a valid burn permit and dai ly burn authorization is granted.

Grape vines are used to produce table grapes, wine grapes or raisin grapes. The grape canes and spurs from a grape vine are usu ally pruned once a year in the winter when the grape vine is dormant. Wine vi neyards now have high tensile wire to withstand the machines that go thro ugh the rows during pruning. The pruned grape canes and any other pruned materia l, such as spurs, are positioned in the center of the grape vine rows and shredded. Many growers typically shred their grape vine pruning material u sing a tractor and a shredder. Grape canes and other materials from the grape vine s do not include the prunings from kiwi crops, which are already subject to Rule 4103.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-25 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning Figure 3-1 Illustration of Grape Vine and Cane

A head-trained vine with cane pruning

Bilateral cordon training with spur pruning

http://www .ipm.ucdavis.edu/PMG/GARDEN/FRUIT/CULTURAL/grtrainp rune.html

According to ag representatives and growers, the sh redding and soil incorporation of grape cane prunings and other prun ing materials from a grape vine have been long time traditional practices of g rowers. According to ag representatives, growers and biomass power plant op erators, they are not aware of anyone doing anything with grape canes and other pruning materials from vines, except for shredding them and incorporating the shredded material back

into the soil.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-26 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 3.7.2 Raisin Trays

Summary and Recommendation

Table 3-14 Summary of Analysis

*N/A: not applicable

Recommendation: District staff has considered the factors currently impacting the alternatives for open burning of raisin trays and recommends that op en burning of raisin trays be allowed to continue. There is currently not enough research information for using raisin trays as fuel at biomass power plants. In a ddition, District staff believes

that the increase to 40% of mechanical harvest for raisin production in 2009 alone has also significantly reduced the amount of emissions from these materials. As growers continue to switch to mechan ical harvesting as an alternative to using raisin trays and open burning the material, District expects that open burning emissions from raisin trays will subside as well. According to the District’s burn data, growers have continued to reduce open burning of raisin trays. Since 2007, growers have reduced burning of raising trays by over 27%, or 0.11 tons. District staff recommends that growe rs implement the practices below to control open burning of raisin trays and t hat the District work with the ag industry to develop any additional measures.

Description and Findings

Raisin trays are used in producing raisins. There are several types of drying trays used for sun-dried raisins. Wooden trays wer e used in the past, but have been replaced by paper trays. Due to changes in fa rming practices and other factors, several new paper trays have been develope d. The types of paper trays available include regular paper, wet-strength paper and poly-coated paper. Both wet-strength paper and poly-coated paper trays are especially suited for protecting the raisin crop under wet conditions.

The traditional paper tray is approximately 24 inch es wide and 36 inches long although other sizes are available for certain situ ations. The continuous tray, which consists of tray material wound into rolls of specified widths, resulted from the development of mechanical harvest machines. Th e continuous paper is a heavier weight than individual trays. Surface

Harvested Prunings – Vineyard

Materials Potentially feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre at

20 acres or

more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Raisin Trays None. Polymer &

Recycling Issues. N/A N/A N/A N/ASan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-27 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning Once the raisins have cured adequately and the mois ture in the rolls is acceptable, normally in late September, they are re ady to be collected. Raisins must be at 16 percent or less moisture content to m eet the industry’s incoming inspection requirements. There are several methods used for collecting the raisins and preparing them for the next step in the ir processing. After the raisins are collected, they are separated from the raisin t rays for further processing and delivery to a raisin handler. Once the raisins are removed from the raisin trays, the raisin trays are ready for some other use or di sposal.

Growers have continued to pursue alternative ways t o burning raisin trays for over 50 years. Ag representatives indicated that o nly about 50,000 acres of vineyards using raisin trays are expected by 2015 b ecause growers are transitioning to mechanical harvesting, which does not include the use of raisin trays. It is expected that there will be a continu al reduction in burning. The long term goal of the California raisin industry is to t ransition toward 100% mechanization of raisin harvest and drying 5 . Based on information received from the ag representatives, the historical use of paper raisin trays has been significantly reduced by over 52% since 1990. The table below is a summary of information provided by ag representatives and show s the progress made in reducing the use and open burn of raisin trays.

Table 3-15 Raisin Tray Paper Volume History

Year Total Amount of

Raisins in

Production (tons) Percentage of

Raisins

Mechanized (%) Amount of

Raisins

Produced on Raisin Trays (tons) Number of Raisin

Trays (four pounds of raisins per tray)

1990 395,000 5 375,000 188,000,000
2000 432,000 10 389,000 195,000,000
2009 300,000 40 180,000 90,000,000

According to ag representatives, some growers used recycling firms to dispose of their trays in the past. The trays were then shipp ed to China. The growers were typically charged a fee when the recycling firms pi cked up the trays at the growers site. However, China has cut off import of raisin trays because of the dollar’s value and the practice of sending raisin t rays to China is no longer a

feasible alternative.

District staff has considered soil incorporation an d biomass power plants as possible alternatives; however, the materials in th e raisin trays create several potential issues. Ag representatives have indicate d that some growers grind and soil incorporate their raisin trays. The raisin tr ays contain polymer (5%) so thatSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-28 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning the moisture on the ground can not be absorb effici ently through the raisin trays. The trays that are ground up and soil incorporated into the soil can create problems because the materials are slow to decompos e and some pieces will scatter around. Growers prefer clean fields for op erations, which also help keep rodents and pests away.

The raisin trays currently can not be recycled for use as fuel at biomass power plants due to the polymer in the material. Accordi ng to biomass power plant operators, both Madera and Mendota power plants are permitted to burn paper. Power plant operators indicated that they are willi ng to work with the District to address these issues. Power plant operators are de termining a way to incorporate raisin trays into their fuel and analys is is pending. Additional research is needed for the potential use of raisin trays as fuel for biomass power plants.

In efforts to help reduce and control the burning o f raisin trays, Ag representatives have developed and recommended the following practices for the burning of raisin trays:

1) All burning locations must be attended at all ti mes when the raisin trays are burning, by able bodied adults with adequate to ols or equipment to control a fire from escaping.

2) All burn locations must have adequate clearance to avoid escape. The burn area should be a “fire safety zone” away from dry fields, homes, shops, garages, utility poles or utility supply lin es, and other buildings or equipment. A rule to remember is to remove all combustible

materials from 30 or more feet around the burn area

.

3) Paper raisin trays must be burned in a container to avoid escape of burning embers or ash, such as a wire cage. A wire cage may be constructed out of hardware cloth or chicken wire p rovided that the mesh is no larger than a 1⁄2 inch opening. The cage should never be filled beyond half and should be placed in a “fire safe zone”. Using a burn barrel for burning anything is illegal.

4) Don’t burn on windy days.

5) Avoid burning near a highway or roadway. Ashes or heavy smoke can create a very dangerous situation for drivers and w inds caused by vehicles could cause the fire to escape from the fi re safety zone.

6) Don’t cause a smoke nuisance to your neighbors.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-29 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning District staff will work with the Ag stakeholders t o implement the recommended practices when burning raisin trays.

3.7.3 Almond, Walnut, and Pecan Prunings

Summary and Recommendation

Table 3-16 – Summary of Analysis

Recommendation: The economic feasibility analysis is presented in S ection E-4 in Appendix E. Based on the considerations and analysis for prunin gs from almonds, walnuts, and pecans, District staff recommends the following :

The District would provide limited burn allocation for surface harvested prunings from almonds, walnuts, and pecans according to the following:

1. Prohibit burning of prunings for each agricultur al operation whose total nut acreage (i.e., almonds, walnuts, and pecans) at all agricultural operation sites is 3,500 acres or more. 2. For each agricultural operation whose total nut acreage at all agricultural operation sites is less than 3,500 acres, a. Allow burning of up to 20 acres of prunings per year, and

b. Allow burning of additional prunings, provided:

i. The operator submits to the APCO before the pruning operation is completed, a representative cost estim ate(s) for shredding all prunings generated by the total nut a creage at the agricultural operation site. The cost estimate (s) shall reflect shredding in a time frame that allows the o perator to proceed with established post-pruning cultural prac tices.

ii. The APCO determines that either the submitted cost estimate(s) represent(s) an unreasonable financial impact to the operator, or that adequate shredding services a re not available in time for the operator to proceed with established post-pruning cultural practices. Surface

Harvested Prunings Potentially

feasible

alternative Currently in

practice by operators? Incremental

Cost, $/acre

at 20 acres

or more: Percent of

Return on

Sales Economically

Feasible? (less than 10% ROS)

Almonds, Walnuts, and Pecans

Farms Less

than 100 acres Shredding Some Operators $38 10.0% Yes

Farms 100

acres or more Shredding Some Operators $38 8.5% YesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-30 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning Description and Findings

Although the pruning methods will vary among grower s, nut crops in general would have similar or common practices. So, unless otherwise noted, the following description for nut crops applies to almo nds, walnuts, and pecans.

Nut trees are usually pruned after harvesting, eith er late or early in the year. In the past, growers generally open burned nut pruning s to dispose of the material. However, many growers have found alternative ways t o convert prunings into something useful such as soil amendment, dust contr ol on unpaved surfaces, compost material, or fuel for biomass power plants. According to published documents and stakeholder comments, most nuts growe rs are currently shredding the prunings and leaving the materials on the orchard floor. Stakeholder comments include growers, vendors, and custom shredders. The ability to shred the materials varies among growers of different size farms and regions. One top nut grower in the SJVAB has conti nued to help minimize impact on air quality through environmentally respo nsible efforts, which include a contract with a biomass power plant to take its orc hard removals and prunings. In 2008, another farm of several thousand acres ini tiated cultural practices and equipment necessary to shred all of the prunings ra ther than burn. District staff has also received comments from growers and custom shredders indicating that shredding of nut prunings has been a successful pro cedure in the farming operation, particularly for walnuts for one grower. However, there were also concerns from other growers regarding the burn proh ibition for the prunings of
nut crops.

A primary concern that some almond and walnut growe rs have is preventing the pruning material from interfering with the harvesti ng of the crop. Some of the existing shredding equipment currently shred the ma terials from one inch to a

few inches in size.

One problem that some growers have experienced with chipping is the build up of chipped material on the ground, which slows the decomposition process. This situation can then cause the chipped material to be picked up during harvest. Some growers till the shredded material to help the decomposition. A grower noted that all pecans are no till operations wherea s only a third of walnuts are no till operations. Although tilling could be done to bury the chipped material to promote faster decomposition, growers try to minimi ze the number of tractor passes in their orchards.

According to ag representatives, the almond hullers indicated that the impact of almond prunings or chips has been problematic. The chips are picked up with the almonds during the harvest process. The chips pass by the “detwiggers” which remove the larger sticks and branches that ma y get knocked down duringSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-31 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning the typical harvest process (shaking, sweeping and pick-up). The product then goes to the almond hullers/shellers, which separate the hull and shell from the almonds. Growers want to keep the harvest as clean as possible in order to maximize the price they receive from the almond hul l processors that convert the hulls into animal feed. In order to keep the groun d surface free of pruning material at harvest time, many growers have mostly relied on removing the pruning material from the field and open burning th e pruning material.

Ag representatives also provided the following info rmation to the District. The hull has significant feed value to dairies, and hul ls with 15% fiber content or less are considered “prime hull” and receive the highest value. The next product is

“hull and shell” which is limited to a fiber conten t of between 15% and 29%. And lastly, the shell or any product that has greater t han 29% fiber content has little value and hardly any market. The almond hullers th at the ag representatives spoke to estimate a five percent to 11% loss in pri me hull revenue due to the presence of chips. Prices vary from year to year, but prime hull sells for significantly more than hull and shell. During a s urvey that the ag representatives conducted in 2009 for the purposes of developing comments for Rule 4103, prime hull was selling for $75 per ton, while hull and shell was selling for $45 to $50 per ton. Chips are high fiber conte nt and when picked up with the hulls during the hulling process, they can signific antly shift the fiber content. One huller estimated that the 4,000 tons out of 35,000 expected tons were shifted from “prime hull” to “hull and shell” due to the ex istence of chips. This was an 11.4% loss amounting to $120,000 in lost revenue. Another huller lost an estimated five percent of their “prime hull sales” due to the existence of the chips.

For walnuts, the hulls are not used for feed; howev er, growers still need to keep the harvest clean in order to minimize any negative impacts during the processing of the nuts. According to the ag repres entatives, the walnut growers and walnut processors have indicated that the prima ry issue is that the chips plug the lines at the processor, especially under wet co nditions. Walnuts are typically harvested from mid-September through mid-November. About half of the time, rains during the fall begin before the harvest can be completed. Since the prunings occur in the winter, it is impossible to g et a chipper into the orchard until after the rains subside. The chips do not decompos e in the six to seven months between the pruning and the beginning of harvest. This is where the plugging occurs. The wet chips impede the ability to move t he walnuts through the ductwork at a huller/dehydrator and processor, as t he chips are picked up with

the walnuts.

Ag representatives stated that walnut processors ha ve also expressed concern with the chips being left in the orchard due to con cerns over food safety. Since the chips are an organic material, they are subject to mold growth. If this mold is picked up during harvest, it can create a significa nt food safety issue in terms ofSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-32 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning the potential for aflatoxin. Food safety has becom e the number one issue of concern for the tree nut industry, and any issue th at would confound food safety would be problematic.

As the trees are pruned late in the year, the groun d is usually too wet to run heavy equipment in the field in order to chip the p runings. Growers will then wait for the ground to dry but they can only wait for a limited time as they need to spray and irrigate their fields early in the year a nd the pruning material can interfere with these operations. This gives the gr owers a short window of opportunity to have their prunings chipped. Some g rowers usually find it more conducive to their operations to gather the pruning s and burn them.

For growers that shred the pruning material as an a lternative method to open burning, the practice varies among nut growers. In addition, the pruning practice for the growers in the northern region appears to b e different than the southern region. Growers could shred the prunings by rentin g, purchasing, or borrowing special equipment, or by hiring a custom shredder. These options depend on the availability of the custom shredder or the equipmen t. Costs for the options above also vary; however, District staff has analyzed the cost of hiring a custom shredder as the likely alternative (see section on Costs for analysis) for growers that own smaller farms. Custom shredders currently charge a two hour minimum fee to shred nut prunings. The average charge is a round $260 per hour for a total of $520 for two hours. Purchasing a special shredding equipment that can shred the material into fine pieces to address the issue with the chips being picked up during harvest season could cost over $30 0,000 and is an expensive option and less likely for a small grower.

Ag representatives, custom shredders, and growers h ave mentioned that there is a shredder in the market which can shred the prunin gs into smaller pieces, thereby reducing problems during the harvest season . The shredder can also operate in all weather conditions, including the ra ining season. The vendor of the shredding equipment has indicated that 48 of those shredders are currently available for the industry and that previous shredd ing equipments have been sold mostly to growers where some also provide custom sh redding service. One of the custom shredder indicated that most growers tha t farm over 3500 acres typically shred their own material and that it woul d be more costly for a grower that farms less than that to purchase the same shre dder.

District staff conducted an analysis to determine w hether it would be viable for growers to purchase a shredder instead of hiring a custom shredder. The following information was used to conduct this anal ysis:

1. Harvesting ends in October and cultivation begin s around January/February. District staff estimated that th e available monthsSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-33 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning during the pruning season are November, December, a nd January (three months). 2. According to a custom shredder, the specific shr edding equipment can cover eight to ten acres per hour. District staff estimated nine (9) acres per hour for the shredding equipment. 3. One working day equates to about eight (8) hours . Average number of working days per month is 22 days. District staff estimated that two hours are used to prepare the equipment before and after operation and six hours are used to shred (process) the pruning mater ial.

The calculations for one shredder are as follow:

1. Total Number of Acres Processed Per Month

Hours Processed Per Day x Acres Processed Per Hour x Averaged Number of Days Per Month:

6 hrs/day x 9 acres/hr x 22 days/month = 1188 acres /month

2. Total Number of Acres Processed During the Pruni ng Season (Three Months)

Total Acres Per Month x Three Seasonal Months:

1188 acres/month x 3 months = 3564 acres

Based on the calculations, one shredder can cover a pproximately 3500 acres.

District staff believes that it would be reasonable for a grower that farms 3500 acres or more to purchase an equipment to address h eavy to light prunings from the nut orchards. As mentioned by the vendor and c ustom shredder, many growers that own their own shredding equipment also provide custom shredding service to other growers.

District staff conducted further analysis on the co st benefit of purchasing the shredding equipment for a farm over 3500 acres. Th e analysis below is intended to compare the two methods for the shredding altern ative and is not representative of the incremental cost. The analys is is based on the following

factors:

1. Hiring a Custom Shredder:

• Per custom shredder, the average charge is $520 fo r two hours

minimum.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-34 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning • Equipment can process eight to ten acres per hour, or 16 to 20 acres minimum (Averaged: 18 acres).
(Reference: http://www.panerofarms.com/why-flory-powertrack.htm l )

• Based on the above information, minimum averaged c ost per acre is $29.

2. Purchasing a Shredding Equipment:

• Per vendor and custom shredder, the estimated cost of purchasing the shredding equipment range from $315,000.

• Labor rate of $14.74 per hour for machine operator s, which includes payroll overhead of 34%.

(Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

• Price for on-farm delivery of diesel is $2.50 per gallon, which

includes a 2.25% sales tax on diesel fuel.

(Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

• Fuel use for a shredding machine with similar hors epower is 12 to 15 gallons per hour. District staff estimates that the averaged amount of fuel (diesel) required to operate the shr edder for one hour is 14 gallons (References: http://www.jgpress.com/archives/_free/001555.html and http://www.neequip.com/KFNA/BROCHURES/PDF_BRO/Cramb o_2005E.pdf )

• Annual maintenance is calculated as two percent of the purchase price. (Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

• Other additional costs include property insurance and property taxes (cash overhead). According to the 2008 Almonds costs and Returns Study

, the cash overhead contributes to about 9.5% of th e capital recovery. (Reference: http://coststudies.ucdavis.edu/files/almondvs08spri nk.pdf )

Based on the best available information and analysi s above, the following calculations use 3564 acres per year for an equival ent comparison of the cost of purchasing a shredder and the cost of hiring a cust om shredder.

The calculation for hiring a custom shredder is as follows:

1. Total Annual Cost of Hiring a Custom Shredder

Minimum Averaged Cost Per Acre x Number of Acres:

$29/acre x 3564 acres = $103,356San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-35 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning The calculations for purchasing a shredder are as f ollows:

1. Total Annualized Capital Costs of the Shredder

The District uses the following formula to calculat e an equivalent annual cost from a capital cost using a capital recovery factor as shown below:

A = [P x i(1 + i) n ] / [(1 + i) n – 1]

Where: A = Equivalent annual cost of control

P = Capital cost of the control equipment, includin g installation cost

I = Interest rate (used 10% as a conservative esti mate)

n = Equipment life (used 10 years as a conservativ e estimate)

[$325,000 x 10%(1 + 10%)^10yrs] / [(1 + 10%)^10yrs – 1] = $51,265

2. Total Annual Cost of Diesel Fuel

[Estimated Amount of Fuel (in Gallons) Used Per Hou r x Hours Processed Per Day x Averaged Number of Days Per Month] x Cost of Fuel Per Gallon:

[14 gallons/hr x 6 hrs/day x 22 days/month x $2.50 /gallon] x 3 months = $13,365

3. Total Annual Cost of Hiring a Machine Operator

Labor Rate Per Hour x Total Number of Work Hours Pe r Day x Averaged Number of Days Per Month x Three Seasonal Months:

$14.74/hr x 8 hrs/day x 22 days/month x 3 months = $7,783

4. Total Annual Cost of Maintenance

Cost of the Shredder x Two Percent of the Cost of t he Shredder:

$315,000 x 2% = $6,300San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-36 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning 5. Total Annualized Cost of Property Insurance and Property Taxes

Total Annualized Costs of the Shredder x 9.5 Percen t for the Cash Overhead (Insurance and Taxes):

$52,892 x 9.5% = $4,883

Table 3-17 and Table 3-18 summarizes the annualized cost estimates for the purchase of a shredder and the annual costs of hiri ng a custom shredder.

Table 3-17 – Annualized Cost Estimates for the Purc hase of a Shredder Description Costs Total Capital Cost $315,000

Total Annualized Capital Cost of the Shredder (10% - 10 years) $51,265 Annual Operation & Maintenance Costs Total Annual Cost of Diesel Fuel $13,365 Total Annual Cost of Hiring a Machine Operator $7,7 83 Total Annual Cost of Maintenance $6,300 Total Annualized Cost of Property Insurance & Taxes $4,883 Total Annual Operation & Maintenance Costs $32,331

Net Annual Costs (Annualized Capital Cost + Annual O&M Costs) ($/year) $83,596

Table 3-18 – Annual Cost Estimates for a Custom Shr edder Description Costs Averaged Cost Per Acre $29

Total Annual Cost for 3564 acres $103,356

Net Annual Costs ($/year) $103,356

Based on the analysis above, the estimated savings from purchasing a shredder is close to $20,000 per year.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-37 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning According to GrowingProduce.com, the 2009 Top Nut G rowers make up about 228,000 of nut acreages in California. Out of the 25 Top Nut Growers, 18 of those growers are in the District’s burn permit dat abase or the Conservation Management Practices (CMP) database. The 18 grower s make up about 183,154 acres of nut crops. Pistachios contribute to about 16% of the total acreage in the SJVAB, therefore the estimated acrea ge for almonds and walnuts for SJVAB growers is 154,327 acres, which is about 20% of the total nut acreage in the SJVAB. Twelve of those growers are over 3,5 00 total farm acres of nut crops and contributes to over 94% of the top acreag es on the list, or about 212,000 total nut acreages. At least two growers i n this group are either shredding the pruning material or taking the materi al to the biomass power plant. Based on the 2007, 2008 & 2009 Top Nut Growers tabl es, District staff expects that at least 80 percent of the farms in the top 25 list could buy their own shredding equipment. At the bottom of the 80 perce nt range, the total nut acreages average about 3460 acres.

According to the custom shredders, the average char ge to shred the prunings is a minimum of two hours. The recommended shredder, which can shred the materials to finer pieces to address issues with th e chips not being decomposed by harvest season or being picked up during harvest , can process eight to ten acres per hour. Due to the two hours minimum that custom shredder charges the grower, District staff believes that the cost o n a per acre basis would increase as the acreage becomes smaller. Therefore, the 20 acres limit within the two

hour timeframe is reasonable.

District staff is aware of at least three custom sh redders in the SJVAB that operate a total of five of those shredders and anot her two contractors that do custom shredding. There are also several types of other shredding equipment available, where some may require more passes in or der to shred the prunings into acceptable sizes.

The Jack Rabbit equipment is typically used to remo ve the material from the orchard. Transporting the material to composting f acilities appear to be less common among growers compared to shredding the mate rial onsite or taking the material to the biomass power plants. According to biomass power plant operators, some biomass power plants purchase some, but not all, of these prunings. The preferred alternative at this time f or most pruning material is to shred and leave the material on the ground, since i t can be more efficient than chipping and transporting the material offsite. So me growers have found that shredding and incorporating the materials back into the ground helps replenish the soil with nutrients. Several growers are also moving towards lighter pruning, which are about one-fifth of what they used to be. Since 2007, the amount of almond prunings burned has been reduced by over 22, 000 acres, or 76 tons of PM2.5. The amount of burn acres from walnut prunin gs has also been reducedSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-38 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning by over 5,500 acres, or over 13 tons of PM2.5. The category for pecan prunings has shown a slight change in open burning; however, prunings are also shredded and left on the ground. The overall amount of emis sions reduced since then could be even higher as a result of lighter pruning s.

Over the past ten years, NRCS has encouraged grower s to chip or shred the prunings from almond and walnut orchards by providi ng a cost-share basis through the Environmental Quality Incentives Progra m (EQIP). According to NRCS staff, it is uncertain how long this program w ill last. Many of the growers shred the material on site through this program, wh ich helps reduce Nox, VOC, PM10, and PM2.5 emissions generated from open burni ng. According to NRCS, the program resulted in an average of 120,333 acres of almond and walnut prunings chipped per year in the SJVAB from 2007 to 2009. Along the same years, the average amount of almond and walnut prun ings burned from the District’s database was 68,802 acres per year. Acc ording to the County Agricultural Commissioner’s data for Calendar Year 2008, the total harvested acreage for both of those crops in the SJVAB was 75 3,515 acres. The total harvested acreage for pecans is 611 acres, or 0.08% of the total nut harvested acreage. See table below for a summary of the alte rnative methods for almond and walnut prunings. Pecans are not included in th e analysis below because NRCS data only addresses almonds and walnuts.

Table 3-19 – Analysis of Alternative Methods for Al mond and Walnut

Prunings Surface Harvested Prunings from Almond and Walnut C rops Acres Total Harvested Acreage for Almonds 625,814 Total Harvested Acreage for Walnuts 127,701 Total Harvested Acreage for Almonds and Walnuts 753 ,515

Estimated Acreage Pruned per Year 1 376,758 Chipped/Shredded Acreage of Almond & Walnut Pruning s per year (NRCS) 120,592

Open Burned Acreage of Almond & Walnut Prunings per year (District) 68,802

Estimated Acreage from Alternative Disposal of Almo nd & Walnut Prunings 2 187,364

1 Assume Pruning is done in alternate years: [(753,51 5) / 2] = 376,758. The 2008 Almonds Costs and Returns Study and 2007 Walnuts Costs and Returns Study use alternate years for pruning of mature orchard. Both studies analyzed the alternat ive method of chipping and shredding onsite and indicated that the practices will vary among gr owers and regions.

2 The remaining acreage is likely to be voluntary dis posal through alternative methods to open burning, such as shredding, chipping, biomass fuel, or other methods, and without the EQIP

program.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-39 Chapter 3: Technical and Economic Analysis of Affected Crop Categories and Recommendations Revised Proposed Staff Report and Recommendations on Agricultural Burning Based on the table above, if growers prune the harv ested orchards during the dormant period every other year, the actual amount of acres pruned per year would be about 376,758 acres. Based on the analysi s above, about 18% of the acreage pruned per year is contributed to open burn ing, while most of the growers are using other alternative practices rathe r than open burn.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

3-40 Chapter 3: Analysis of Affected Crop Categories and Recommendations Revised proposed Staff Report Recommendations on Agricultural Burning This page intentionally blank.Revised Proposed Staff Report and Recommendations on Agricultural Burning



## Chapter 4

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## .San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-1 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning 

### Chapter 4: TECHNOLOGICAL FEASIBILITY OF

ALTERNATIVES TO BURNING

District staff has conducted detailed research and identified several potentially feasible alternatives to open burning of agricultur al materials. Some of the alternatives were previously identified during the 2005 and 2007 burn prohibition schedules. Potential alternatives for agricultural wood and agricultural non-wood materials were identified for each of the following groups: 1) vegetative and related material and 2) animal-related material.

The more common methods of disposing of agricultura l material that cannot be open burned include the following:

• Some agricultural materials, like orchard removals , are primarily transported to biomass power plants for use as fuel

.

• Chip or grind the material and transport it off-si te for disposal or other

renewable uses.

• Prunings and some field crop materials may be shre dded in place, chipped onsite, or tilled into the soil.

• Some materials, such as rice straw, may be baled a nd sold for various commercial purposes, although the market for such p roduct is much less than available supplies.

The potential alternatives to open burning of agric ultural wood and agricultural

non-wood materials are described below.

4.1 VEGETATIVE AND RELATED MATERIAL

Most alternatives to open burning agricultural wood materials and pruning materials require that the agricultural materials g o through a chipping, grinding or shredding process. These processes are typically u sed to change the agricultural wood materials into a more manageable and useable size. Some of the benefits of chipping, grinding and shredding in clude faster decomposition of the materials, easier incorporation into the soil, easier to process and transport,

and better combustion when used as fuel at biomass power plants.

Agricultural wood and pruning material that are to be chipped need to be as free of debris as possible to prevent damage to the chip ping equipment and to increase its acceptability by potential end users s uch as biomass power plants and other processors. Orchard removal material is usually removed from theSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-2 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning farm after the chipping process, as growers want a relatively clean field for planting a new crop. For pruning, growers may recy cle the materials onsite or

remove the material from the farm.

4.1.1 Biomass Power Plants

Biomass power plants in the SJVAB will generally ac cept agricultural, forestry, construction, and urban residues. The power plants burn the material in combustors to produce steam. The steam is then use d to spin turbines to generate electricity.

Biomass power plants do not universally accept all agricultural material due to concerns that some materials may harm power plant m achinery. Several issues have been noted concerning the types of material, s uch as citrus chips, that can be burned by the biomass power plants and the amoun t of agricultural materials that is accepted at the biomass power plants at any given time. Biomass power plant operators have indicated that these issues ha ve been overcome over the past few years as the facilities involved have adap ted in processing the ag

materials to better suit the situations encountered

.

Using the orchard removal materials for fuel at the biomass power plant is currently the most viable and cost effective altern ative to open burning for growers due to available tax credits for biomass fa cilities and required agricultural offsets for some biomass power plants. However, reliance on biomass fuel as a primary alternative to burning is somewhat uncertain since there are no long-term federal or state funding com mitments for the biomass facilities in the SJVAB. It is also relatively mor e affordable for the biomass power plants to accept urban waste than agricultural mate rials. Pruning materials are sometimes accepted by biomass power plants. The re sidents of a typical community are being charged more money to divert ur ban waste out of a landfill. Therefore, the urban waste is subsidized by the com munity in their waste payments and this provides the urban fuel to be pro cessed at biomass plants at a more competitive price.

4.1.2 Land Application/Soil Incorporation

Applying agricultural materials to the soil is a co mmon method of disposal of the materials. The pruning material from many tree cro ps and vineyards is usually gathered into windrows and shredded in place using grinders suitable for brush. The shredded material can either be left on the gro und or be incorporated into the soil when the field is tilled. Over time, the material decomposes into the soil which adds valuable organic material to the soil an d can lead to better water infiltration and soil quality. This practice is evo lving as more growers andSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-3 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning equipment manufacturers innovate and collaborate to make the process work for

everyone.

Current practice does not work well for all crops, especially for pome (apple, pears, and quince) fruits with concerns over the sp read of diseases and for nut crops which harvest the nuts from the ground. With the exception of the potential spread of diseases from pome fruits, other operator s can usually minimize or prevent this problem for other crops by taking step s to better ensure that chipped pruning material has decomposed by the time that cr ops are harvested or that chipped pruning material is not placed in the area where the crop is to be harvested. The pruning material can be chipped int o smaller pieces using upgraded technologies that can shred the material i nto finer quality. The cost of this equipment will be assessed later in this repor t to determine if it would be economically feasible.

4.1.3 Anaerobic Digestion

Anaerobic digestion is a biological process that de composes organic matter with minimal or no oxygen level, which results in a liqu id/solid stream (digestate) and biogas that contains mostly methane and carbon diox ide. This biological process can either be found or managed through some of the following: marshes, sediments, wetlands, the digestive tracts of rumina nts and some insects, landfills, many wastewater treatment facilities, and animal fe eding operations and dairies. The anaerobic digestion technology that is managed at a farm or facility could include several steps in the process, such as feeds tock handling/storage, preprocessing, digester, collection and storage of the biogas, dewatering of the digestate, and handling/storage of the dewatered di gestate.

There are currently no commercial-scale solid waste digesters in operation in the United States even though anaerobic digesters have long been used to treat agricultural and municipal wastewater. Although, D istrict staff has found that the anaerobic digestion technology will be installed in Emmetsburg, Iowa, in 2011, as part of a commercial scale cellulosic ethanol plant . The digestate would be used as a source to power the plant.

District staff is not aware of any facilities in th e SJVAB that can process agricultural materials through anaerobic digesters on a commercial scale. In addition, it is not believed to be practical to req uire that growers install an anaerobic digester for the purpose of disposing the agricultural material. The agricultural materials that are subject to Rule 410 3 are typically pruned or removed once a year or every few years for orchard removals. Based on these considerations, District staff will not conduct fur ther analysis on anaerobic digesters as a viable technology in the SJVAB.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-4 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning 4.1.4 Composting

Composting is the process by which organic material is broken down aerobically to form a biologically stable organic substance sui table as a soil enhancer and plant fertilizer.

Agricultural material is one of the sources of orga nic material for composting operations. Other sources could include, but are n ot limited to, urban waste, biosolids, and manure. The District distinguishes the blend of organic material into two categories, composting and co-composting. Along with vegetative material, co-composting includes biosolids, manure, and/or poultry litter. The vegetative materials are a good source of nitrogen, whereas, chipped wood provides carbon to the mixture. As a result, compo st and co-compost facilities sometimes accept agricultural materials either as f eedstock or as amendment for the operation. Some compost and co-compost facilit ies also accept and store

the material for other use such as fuel for biomass power plants or animal feed. Based on District’s data, there are currently 19 co mposting and co-composting facilities in the SJVAB that might be able to accep t and process the agricultural

material.

Sources usually pay a tipping fee to compost operat ors to dispose of the material at the composting site. With competing materials f rom subsidized urban waste, disposal costs for agricultural materials could be higher and the accepted amount of agricultural materials could vary. This fee wou ld be additional to other operational costs, such as chipping and transportin g the material to the compost facility. These operational costs for the grower w ould be similar to the cost of chipping and transporting the material to the bioma ss power plants, which does not charge a fee for disposal. Based on discussion with the chipping operators, most of the agricultural materials that are chipped are transported to biomass power plants for use as fuel. Therefore, District staff plans to conduct the economic feasibility analysis on transporting the m aterial to biomass power plants as a more cost effective alternative.

4.1.5 Landfill

Growers and chipping companies can take agricultura l materials to local landfills for disposal. Not all landfills will accept these materials, particularly landfills designated for hazardous waste. Municipal solid wa ste landfills are allowed to receive putrescible waste, such as yard waste or an y methane producing material. Agricultural materials accepted at these landfills may be disposed at the site but are primarily being used as alternativ e daily cover (ADC) to reduce odor and for vector control. State Assembly Bill A B 939 was passed in 1989 and mandated local jurisdictions to meet solid waste di version goals of 25 percent by 1995 and 50 percent by 2000. Local agencies within California are required toSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-5 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning comply with the mandated landfill diversion require ment every year.

There are four landfill facilities within the Distr ict that are currently accepting organic material, which could include materials fro m agricultural crops and orchard removals. Similar to compost facilities, l andfills also charge tipping fees for the disposal. Due to the state mandated landfi ll diversion requirement and

the small number of landfills that are allowed to a ccept organic material, it is not feasible to promote agricultural material going to the landfills. District staff has considered the information above and plans to condu ct the economic feasibility analysis on transporting the material to biomass po wer plants as a more cost

effective alternative.

4.1.6 Cellulosic Ethanol Production

Cellulosic ethanol, a key next-generation biofuel, can be made from switch grass, corn stover, forest waste, fast-growing trees, wood chips and other plant

material.

Advanced biofuels are those that do not rely on the corn kernel starch. In contrast, the most common type of ethanol in the Un ited States is corn ethanol which is produced from corn with only the grain bei ng used. Corn ethanol is primarily used in the United States as an alternati ve to gasoline and petroleum (first-generation biofuel).

The production of cellulosic ethanol is still predo minately in the demonstration plant phase of development. At this time, District staff is not aware of any commercial plant within the SJVAB that currently us es agricultural materials for the production of cellulosic ethanol.

4.1.7 Gasification for Liquid Fuels

There are emerging technologies that can convert ag ricultural materials, sewer sludge, wood, trash, and plastics into diesel or bi ofuel. In traditional gasification, oxygen is used, but the new technique uses hydrogen and steam at nearly 1,500 degrees F to break apart the feedstock into a gas m ade up of its molecular components. After gasification, the resulting gas then goes through additional steps that produce water, wax, and diesel fuel. Up to 85% of the feed material becomes usable liquid fuel at the end of the proces s.

Agricultural wood materials can be used as a solid fuel by being burned in a combustion device or it can undergo processing to c onvert it into a gas or liquid fuel. Operators could choose to purchase a system given adequate space, but many of these vendors are located outside of Califo rnia. For most of these situations, the agricultural wood materials are usu ally chipped on the farm siteSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-6 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning and then transported to the processing facility. D istrict staff is not aware of these types of facilities currently in operation in the S JVAB, which would indicate that these technologies are not current alternatives to burning.

4.1.8 Pyrolysis

A new biofuel derived from wood chips through a pyr olysis process has been developed. The process involves heating wood chips and small pellets in the absence of oxygen and high temperature (pyrolysis). About a third of the dry wood becomes charcoal and the rest becomes a gas. The gas then undergoes a chemical process where it is converted into liquid bio-oil. According to researchers, the new method offers environmental be nefits and could reduce

industrial costs of alternative fuel for convention al diesel engines. The technique is still in the early stage; therefore, use of wood chips for this process would not

be a viable alternative source in the SJVAB at this time.

4.1.9 Mulch

Soil Stabilization / Dust Control A project in Northern California gauged the use of wood chips as an alternative source for soil erosion and stability to roads and parking areas. The Road Stabilization and Improvement Demonstration Project demonstrated that the use of wood chippings not only provides stabilization a nd erosion control on light duty, low-use roads, parking, and access areas, but is also cost-effective when compared to the use of other road materials.

The project found that using wood chips for road us e was a feasible alternative to expensive materials such as rock or shale. Other b enefits resulting from the project include added value to the chipped material s, improved site and off-site water quality, improved stability, usability, and m ud free road and area conditions. The project addresses the successful u se of wood chippings for soil stabilization or dust control as potential alternat ives. District staff is not aware of a feasible market in the SJVAB that could accept an d process all of the agricultural material for use as dust control but t his alternative would be considered as a similar alternative to soil incorpo ration and a possible option, given that the materials serve as beneficial use. Typically, operators apply the chipped material onto surfaces for nutrient value a nd may apply the extra material on road surfaces. In other cases, not all roads are in need of chipped

materials.

Hydraulic Mulch Agricultural material can be shredded into wood fib er and used as hydraulic mulch by Caltrans or others. Hydraulic mulch is a mixture of shredded wood fiber or a hydraulic matrix and a stabilizing emuls ion or tackifier. The mixture isSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-7 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning typically applied to disturbed areas requiring temp orary protection until permanent vegetation is established or disturbed ar eas that must be re-disturbed following an extended period of inactivity (Caltran s Storm Water Quality Handbooks, Section 3, Hydraulic Mulch SS-3). Caltr ans uses hydraulic mulch as one of the alternatives to temporarily protect expo sed soil from erosion by rain or wind. However, the wood fiber hydraulic mulches ar e generally short-lived, lasting only a part of a growing season, which oper ators may have to take into account for long-term projects. In addition, for t he wood fiber hydraulic mulches to be effective, the material requires a drying tim e of 24-hours (Standard Specifications Sections 20-2.08).

Wood chips to be used as hydraulic mulch are requir ed to be cleaned and free of salt and deleterious materials such as clods, coars e objects, sticks, rocks, and weeds. Such requirements may minimize efficiency d uring processing of the agricultural materials, and increase costs from sep arating the material or diverting different parts of the material to variou s locations for alternative use. Use of hydraulic fiber mulch has increased over the years as it has proven to be a cleaner alternative to hay or straw mulches, howe ver, staff is not aware of agricultural material being used for the hydraulic mulch process on a market scale. Therefore, staff will not pursue this optio n as a feasible alternative for open burning of agricultural material.

Wood Mulch Agricultural materials could also be recycled as wo od mulch. Wood mulching can be used in landscape projects or for erosion co ntrol and may be a mixture of shredded wood mulch, bark, and compost. The materi al is primarily used to reduce erosion by protecting bare soil from rainfal l impact, increasing infiltration, and reducing runoff. Caltrans found that wood mulc hing can be used as temporary soil stabilization for disturbed areas aw aiting revegetation and permanent cover or as a temporary, non-vegetative g round cover on slopes (Caltrans Storm Water Quality Handbooks – Section 3 , Wood Mulching SS-8). As part of wood mulching, the greeneries from the a gricultural materials may also be used for similar purposes and composted as neces sary to kill weed seeds. However, there are limitations to using wood mulch, such as introduction to unwanted species, possible sheet erosion because th e material cannot withstand concentrated flows, and the green materials may bri ng in unwanted weeds and plant materials. In addition to these consideratio ns, staff is not aware of most agricultural material being used for this process o n a market scale. Therefore, staff will not pursue this option as a feasible alt ernative to open burning of agricultural material.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-8 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning 4.1.10 Hand Crews for Removal of Materials

Some operators have considered using hand crews to remove materials, such as weeds, as a potential alternative for open burning. The labor-intensive removal

of individual weeds is often characterized with unr easonable costs and safety issues. Additionally, hand removal of weeds is tec hnically unfeasible due to the magnitude of weed abatement. Technological develop ment is needed to reduce the burning of weed abatement material.

4.1.11 Overseas Shipment of Raisin Trays

In the past, some growers have shipped reusable mat erials, such as raisin trays, overseas to be recycled. However, the alternative is no longer available for

these materials.

4.1.12 Water Decomposition for Rice Stubble (Straw)

In recent years, water decomposition has become mor e prevalent than burning rice fields stemming with the passing of the Connel ly-Areias-Chandler Rice Straw Burning Reduction Act of 1991. The Act mandated the reduction of burned rice acres over a ten year period besides that which is done for disease control. Currently, rice farmers are restricted to burn no m ore than 25% of planted acres, or up to 125,000 acres basinwide, and have moved mo re to flooding rice fields to improve the rate of decomposition.

Rice farmers flail mow the rice stubble into about 4-inch sections and stubble disk it, to ensure it has contacted with the soil f our to five inches deep. It is then flooded as soon as possible to keep the clods cover ed. Flooding the fields during the winter helps with blast and speeds decom position, as well as providing

some fertilizer benefits.

Water availability and costs for winter water are a concern but can be offset by other practices. Some disadvantages of water decomp osition arise with certain weather conditions but extra precaution is taken, s uch as managing the water flow and battening down the hatches, to prevent dam age to the rice patties. Water decomposition is a common alternative to burn ing and is required in areas that limit the amount of acreage that can be burned

.

4.1.13 Baling Rice Stubble (Straw)

As discussed above, alternatives to burning rice fi elds have been sought, especially with the passing of the Connelly-Areias- Chandler Rice Straw Burning Reduction Act of 1991. Baling rice straw was a high ly anticipated option when the Act was passed but has declined in viability. It is estimated that only about 3-5%San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-9 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning of farmers use rice straw off-field. Baling rice st raw is utilized even less due to a diminished market need and cost of production. Soil incorporation and flooding

rice fields are more feasible and viable alternativ es while potential uses are still being explored.

4.2 ANIMAL-RELATED MATERIAL

4.2.1 Burial

Burial seems to be most suitable for small amounts of material. Burial requires care in site selection because as carcasses decompo se, they release materials that can pollute ground water, particularly if larg e volumes are buried. Advantages of burial are the low cost (if the opera tor owns the necessary equipment) and biosecurity (no trucks coming to the farm to pick up carcasses).

4.2.2 Incineration

Field incineration is only appropriate for deceased animals in those instances where the spread of disease is a concern. Decision s on how to dispose of diseased animals are deferred to local agricultural commissioners.

4.2.3 Rendering

Rendering provides a much needed service to the ani mal industries in the SJVAB and is subject to certain government food saf ety and environmental regulations. There are six rendering plants in the SJVAB. Five of the plants are independent operations and collect animals from oth er sites. The sixth plant is an integrated plant and operates in conjunction wit h its affiliated animal slaughter and meat processing plants.

In most rendering systems, raw materials are ground to a uniform size and placed in continuous cookers or in batch cookers, w hich evaporate moisture and free fat from protein and bone. A series of convey ers, presses, and a centrifuge continue the process of separating fat from solids. The finished fat (e.g., tallow, lard, yellow grease) goes into separate tanks, and the solid protein (e.g., meat and bone meal (MBM) and poultry meal) is pressed in to cake for processing into feed. Other rendering systems are used, including those that recover protein solids from slaughterhouse blood or that process us ed restaurant grease.

The five independent rendering plants provide pick up and delivery for their customers. The plants do not allow public drive-up delivery in order to better control traffic at the plant and the quality of the animals processed. The pick up and delivery service is not available to any operat or that has animals available forSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

4-10 Chapter 4: Technological Feasibility of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning several reasons. A key reason is the traveling exp ense which may make it impractical to pick up small numbers of carcasses.

Rendering companies have certain regulatory and ope rational restrictions regarding the condition of the carcasses they proce ss. In addition to complying with regulations governing diseased animals, render ing companies will generally not accept carcasses that do not remain intact when handled. Depending upon the end product of the rendering process, there may be other restrictions on carcass quality and condition. Although this alter native is available, District staff does not consider rendering to be a viable or feasi ble alternative. District staff considers burial and incineration (for deceased ani mals with diseases) to be viable alternatives, which are current practices fo r the industry.

4.2.4 Sterilization

For bee hives of diseased colonies that must be des troyed, disease experts

recommend that the frames and combs be burned in a pit and the ashes covered. The heavy woodenware (supers, tops and bo ttoms, etc.) may be sterilized by scraping them clean (the scrapings sh ould be burned) and scorching the inside surfaces. The scorching can be done wit h a propane torch with particular attention being paid to cracks and corne rs. If large quantities of supers are to be scorched they may be stacked and painted inside with kerosene and lit. To sterilize large quantities of equipment, operato rs could set up a barrel with a boiling lye solution. The woodenware should be imm ersed in the solution and boiled until clean. Frames may also be sterilized in this manner.Revised Proposed Staff Report and Recommendations on Agricultural Burning



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- 1 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning 

### Chapter 5: EMISSIONS FROM AGRICULTURAL BURNING AND ALTERNATIVES TO BURNING, AND HEALTH CONSIDERATIONS

Figure 5.1 Map illustrating PM2.5 Emissions in the Valley from Open BurningSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5

- 2 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning 5.1 DISTRIBUTION OF AGRICULTURAL OPEN BURNING EMISS IONS

The map on the previous page illustrates the tons o f PM2.5 emissions per square mile and existing and proposed biomass plants in th e San Joaquin Valley air basin (Valley). The Sectional divisions of the map are the 103 burn allocation zones as developed by the District for use in the s moke management system (SMS). Each zone in the map is marked to illustrat e the three-year average annual tons of PM 2.5 emissions per square mile gen erated from agricultural burning of all types for that zone between the year s of 2007 and 2009. Most of the burn allocation zones with the highest emission s from agricultural burning

have biomass facilities in or near them.

5.2 CURRENT EMISSIONS INVENTORY FROM AGRICULTURAL B URNING

For purposes of this report, the criteria pollutant s analyzed include volatile organic compounds (VOC), oxides of nitrogen (NOx), and particulate matter (PM2.5). The 2007 Ozone Plan control measure for O pen Burning (S-AGR-1) (Managed Burning and Disposal) pertains to the burn ing of any material including agricultural materials. The Plan identified the su mmer 2005 emissions inventory for open burning as 4.8 tons of NOx per day and 5.7 tons of VOC per day. In the winter, the 2008 PM2.5 Plan control measure for Ope n Burning (S-AGR-1) (Managed Burning and Disposal) identifies the 2005 emissions inventory for open burning as 8.16 tons of NOx per day, 10.70 ton s of PM2.5 per day and 0.19

tons of SO 2 per day. As shown in Figure 5-2, agricultural burn ing is concentrated

in winter months when PM2.5 is elevated and ozone v alues are relatively low.

Figure 5-2 Average Monthly Agricultural Burning (2007-2009)

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

January

F eb r ua r y M arc h Ap r i l M ay June July

August

Se ptember October

N ovemb er DecemberBurn TonsSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

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- 3 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning Table 5-1 below presents the burn tons, burn acres, and tons of associated criteria pollutant emissions associated with agricu ltural burning averaged over a three year period for specific crop types and activ ities. The specific crop types and activities are the crops to be analyzed for the 2010 burn prohibitions resulting from state law. Because several crops ar e not a part of this analysis and do not pertain to this report, the data from th ose crops has been omitted

from the table below. The data for this table is t he best available information,

and came from the District SMS emission database.

Table 5-1 Average Annual Tons, Acres, and Emissions from Open Burning of the Remaining CH&SC Crop Types (2007-2009)
Emissions (Tons)

Crop Name Burn

Tons Burn

Acres NOx PM 2.5 VOC PM 10

Almond Pruning 51718 51718 152.57 173.26 134.47 18 1.01

Apple Pruning 900 391 2.34 1.66 1.03 1.75

Fig Pruning 1227 558 3.19 3.99 3.68 4.23

Pear Pruning 286 110 0.74 1.19 0.73 1.26

Pecan Pruning 501 295 1.30 1.83 1.58 1.96

Quince 47 28 0.12 0.17 0.15 0.18

Walnut Pruning 17083 14236 38.44 34.17 41.00 35.88

<20 Acre Orchard Removal (all crops) 70010 2334 182.03 255.54 220.53 273.04

Apple Orchard Removal 691 23 1.80 1.28 0.79 1.35

Citrus Orchard Removal 54035 1801 140.49 151.30 18 3.72 159.40

Fig Orchard Removal 2392 80 6.22 7.78 7.18 8.25

Pear Orchard Removal 490 16 1.27 2.03 1.25 2.16

Quince Orchard Removal 10 0 0.03 0.04 0.03 0.04

Brooder Paper <1 n/a 0.00 0.00 0.00 0.00

Diseased Beehives 90 41 0.20 0.68 0.48 0.71

Goat <1 n/a 0.00 0.00 0.00 0.003

Ponding/Levee Banks 302 139 0.68 2.29 1.62 2.40

Rice * 9049 3073 23.45 27.79 21.98 29.65

Raisin Trays 890 29683 1.90 0.33 1.94 0.35

Vineyard Removal 197140 13143 512.56 719.56 620.99 768.85

Totals: 406,861 117,668 1,069.3 1,384.9 1,243.2 1,472.5

* Note: no citrus pruning after 2005 1. Rice category includes residual rice straw, rice straw, rice stubble, and rice field levees.

Table 5-1 includes the Phase IV materials that were issued open burning permits. District staff calculated the burn acres and associated emissions from a

list of the amounts of selected Phase IV materials that were issued open burningSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5

- 4 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning permits, averaged from 2007-2009. The list include s almond pruning, walnut pruning, pecan pruning, vineyard removal, raisin tr ays, and rice stubble. The total acres burned from the three-year average of t he crops previously mentioned are 109,128 acres. The emissions from such activit ies are presented below:

Table 5-2 Average Annual Emissions From Open Burning of Selected Phase IV Crops (2007-2009)

Emissions NOx PM 2.5 VOC PM 10
Tons per Year 706.98 929.38 800.17 988.30

5.3 EXPECTED EMISSIONS FROM ALTERNATIVES (Criteria Pollutant – PM 2.5)

Pruning Materials The analysis in this report indicates that prunings from several crops will most likely be shredded on site, or already are shredded on site, as an alternative to open burning. The table below is a comprehensive c omparison of the average annual PM 2.5 emissions from open burn versus shred ding for the aforementioned crops. For purposes of this analysi s, District staff assumed the average burn acres would remain constant and that a ll burn acres would be

shredded on site.

The information for this analysis was derived by in putting the burn acre data from the “Average Annual Tons, Acres, and Emissions from Open Burning of Crops (2007-2009) table presented in Section 5-1 of this report into the District

Emissions Calculator. The District Emissions Calcu lator incorporates the emissions from various pieces of equipment, includi ng tractors and excavators associated with the activity, emissions from transf er and delivery vehicles, and other processes such as chipping, as well as the em ission factor for each crop type and activity. The data presented in the table below is a comprehensive emission inventory encompassing all aspects of the affected crops.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5

- 5 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning Table 5-3 Comparison of the Average Annual PM 2.5 Emissions From Open Burning and Shredding (2007-2009)

PM 2.5 Emissions (Tons)

Crop Name Burn

Acres Open Burn Shred

Almond Pruning 51718 203.0 4.8
Apple Pruning 391 3.5 0.1
Fig Pruning 558 4.8 0.1
Pear Pruning 110 1.1 0.01
Pecan Pruning 295 2.0 0.0

Quince 28 0.2 0.003
Walnut Pruning 14236 67.0 1.4

Total: 67336 281.6 6.4

Orchard Removal Materials The analysis in this report also indicated that sev eral crops are sent to the biomass facilities and will most likely continue to be sent to biomass facilities as biomass fuel as an alternative to open burning. Th e table below is a comprehensive comparison of the average annual PM 2 .5 emissions from open burn versus biomass processing for the aforemention ed crops. For purposes of this analysis, District staff assumed the average b urn acres would remain

constant and that all burn acres would be sent to t he biomass plant as fuel.

The information for this analysis was derived by in putting the burn acre data from the “Average Annual Tons, Acres, and Emissions from open burning of Crops (2007-2009) table presented in Section 5-1 of this report into the District

Emission Calculator. The District Emission Calcula tor incorporates the emissions created from various pieces of equipment, including tractors and excavators associated with the activity, emissions from transfer and delivery vehicles, and other processes such as chipping, as well as the emission factor for each crop type and activity. The data presente d in the next table is a comprehensive emission inventory encompassing all a spects of the affected

crops.

Table 5-4

Comparison of the Average Annual PM 2.5 Emissions From Open Burning and Biomass Operations (2007-2009 )

PM 2.5 Emissions (Tons)

Crop Name Burn

Acres Open Burn Biomass

<20 Acre Orchard Removal (all crops) 2334 264.2 32.8

Citrus Orchard Removal 1801 203.9 25.3
Fig Orchard Removal 80 9.1 1.1

Total: 4215 477.2 59.2San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

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- 6 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning 5.4 EMISSION REDUCTION ANALYSIS

5.4.1 Introduction

Revised proposed postponements of CH&S burning proh ibitions as described elsewhere in this report will result in greater cur tailment of agricultural open burning currently allowed under District Rule 4103. The revised proposed postponements will result in the following addition al prohibitions:

Orchard Removals

• The prohibition of burning of all orchard removals from fig crops over 15 acres (District Rule 4103 currently allows burning at all acreage sizes).

• The prohibition of burning of all orchard removals for all crops (with the exception of citrus, apples, pears, and quince) wit h acreages over 15 acres up to and including 20 acres (District Rule 4103 cu rrently allows burning of acreages in this range).

Prunings

• The prohibition of burning of all orchard pruning material from fig crops for all acreages (District Rule 4103 currently allows burni ng at all acreage sizes).

• The prohibition of burning of prunings for each ag ricultural operation whose total nut acreage (i.e., almonds, walnuts, and peca ns) at all agricultural operation sites is 3,500 acres or more. For each a gricultural operation whose total nut acreage at all agricultural operation sit es is less than 3,500 acres, burning of up to 20 acres of prunings per year is a llowed plus additional acreage when a determination of economic hardship i s made by the District (District Rule 4103 currently allows burning at all acreage sizes).

The estimated emission reductions to be achieved by the new prohibitions listed above are presented in Table 5-5. Details of the e mission reduction analysis are discussed in the next section (Methodology and Calc ulations).San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

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- 7 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning Table 5-5 Total Annual Emission Reductions from All New Open Burning

Prohibitions

Category Crop Nox (ton/year) PM2.5

(ton/year) VOC

(ton/year)

Figs 2.8 6.7 6.1

Orchard

Removals All Orchards

Less Than

20 Acres* 25.8 61.7 56.4

Figs 0.4 2.1 1.7

Almond 9.5 48.8 38.0

Pecan 0.0 0.1 0.1 Orchard Prunings

Walnut 0.7 3.7 2.9

Total 39.2 123.1 105.2

* except citrus, apples, pears and quince

5.4.2 Methodology and Calculations

Step 1: Determine the reduction in acreage which will be burned as a result of the new prohibitions

District staff analyzed information collected durin g 2007-2009 from the District’s Smoke Management System (SMS) in order to estimate the reduction in acreage of burning resulting from the new prohibitions. Th e SMS manages agricultural open burning in the San Joaquin Valley Air Basin (S JVAB) and collects and maintains information pertinent to the amount and t ype of material burned in the SJVAB. For each permitted open burning operation d uring the time period, the SMS identifies the specific item burned and the ass ociated acreage.

In order to estimate the reductions in acreage of o rchard burning resulting from each of the new orchard prohibitions listed, it was assumed that average annual acreage of permitted burns in the SMS for the perio d 2007-2009 is representative of the expected burning reduction for each category

. Extraction and analysis of data from the SMS for or chard removals yielded the following annual reductions in acres burned:San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

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- 8 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning Table 5-6 Data from the SMS for Orchard Removal and Pruning

New Prohibition Annual

Reduction in Acreage Burned

Orchard removals from fig crops over 15 acres 61

Orchard pruning material from fig crops for all acr eages 557

Orchard removals for all crops (with the exception of citrus, apples, pears, and quince) 560

Almond pruning material 12,670

Pecan pruning material 22

Walnut pruning material 969

Step 2: Establish Applicable Emission Factors on a Per A cre Basis

Differential emission reduction factors for orchard removals and for orchard prunings, along with the basis for their developmen t, are presented in Tables 5-7 and 5-8 respectively of the cost and emissions sect ion of this staff report (Chapter 5).

Differential emission reduction factors for orchard removals (assuming 30 tons dry biomass per acre) are based on chipping and con version of the removed trees to biomass fuel rather than burning:

Differential

Emission

Factor (tons/acre) = Burning

Emission

Factor (tons/acre) - Chipping/Biomass

Emission Factor (tons/acre)

From Table 5-4 of the cost and emissions section th e differential emission factors

for orchard removals between 15 and 20 acres are:

NO

x 0.0460 tons per acre

PM 2.5 0.1101 tons per acre VOC 0.1007 tons per acreSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5

- 9 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning Differential factors for prunings (assuming 1 ton o f dry prunings per acre) are based on chipping and land incorporation of pruning s in lieu of burning:

Differential

Emission

Factor (lb/acre) = Burning

Emission

Factor (lb/acre) - Land

Incorporation

Emission Factor (lb/acre)

From Table 5-8 of the cost and emissions section th e differential emission factors for orchard prunings are:

NO

x 1.5 lb per acre

PM 2.5 7.7 lb per acre VOC 6.0 lb per acre

Step 3: Apply Applicable Emission Factor to Acreage Data Extracted from the

SMS

Tables 5-11 and 5-12 present the results for orchar d removals and prunings respectively.San Joaquin Valley Unified Air Pollution Control District May 20, 20105-10Chapter 5: Emissions from Agricultural Burning andAlternatives to Burning and Health ConsiderationsRevised Proposed Staff Report andRecommendations on Agricultural BurningTable 5-7Emission Reductions from New Orchard Removal ProhibitionsProhibitionNOx PM2.5 VOCCropCurrentPermittedOpenBurningNewProhibitionAcresReducedper SMSDifferentialEmissionFactor(ton/acre)AnnualEmissionReduction(tons)DifferentialEmissionFactor(ton/acre)AnnualEmissionReductiontons)DifferentialEmissionFactor(ton/acre)AnnualEmissionReductiontons)FigsPermittedat allacreagesProhibitedfor acreagegreater than15 acres61 0.046 2.8 0.1101 6.7 0.1007 6.1All other crops(with theexception ofcitrus, apples,pears, andquince)Permittedfor 20acres orLessProhibitedfor acreagegreater than15 acres560 0.046 25.8 0.1101 61.7 0.1007 56.4San Joaquin Valley Unified Air Pollution Control District May 20, 20105-11Chapter 5: Emissions from Agricultural Burning andAlternatives to Burning and Health ConsiderationsRevised Proposed Staff Report andRecommendations on Agricultural BurningTable 5-8Emission Reductions from New Orchard Pruning ProhibitionsProhibitionNOx PM2.5VOCCropCurrentPermittedOpenBurningNewProhibitionAcresReducedper SMSDifferentialEmissionFactor(lb/acre)AnnualEmissionReduction(ton)DifferentialEmissionFactor(lb/acre)AnnualEmissionReduction(ton)DifferentialEmissionFactor(lb/acre)AnnualEmissionReduction(ton)FigsPermittedat allacreagesProhibited forall acreages557 1.5 0.4 7.7 2.1 6.0 1.7Almond (surfaceharvested crop)Permittedat allacreagesProhibited foracreagegreater than20 acres12,670 1.5 9.5 7.7 48.8 6.0 38.0Pecan (surfaceharvested crop)Permittedat allacreagesProhibited foracreagegreater than20 acres22 1.5 0.0 7.7 0.1 6.0 0.1Walnut (surfaceharvested crop)Permittedat allacreagesProhibited foracreagegreater than20 acres969 1.5 0.7 7.7 3.7 6.0 2.9San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-12 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning 5.5 HEALTH BENEFITS OF REDUCED OPEN BURNING

Given the minimal impact of open burning on ozone l evels in the Valley mentioned above, this discussion emphasizes the hea lth benefits of reduced open burning and associated PM 2.5 emissions. Prio r scientific studies as well as District experience have shown the importance of steadily reducing population exposure to PM 2.5 through controls on residential wood burning and open burning. The San Joaquin Valley experiences some o f the highest annual average concentrations of PM 2.5 in the nation. We ll-defined epidemiological relationships have been established between exposur e to elevated PM 2.5 and a range of health endpoints, including ischemic heart disease, asthma, chronic bronchitis, premature mortality, and others. The r egion can experience multi-day periods of atmospheric stagnation during which very little air mass is transferred in and out of the Valley. The net result can be a daily buildup of PM 2.5 levels, sometimes beyond the 24 hour federal standard of 35 μg/m 3

.

Unlike areas such as Southern California where PM 2 .5 levels are more distributed throughout the year, fine particulates are seasonally concentrated in the Valley. Because of this seasonal concentration effect, District controls currently imposed on open burning and residential w ood burning have had a disproportionate effect in reducing wintertime PM 2 .5 concentrations. In the case of residential wood burning, an external scientific evaluation was conducted by California State University (CSU) Fresno of Rule 49 01’s periodic curtailments (see www.cvhpi.org). This assessment found that as of the winter 2007-08 season (prior to the October 2008 amending of Rule 4901), daily curtailments coupled with reduced household wood burning overall had resulted in a 12.9%

and 13.6% reduction in annual PM 2.5 concentrations for Bakersfield and Fresno, respectively. Using the US EPA’s BenMAP mo del for calculating health benefits of reduced PM2.5 exposure, these reduction s translated into significant public health benefits, including significantly red uced cardiovascular disease, pulmonary disease, and pre-mature deaths.

A key element in this success has been the impositi on of restrictions in residential wood burning on days when meteorologica l conditions create the risk of health standard violations. Initially, as of No vember 1, 2003, that threshold

was established at the 1997 24 hr. PM 2.5 standard of 65 μg/m 3 . As amended in October 2008 for the 2008-09 winter season, that da ily curtailment threshold was substantially reduced to 30 μg/m 3 . That reduced curtailment threshold has benefited public health in three ways: First, it h as resulted in an absolute reduction in the total seasonal tonnage of resident ial wood burned. Second, it has insured that on days when wood burning is allow ed, each ton of emissions is more thoroughly diluted and dispersed, with attenda nt reductions in harmful peak exposures. And third, by restricting burning to da ys with reasonably goodSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-13 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning atmospheric dispersion, the formation of secondary aerosols such as ammonium nitrate during multi-day stagnation events is minim ized.

By restricting the analysis to the Bakersfield and Fresno/Clovis metro areas, the health evaluation of Rule 4901 (Wood Burning Firepl aces and Wood Burning Heaters) was made possible by a well-defined pre-an d post-Rule 4901 population exposure estimate for PM2.5. However, i n the case of health benefits from reduced burning under Rule 4103, it is not pos sible to replicate this analysis for several reasons. First, ambient monitors are g enerally not found in rural areas. In addition, the population density is cons iderably lower. As a result, estimating accurate population exposure reductions resulting from current or revised proposed reductions on agricultural burning is very difficult and not attempted here.

However, it is possible to draw on the experience o f the District evaluation of

Rule 4901 to draw some reasonable conclusions that provide a public health justification for past and prospective reductions i n open burning under Rule 4103. First, the basin-wide emissions inventory for open burning and residential wood combustion are comparable. According to the 2008 C ARB emissions inventory, estimated tons per day (tpd) of PM2.5 from wood bur ned by households was 9.5 and 14.8 for agricultural material. Second, it is important to note at that as of December 2009, daily county-level curtailments of o pen burning are based on the same predicted 24 hr. 30 μg/m 3 concentration threshold used in Rule 4901. This means that a predominant source of rural and u rban open burn emissions has been eliminated on low dispersion days, with co rresponding reductions in overall exposure to individuals in areas where open burning is occurring, as well as minimizing exposure to secondary PM2.5.

Reduced emissions from Rule 4103 are presented belo w in Table 5-9. In a historical sense, reductions achieved to date repre sent a very rapid rate of emission decline in a given economic sector, with a ttendant health benefits to a more dispersed, rural population.

Table 5-9

Reductions in Criteria Pollutants Under Rule 4103 S ince 2004

NOx PM10 PM2.5 VOC CO Total Tonnage Reduction Since 2004 1,217 1,981 1,860 1,516 15,273

% Reduction Since 2004 48.9% 52.7% 52.6% 50.4% 48.5%

TPD Reduction Since 2004 3.3 5.4 5.1 4.2 41.8

Additional reductions anticipated under the amended Rule 4103 are shown above. The more modest reductions arising from the revised proposed

recommendations reflect the current balance of comm odity profitability and costs for processing at biomass plants, as defined by the CH&SC. Past experienceSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-14 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning has shown that the per unit costs of alternative di sposal options with less environmental impacts tend to decline over time due to, in this case, new biomass plant capacity and the emergence of alterna tive disposal technologies. The District supports legislation that will encoura ge, promote and facilitate alternative uses for agricultural material as well as policies and initiatives that encourage renewable energy and energy efficiency in cluding supporting legislation that provides additional biomass capaci ty utilizing agricultural materials. It is likely that the current constrain ts on open burning emission reductions imposed by the CH&SC will be reduced ove r time, with proportional

health benefits.

5.6 HEALTH RISK ASSESSMENT OF OPEN BURNING AND

ALTERNATIVES

Often under the requirements of CEQA-mandated risk assessments, the District routinely employs several health risk assessment (H RA) models in order to estimate health risks posed by exposure to air poll utants from existing or hypothetical sources. These HRA models are based o n the following elements: (1) knowledge from prior scientific studies about t he relative toxicity of pollutants, (2) similar knowledge about the relative effects of increased concentrations of a given pollutant, (3) the hourly rate of emissions b y mass or parts per volume, i.e. emission factor, from a given source and the durati on of those emissions, (4) specification of meteorological conditions, (5) how the pollutants are dispersed and/or transformed in the atmosphere, (6) a gradien t or exposure surface that specifies various concentration levels at a given d istance from a source and time, (7) (in some cases) the spatial distribution and ch aracteristics of the exposed population, and (8) (in some cases) whether and how different sub-populations may be differentially affected such as children to a given level and duration of

exposure.

To evaluate the acute (short-term) and chronic (lon g-term) health impact of open burning of agricultural material and alternative di sposal methods, the following scenarios were analyzed (modeled):

Scenario 1: Open burning of prunings from 20 acres of nut trees. Emission

sources included diesel exhaust from equipment used to form the burn piles, and emissions from combustion of the or ganic material.

Scenario 2: Land incorporation of prunings from 20 acres of nut trees. Emission

source included diesel exhaust from equipment used to shred and incorporate prunings into the soil.

Scenario 3: Transfer of prunings from 20 acres of nut trees to a biomass facility.

Emission sources included diesel exhaust from equip ment used to collect and chip/shred prunings, diesel exhaust fro m trucks used to transport the chipped material to the biomass plant , diesel exhaustSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-15 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning from equipment used to unload and process the chipp ed material at the biomass plant, and emissions from the biomass c ombustor.

Scenario 4: Open burning of 20 acres of nut trees (orchard removal). Emission

sources included diesel exhaust from equipment used to form the burn piles and emissions from the combustion the or ganic material.

Scenario 5: Transfer of 20 acres of nut trees (orc hard removal) to a biomass

facility. Emission sources included diesel exhaust from equipment used to collect and chip/shred the orchard material , diesel exhaust from a truck used to transport the chipped material to the biomass plant, diesel exhaust from equipment used to unload and process the chipped material at the biomass plant, and emis sions from the

biomass combustor.

5.6.1 Methodology and Calculations

Emissions for each scenario evaluated were calculat ed using District-developed spreadsheets and the parameters listed below:

Table 5-10

Variables used to estimate scenario emissions

Variables Prunings Orchard

Removal Crop type Orchard Orchard Ag material (acres) 20 20 Material removed (tons/acre) 1 30 Roots removed (tons/acre) 0 1 Field equipment activity (hours/acre) 1 1 Power plant equipment activity (hours/acre) 2 2 Ag material delivered to power plant (tons/truck) 24 24

Round trip distance to power plant (miles) 100 100

Off-road diesel equipment was used to process crop material in the field and at the biomass facility. Off road equipment activity was modeled as an area source over the entire surface of the orchard or that port ion of the biomass facility used to receive and process wood chips. All particulate matter from off-road diesel equipment exhaust was modeled as diesel particulate matter (DPM). Relative risks generated by air contaminants from the open b urning of agricultural material were calculated using the California Air Resources Board (CARB) particulate matter speciation profile 450 for particulates, and emission factors from Lemieux, Lutes and Santoianni (2002) for volatile organic co mpounds. Emissions from open burn piles were modeled as point sources to al low for thermal loft from the heat of combustion. The open burning of orchard pr unings was assumed toSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-16 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning occur in four separate piles located at the souther n border of the orchard. The open burning of the orchard removal material was as sumed to occur in twenty piles evenly distributed within the orchard over a 24 hr. period. All particulate

matter from on-road diesel truck exhaust was modele d as DPM. On-road truck travel was modeled as a line source consisting of a one mile series of volume

sources.

To calculate pollutant dispersion and the resulting exposure gradient, the AERMOD model was used. Meteorological data for 200 4-2008 from Bakersfield was employed to determine the dispersion factors (i .e., the predicted

concentration or Χ divided by the normalized source strength or Q) fo r a receptor (human population) grid. These dispersion factors were input into the Hot Spots Analysis and Reporting Program (HARP) risk assessme nt module to calculate

the chronic and acute hazard indices as well as the carcinogenic risk for five

scenarios outlined above. No actual locations and nearby populations were used in the model analysis.

5.6.2 Health Risk Assessment Results

Worst case health risks for the open burning of agr icultural material and their alternatives are presented in Table 5-11 (pruning s cenario) and Table 5-12 (orchard removal scenario). The model results for open burning of prunings

show that the cancer risk and chronic hazard indice s are very low and not of concern for all disposal options. The acute hazard index in this case pertains to risk of an acute respiratory response over the shor t-term (24 hour) exposure generated by the burning of the prunings for a pers on standing within 25 meters of the burn piles. In this air pollutant modeling scenario, any acute hazard index score of over 1.0 indicates the potential for a neg ative impact on respiratory health. As shown, this threshold is not exceeded f or a maximum 24 hour. exposure scenario.

In the case of a worst-case health risk assessment for orchard removal options are shown in Table 5-11. As in the case of pruning s, cancer and chronic hazard indices for all options are very low values that do not indicate excessive risk. As shown in Figure 5-3, the open burning exposure scen ario is based on the assumption that removed trees are put into 20 piles , one per acre, and burned simultaneously. In this case, the acute hazard ind ex score for 24 hr. exposure in the zone nearest the burn piles is excessive (10.70 ). As one moves further from

the burn zone this relative hazard to short-term re spiratory health drops relatively quickly, falling by approximately 50% after 500 met ers and to an acceptable level of less than 1.0 after 1,000 meters.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-17 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning Table 5-11 Comparative Pruning Risk (20 Acres): Open Burning vs. Chipping/Shredding and Incorporation vs. Biomass Facility

Health Risk

Source Maximum

Individual Cancer

Risk 2
(x 10 -6 ) Acute Hazard

Index Chronic Hazard

Index

Orchard Burning 3.32 0.83 0.07 Land Incorporation 7.59 nc 1 nc Biomass Facility – Off Site

Orchard 9.69 nc nc

Transit 0.00 nc nc

Off Site Total 9.69 nc nc Biomass Facility – On Site Facility 0.10 0.00 0.00

Transit 0.00 nc nc

On Site Total 0.10 0.00 0.00

1 Acute and Chronic Hazard Indices were not calculat ed since there is no risk factor or the risk factor is so low that it has been determined to be insignificant for this type o f unit.

2 70 year exposure used.

Table 5-12 Comparative Orchard Burning Risk (20 Acres): Open Burning vs. Chipping/Shredding,

On-Site Biomass Facility vs. Off-Site Biomass Facil ity

Health Risk

Source Maximum

Individual Cancer

Risk 2

(x 10 -6 ) Acute Hazard

Index Chronic Hazard

Index

Orchard Burning 2.69 10.70 0.58 Biomass Facility – Off Site

Orchard 1.84 nc 1 nc
Transit 0.09 nc nc

Off Site Total 1.93 nc nc Biomass Facility – On Site Facility 0.55 0.00 0.00

Transit 0.09 nc nc

On Site Total 0.65 0.00 0.00

1 Acute and Chronic Hazard Indices were not calculat ed since there is no risk factor or the risk factor is so low that it has been determined to be insignificant for this type o f unit.

2 9 year exposure used.San Joaquin Valley Unified Air Pollution Control District May 20, 20105-18Chapter 5: Emissions from Agricultural Burning andAlternatives to Burning and Health ConsiderationsRevised Proposed Staff Report andRecommendations on Agricultural BurningFigure 5-3Acute Respiratory Risk Isopleths for Open Burning of Prunings (24 hr exposure)San Joaquin Valley Unified Air Pollution Control District May 20, 20105-19Chapter 5: Emissions from Agricultural Burning andAlternatives to Burning and Health ConsiderationsRevised Proposed Staff Report andRecommendations on Agricultural BurningFigure 5-4Acute Respiratory Risk Isopleths for Open Burning of Orchard Removal (24 hr exposure)San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-20 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning There are a number of practices currently employed by District Compliance staff under the policy for Rule 4103 that are designed to minimize the potential health hazard of orchard removal burnings of this scale. The Appendix A (p. 7) from the Rule 4103 District Policy identifies the conditions that must be satisfied when District Compliance staff conduct their mandatory f ield site inspections prior to granting approval to proceed with burning:

Burn permits issued in rural residential areas , or in other areas where smoke may affect smoke sensitive areas, must include sitespecific instructions and permit conditions. The in structions and/or conditions must limit the possible smoke impact on nearby neighbors and/or smoke sensitive areas.

1. The permit applicant must be advised that only t hose materials produced along with the crop and listed on the burn permit may be permitted to burn.

2. Additional permit conditions may stipulate any o r all of the following:

a. The wind direction required at the time of ignit ion b. The burn site location on the property c. The day(s) of the week the burning may occur d. The time of day a burn may be ignited e. The time of day to cease burning or cease adding material to

the fire f. The size of the burn pile permitted to be burned at one time g. The permit will be issued for the duration of ne ed only.

Compliance Appendix A (p. 35) from the Rule 4103 Di strict Policy also makes explicit limits on burning in smoke sensitive areas with greater population

densities or facilities with sensitive individuals:

SMOKE SENSITIVE AREAS : Smoke sensitive areas are populated areas or other areas where smoke and air pollutants can adversely affect public health or welfare. These areas can in clude cities, towns, communities, campgrounds, trails, recreation al areas, hospitals, nursing homes, medical clinics, schools, day-care centers, roads and highways, airports, public event s, and shopping

centers.

A District on-site inspection is required near dens e populations or

smoke sensitive areas. If the District determines t here is a reason to believe smoke produced from a proposed burn may causeSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-21 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning complaints or create a nuisance, the burning may on ly be permitted under the following conditions:

A. The District must determine there is no other reasonable method of disposal.

B. The quantities of materials to be burned shall be limited as

needed.

C. The days burning may be authorized may be limit ed. For example, a burn site upwind from a school may have to limit burning to when school is not in session, such as o n weekends or during school vacation provided that no other sp ecial events or school functions are occurring during these off times.

D. Permittee must establish and provide an at-read y means to extinguish the fire if directed to do so by the Dis trict or any public officer.

E. Additional permit conditions may stipulate:

1. The wind direction required at the time of ignit ion. 2. The burn site location on the property. 3. The day(s) of the week the burning may occur. 4. The time of day a burn may be ignited. 5. The time of day to cease burning or cease adding material

to the fire. 6. The size of the burn pile and/or the number of b urn piles

authorized to burn at one time. 7. The permit will be issued for the duration of ne ed only.

F. If any of the conditions provided above cannot b e met, such burning shall not be permitted.

Because of these limitations, excess acute health r isks from orchard removals are minimized. As noted above, the overall traject ory of health risks from agricultural open burning has been following a stee p downward path since 2004.

The results of this health risk assessment undersco re the logic of (1) the current

balance stuck under the current CH&SC between the e conomic costs of alternatives to burning on the one hand and the pot ential health impacts of open burning on the other, as well as (2) the ongoing im portance of finding new incentives and technologies for the long-term elimi nation of open burning of agricultural materials.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

5-22 Chapter 5: Emissions from Agricultural Burning and Alternatives to Burning and Health Considerations Revised Proposed Staff Report and Recommendations on Agricultural Burning This page intentionally blank.Revised Proposed Staff Report and Recommendations on Agricultural Burning



## Chapter 6

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



## .San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

6-1 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-2 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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 these services consistent with quoted project minimums fo r smaller chipping operations.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

6-3 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning 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, 20106-4Chapter 6: Cost Impacts ofAlternatives to BurningRevised Proposed 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

6-5 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-6 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-7 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-8 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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.

• Wheel loader emissions are estimated based on a 25 0 hp Tier 2 diesel engine operating at a rate of one hour per acre.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

6-9 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning 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

6-10 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-11 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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.

• 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.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010

6-12 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning 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, 20106-13Chapter 6: Cost Impacts ofAlternatives to BurningRevised Proposed 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 $244 for root compostingTable 6-4Per Acre Emissions and Costs Using District DataOpen Burning versus Grind and Haul for Orchards other than CitrusCost Basis: Chipper Contractor Quotations Jan 2010OrchardRemovalSizeOpen BurningGrind & HaulDifferenceEmissionsTons per AcreCost$/acreEmissionsTons per AcreCost$/acreEmissions ReductionTons per AcreCost$/acreSan Joaquin Valley Unified Air Pollution Control District May 20, 20106-14Chapter 6: Cost Impacts ofAlternatives to BurningRevised Proposed 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, 20106-15Chapter 6: Cost Impacts ofAlternatives to BurningRevised Proposed 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

6-16 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-17 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed 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

6-18 Chapter 6: Cost Impacts of Alternatives to Burning Revised Proposed Staff Report and Recommendations on Agricultural Burning This page intentionally blank.